-------
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
-------
I
UJ
UJ
to
4
O
-=
E
UJ
£
CO
I
I
O
l
CO
o
g
g
£
o
Q
o
I
UJ
cc
cc
a
UJ
CO
CO
g
a.
o
o
a
o
i
HI
Q
O
Figure 1. Sacrificial Anode and Impressed Current Cathodic Protection
-------
(*)
CURRENT
FLOW
I ELECTRON
I FLOW
SEAWATER
(ELECTROLYTE)
CATHODE
•'M->M*n
4OHT
2H'+2e" ->
ANODE:
-CONSUMED IN THE
ELECTROCHEMICAL REATION
- SITE OF OXIDATION
REATION(S)
CATHODE:
- PROTECTED SURFACE
- SITE OF REDUCTION REACTION(S)
- OTHER REDUCTION REATIONS ARE
POSSIBLE.
Figure 2. Electrochemical Cell
-------
Figure 3. Impressed Current Cathodic Protection System
-------
1. Observed Zinc Consumption Rate:
(aggregate of in-port and underway)
Per 23-lb Anode
50% of 23 lb/3 years
= 3.83 Ib zinc/yr
Per Pound of Anode
3.83 (Ib zinc/yr)/ 23 Ib anode
= 0.167 Ib zinc/yr/lb of anode
2. Fraction of Year Vessel is:
In Port
365 days/yr
= 0.48
Underway
189 days/yr
365 days/yr
= 0.52
3. Annual Zinc Corrosion/Dissolution Rate:
let x = in port corrosion/dissolution rate,
and 4x = underway corrosion/dissolution rate
0.48 (x) + 0.52 (4) (x) = 0.167 (Ib zinc/yr)/lb of anode
x = 0.065 (Ib zinc/yr)/lb of anode
4x = 0.261 (Ib zinc/yr)/lb of anode
note: the underway corrosion/dissolution rate is 4 times the in port rate as discussed in section 3.2.1
and reference 3 and 10.
4. Hourly zinc corrosion/dissolution rate: In-Port
(per Ib anode)
0.065 (Ib zinc/lb anodeVvr
8760hr/yr
Underway
0.261 (Ib zinc/lb anode)/yr
8760 hr/yr
= 7.4 x 10"6 (Ib zinc/lb anode)/hr = 3.0 x 10"5 (Ib zinc/lb anode)/hr
5. Unit conversion:
Average density of zinc anodes (Table 2) = (1,862,000 Ib) / (10,861,000 ft2) = 0.17 Ib/ft2
In-Port: (7.4 x W6 (Ib zinc/lb anode)/hr)( 0.17 Ib/fl2) = 1.3 xlO^lb zinc/ft2)/^
Underway (3.0 x 10'5 (Ib zinc/lb anode)/hr) ( 0.17 Ib/ft2) = 5.1 x W6 (Ib zinc/ft2)/^
Calculation Sheet 1. Calculation of Corrosion/Dissolution Rates from Sacrificial Anodes
-------
Vertical tidal excursions for 1996 is based on the summation of the daily outgoing tides (i.e., high-high
water to low-low water and high water to low water).
San Diego
• Surface Area = (10,532 acres) (4046.2 m2/acre) = 4.26 x 107 m2
* Total annual vertical tidal excursion for 1996 = 884.5 m
Average tidal excursion = (884.5 m/yr)/((365 days/yr)(2 tides/day) = 1.2 m
• Tidal prism volume for 1996 = (4.26 x 107 m2) (884.5 m) = 3.77 x 1010 m3
= 3.77xlOl3L
Mayport
• Surface Area = (169.8 acres) (4046.2 m2 /acre) = 6.87 x 10s m2
• Total annual vertical tidal excursion for 1996 = 970.3 m
Average tidal excursion = (970.3 m/yr)/((365 days/yr)(2 tides/day) = 1.3 m
• Tidal prism volume for 1996 = (6.87 x 10s m2 ) (970.3 m) = 6.67 x 108 m3
= 6.67xlOuL
Pearl Harbor
• Surface Area = (3,031 acres) (4046.2 m2/acre) =1.23 x 107 m2
• Total annual vertical tidal excursion for 1996 = 278.2 m
Average tidal excursion = (278.2 m/yr)/((365 days/yr)(2 tides/day) = 0.38 m
• Tidalprismvolumeforl996 = (1.23xl07m2)(278.2m) =3.41xl09m3
= 3.41 x!012L
Calculation Sheet 2. Calculation of Tidal Prism Volumes for San Diego, CA; Mayport,
FL; and Pearl Harbor, HI
-------
1. Concentration = (Mass of Zinc) / (Volume)
2. Volume modeled as a half-immersed cylinder:
Ship Class: FFG7
Length = 415 ft
Underwater Wetted Area = 19,850 ft2 = 72(2)(7r)(R,Xlength)
= = (I)
=>R! = 15.225 ft(
Volume(modci) = V2 -V,
Vt = '/^(RO^length) = 151,1 10 ft3
V2 = '/27i(R, + d)2(length)
d = variable (1 ft for this sample calculation)
Volume = V2 - V, = ['/2TC(15.225 ft + 1 ft)2(415 ft)] - (151,1 10 ft3)
= 20,500 ft3
3. Mass of zinc:
Mass = (generation rate)(mass of anode installed)(time between water exchanges)
Generation rate = 7.4 x 10"6 (Ib zinc/lb anode-hr)
Mass of installed anodes = (172 anodes)(23 Ib/anode) = 3,956 Ib
Time between water exchanges = variable (1 hr for this sample calculation)
Mass of zinc generated = (7.4 x Iff6 (Ib zinc/lb anode-hr))(3,956 Ib)(l hr)
= 0.029 Ib zinc
4. Concentration:
Concentration = (Mass of Zinc)/(Volwae)(required conversion factors)
= (0.029 Ib 2inc)(454 g/lb)(l(f}ig/g)l\(2Q,5W f?)(28.32 L/f?)]
= 22.7 ug/L s 23 ug/L
notes:
(1) Additional significant figures recommended in this step due to subsequent squaring operation.
Calculation Sheet 3. Zinc Concentration (Mixing Zone Model) Sample Calculations
-------
1. Concentration = (Mass of CPO) / (Volume)
2. Volume modeled as a half-immersed cylinder:
Ship Class: CG47
Length = 533 ft
Underwater Wetted Area = 37,840 ft2 = '/2(2)(7t)(R,)(length)
=>Rj= 22.598 ft(1)
V, = '/27i(R,)2(length) = 427,558 ft3
V2 = '/2rcR, + d)2(length)
d = variable (1 ft for this sample calculation)
Volume = V2 - V, = ['/27i(22.598 ft + 1 ft)2(533 ft)] - (427,558 ft3)
= 38,677 ft3
3. Mass of CPO:
Mass = (generation rate)(efficiency)(time between water exchanges)
Generation rate = 46.g/hr
Efficiency =100%
Time between water exchanges = variable (1 hr for this sample calculation)
Mass of CPO generated = (46.3 g/hr)(100%)(l hr)
= 46.3g
4. Concentration:
Concentration = (Mass of CPO)/(Volwns)(required conversion factors)
- (46.3 g CPO)f/0Ws>/[(38,677 tf)(28.32 L/ft3)}
= 42.3ng/L = 4
notes:
(1) Additional significant figures recommended in this step due to subsequent squaring operation.
Calculation Sheet 4. CPO Concentration (Mixing Zone Model) Sample Calculations
-------
NATURE OF DISCHARGE REPORT
Chain Locker Effluent '
1.0 INTRODUCTION
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
-------
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
-------
The chain locker is painted using epoxy polyamide, epoxy, and zinc primer. '''
The detachable links and other anchor chain components are periodically lubricated with
Termalene #2, a water-resistant grease (Commercial Item Description (CID) A-A-50433).
Termalerie #2 is a compound that includes mineral oil, an aluminum complex, a calcium-based
rust inhibitor, an antioxidant, and dye.7 The grease was tested for resistance to washout.8'9 This
test measures the water washout characteristics of lubricating greases under elevated
temperatures and mechanical operating conditions. Termalene #2 experienced "nil" washout
when tested.9 Because the grease is not exposed outside the link and due to the wash-resistant
nature of the grease, it is unlikely grease would be released to the environment.
The zinc anodes in the chain locker can be in contact with seawater for extended periods
of time. Zinc can leach continuously into the chain locker sump. The water that collects in the
chain locker is a combination of seawater and water from the firemain. Also, firemain water is
used as motive water when chain locker effluent is discharged. Therefore, the water could
contain the constituents present in the firemain water. A more complete discussion of these
constituents is found in the Firemain Systems NOD report.
The chain locker effluent might contain the priority pollutants bis(2-ethylhexyl) phthalate,
copper, iron, nickel, and zinc. This effluent does not contain any bioaccurnulators.
3.4 Concentrations
The concentrations of constituents present in the chain locker cannot be easily measured.
Chain lockers are kept dry on most vessels to reduce maintenance. Zinc anodes are present in the
bottom of the chain locker. Because the chain locker is often dry, it is unlikely that these anodes
significantly affect the concentration of zinc hi the effluent. The average measured
concentrations of firemain water constituents that exceed the Federal and/or most stringent water
quality criteria are presented hi Table I.10 Firemain is used as the motive water for drainage
eductors.
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. Mass loadings are
discussed in Section 4.1 and the concentrations of discharge constituents after release to the
environment are discussed in Section 4.2. In Section 4.3, the potential for the transfer of non-
indigenous species is discussed.
4.1 Mass Loadings
Mass loadings were not calculated because constituent concentrations were not estimated.
Chain locker effluent is not anticipated to result in significant loads within 12 n.m. because of the
Chain Locker Effluent
4
-------
infrequency of discharge and because of the management practices in place which pump this
discharge overboard when the vessel is beyond 12 n.m. of shore. Chain locker effluent is
discharged infrequently because only small volumes of water accumulate in the chain locker
sump over time. This determination was made after inspections of chain lockers aboard several
ships.10'11
4.2 Environmental Concentrations
Chain locker effluent is expected to contain zinc, rust, paint, grease, and any constituents
from the firemain water. Because of the intermittent nature of this discharge, acute toxicities are
the primary concern. There is no concentration data available for chain locker effluent. Table 1
shows the concentration of constituents of firemain water that total nitrogen, bis(2-ethylhexyl)
phthalate, copper, iron, and nickel, exceed the Federal and/or the most stringent state acute water
quality criteria.
4.3 Potential for Introduction of Non-Indigenous Species
Inspections of chain lockers aboard several ships revealed that only small amounts of
water actually accumulate within the chain locker. Therefore, there is little potential for
introducing non-indigenous species into the chain locker. The process of washing down the
anchor as it is taken aboard and discharging the effluent beyond 12 n.m. further reduces the
possibility of transferring species via the chain locker.2
5.0 CONCLUSIONS
The small volume of chain locker effluent results in small mass loadings and provides
little opportunity for the transfer of non-indigenous species. The discharge volume is expected to
be small even if the discharge was not controlled. Therefore, this discharge has a low potential
for causing adverse environmental effects.
6.0 DATA SOURCES AND REFERENCES
To characterize this discharge, information from various sources was obtained. Table 2
shows the source of the data used to develop this NOD report.
Specific References
1. UNDS Equipment Expert Meeting Minutes - Anchor Chain Washdown and Chain Locker
Effluent. July 30, 1996.
2. OPNAVINST 5090.IB, Environmental and Natural Resources Program Manual,
November 1 1994.
Chain Locker Effluent
5
-------
3. UNDS Round 2 Equipment Expert Meeting Minutes. March 11,1997.
4. Military Specification MIL-P-24441, Epoxy polyamide. July 1991.
5. Performance Specification MCL-PRF-23236, Epoxy. April 1990.
6. Naval Ships' Technical Manual (NSTM). Chapter 631, Paragraph 8.23.2.1. Preservation
of Ships in Service. December 1996.
7. Bel Ray Company, Inc., Material Safety Data Sheet for Termalene #2. 1996.
8. The American Society for Testing and Materials (ASTM) test method D-1264. June
1996.
9. Bel Ray Company, Inc., Product Data Sheet for Termalene #2. 1993.
10. UNDS Phase 1 Sampling Data Report. Volumes 1-13, October 1997.
11. Navy Fleet Technical Support Center Pacific (FTSCPAC) Inspection Report Regarding
Elevator Pit and Anchor Chain lacker Inspection Findings on Six Navy Ships, March 3,
1997.
General References
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
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
-------
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.
Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.
New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
.*
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201A, Washington Administrative Code (WAC).
Van der Leeden, et al. The Water Encyclopedia, 2nd Ed. Lewis Publishers: Chelsea, Michigan,
1990.
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. 23 March 1995.
Chain Locker Effluent
7
-------
MATCH MARKS
NOTCH
Figure 1. Schematic Diagram of a Typical Detachable Chain Link
Chain Locker Effluent
8
-------
Figure 2. Schematic Diagram of a Typical Chain Locker
Chain Locker Effluent
9
-------
Table 1. Concentrations of Constituents of Wet Firemain Discharge
that Exceed Water Quality Criteria
Constituents
Classicals (ug/L)
Total Nitrogen
Organics (ue/L)
Bis(2-ethyJhexyl)
phthalate
Metals (ug/L)
Copper
Dissolved
Total
Iron
Total
Nickel
Dissolved
Total
Log-normal
Mean
Effluent
500
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
During in-port refuelings of surface vessels, compensated ballast is discharged at a rate of
up to 400 gpm per tank group (2,400 gpm maximum per ship). Based on actual refueling data
obtained from Navy personnel, each ship takes on about 200,000 gallons per refueling in port and
the refuelings occur on average two times per year per ship.5
3.3 Constituents
The Navy has conducted several studies of compensated ballast in the past. These
included:
• in-port refueling test of the USS Nicholson (DD 982);6
• at-sea refueling testing of the USS Spruance (DD 963);7
• in-port and at-sea testing of the USS John Hancock (DD 981 );8 and
• in-port testing of the USS Arleigh Burke (DDG 51).9'10
These previous studies have typically measured the oil concentration of the discharge.
On the DDG 51, in-line oil content monitors were used in conjunction with standard laboratory
analyses to determine the oil concentration in the discharged ballast water. Table 1 summarizes
the data for oil concentration in compensated ballast water from the previous Navy studies. The
concentration of oil in water varied from below detection levels to 370 milligrams per liter
(mg/L).
To further support this NOD report, a sampling effort was conducted. Five samples of
compensated ballast discharge, and an additional quality assurance/quality control sample, were
taken through the course of an in-port refueling operation from the discharge of a single midship
tank group of the USS Arleigh Burke, (DDG 51) on January 27,1997.11 Based on previous Navy
operational and design experience, midship tank groups on DDG 51 Class vessels are expected to
contain the greatest concentration of fuel oil constituents in the ballast water. The samples were
analyzed for volatile and semivolatile organics, selected classical pollutants, metals, and mercury
using EPA series 1600 protocols. Table 2 presents a summary of the validated analytical data
for all detected analytes from the sampling effort that occurred on January 27,1997. The
following priority pollutants were present in measurable amounts: copper, nickel, silver,
thallium, zinc, benzene, phenol, and toluene;12 the only bioaccumulator found was mercury.13
Also, during the UNDS sampling effort, 8 additional samples were taken and analyzed for TPH
by the modified 418-2 method, with results ranging from 11.9 to 108.2 mg/L.14
3.4 Concentrations
As mentioned in Section 3.3, Table 2 presents the validated analytical data from the
UNDS sampling effort. The table includes metals, volatile organics, semivolatile organics,
classicals, and mercury. The table shows the constituents, the log-normal mean, the frequency of
detection for each constituent, the minimum and maximum concentrations, and the mass
loadings of each constituent. For the purposes of calculating the log-normal mean, a value of
one-half the detection limit was used for non-detected results.
Compensated Fuel Ballast
5
-------
In addition to the oil concentration data collected in previous sampling as described in
Table 1, two separate sets of analyses were developed from the UNDS sampling effort to support
this NOD report. The samples were analyzed for Hexane Extractable Materials (HEM) and
Silica Gel Treated (SGT) -HEM. The HEM values correspond to oil and grease and the SGT-
HEM values correspond to total petroleum hydrocarbon (TPH) which is a subset of oil and
grease. The results varied from 8 to 36.5 mg/L for HEM and from 6 to 12.5 mg/L for SGT-
HEM.11
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
4.1 Mass Loadings
Based on ship transit data, Navy surface ships with compensated ballast systems are at
their homeport (within 12 n.m.) between 101 and 178 days per year, and at sea for the balance of
the year.15 A per-ship total annual discharge of 400,000 gallons per year was calculated based
upon the following averages obtained from Navy refueling data:
• 200,000 gallons median discharge per in port refueling; and
• 2 refuelings in port per year.
As mentioned in Section 2.3, 75 surface vessels are homeported in the U.S. and generate
compensated ballast within 12 n.m. of the U.S.16 The majority of these ships' in-port refuelings
occur at their homeport. Flow per ship class can be roughly approximated as the product of the
number of vessels in a class and 400,000 gallons discharged per ship per year as presented in
Table 3. The 75 U.S. based surface vessels discharge 30.0 million gallons within the 12 n.m.
zone.
Total mass loading, for in-port discharges, was estimated by multiplying the log-normal
mean concentration by the total compensated ballast discharge volume of 30.0 million gallons
per year. The generalized equation is shown below:
Mass Loading (Ibs/yr) = ?
(Concentration fcg/L))(Vofcme (gal/yr))(3.785 L/gal)(2.2 lbs/kg)(lQ-9kg/Mg)
Based on the SGT-HEM log-normal mean concentration of 4.65 mg/L the TPH loading
could be 1,160 pounds per year (Ibs/yr). Based on the HEM log-normal mean concentration of
12.73 mg/L, the total estimated oil & grease loading from in-port discharges could be expected to
Compensated Fuel Ballast
6
-------
be 3,180 Ibs/yr.
Using the metal log-normal mean concentrations as listed in Table 2; the mass loadings
are estimated to be 13.3 Ibs/yr for copper; 47.4 Ibs/yr for nickel; 2 Ibs/yr for thallium; 1,063
Ibs/yr for zinc; 0.77 Ibs/yr for silver; and 0.00015 Ibs/yr for mercury. Using the organic log-
normal concentration in Table 2, the mass loading was estimated to be 10.3 Ibs/yr for 2-Propenal;
and 22 Ibs/yr for benzene. Using the log-normal concentration in Table 2, the mass loading was
estimated to be 65 Ibs/yr for ammonia, 97 Ibs/yr for nitrogen, and 15 Ibs/yr for phosphorous.
These mass loadings are summarized in Table 4. The ratio of the number of vessels in each U.S.
homeport to the total of 75 compensated ballast vessels allows the loadings to be proportioned as
shown in Table 5.
4.2 Environmental Concentrations
Screening for acute toxicity was accomplished by comparing the log-normal mean
resulting from the UNDS sampling to Federal or the most stringent state water quality criteria for
these constituents. These data are provided in Table 6. Individual sample concentrations exceed
Florida criteria for oil, as indicated by SGT-HEM, but the log-normal mean does not; however,
this discharge has demonstrated that potential for causing a sheen when procedural controls are
not used.6'8 Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge
sufficient to cause a sheen on receiving waters. The Federal discharge standard is 15 mg/L based
on International Convention for the Prevention of Pollution from Ships (MARPOL 73/78).
MARPOL 73/78 as implemented by the Act to Prevent Pollution from Ships (APPS).
The log-normal mean concentrations for copper, nickel, silver, and zinc samples exceed
both Federal and most stringent state water quality criteria (WQC). The most stringent state
criteria are exceeded by the log-normal mean concentration for 2-Propenal, ammonia, benzene,
HEM, total nitrogen, phosphorous, and thallium. Mercury, a persistent bioaccumulator, was
present in three of the four samples, although it did not exceed WQC.
4.3 Potential for Introducing Non-Indigenous Species
Water taken into the fuel tanks during refueling could contain non-indigenous species,
but it is unlikely that the organisms will be transferred between ports for the following reasons:
1) Water is not taken into the compensated fuel ballast tanks during refueling operations -
water is only discharged during this operation. Water is only taken into the compensated
fuel ballast tanks during fuel transfer operations (either between compensated fuel ballast
tank groups or from a compensated fuel ballast tank to a fuel service tank). Water could
be taken into the compensated fuel ballast tanks prior to a refueling operation because
ship's personnel are trying to maximize the fuel storage on board by transferring fuel
from the compensated ballast tanks to top off the fuel service tanks. This process is
normally done at-sea prior to entering to a port facility. This process also prevents silt
and debris from shallow harbors from being introduced into the tanks.
Compensated Fuel Ballast
7
-------
2) If the ship has been generating its own electrical power for an extended period while
in-port then the fuel transfer may take place in the harbor prior to the refueling in order to
maximize the fuel stored on-board the vessel. However, the refueling that takes place
immediately after the fuel transfer will discharge the compensating water back into the
same harbor.
3) Compensating water from the fuel storage tanks is frequently flushed while the ship is
at sea due to frequent refuelings. Navy surface ships with compensated ballast systems
normally refuel every three to four days while out at sea to prevent fuel levels from
dropping below 70% capacity. Based on ship transit data, these ships are at sea between
187 and 264 days per year.11 Using the minimum number of days at sea (187), and
assuming that the ship is refueled at-sea every 4 days, results in an estimate of
approximately 46 at-sea refuelings per year compared to two in-port refuelings per year.
Therefore, there is little chance for compensating water that may have been taken on in
one port to be discharged in another port
5.0 CONCLUSIONS
Uncontrolled, compensated ballast discharge has the potential to cause an adverse
environmental effect because significant amounts of oil are discharged during a short duration at
concentrations that exceed discharge standards and water quality criteria. This discharge has
been reported to cause an oil sheen when procedural controls are not applied.6'8
6.0 DATA SOURCES AND REFERENCES
To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge. Based on this estimate
and on the reported concentrations of the constituents, the concentrations of the constituents in
the environment resulting from this discharge were compared with relevant water quality criteria.
Table 7 shows the sources of data used to develop this NOD report.
Specific References
1. Naval Sea Systems Command, Engineering Operating Sequencing System (BOSS),
Operational Procedure Fuel Oil Refueling, Code SRFO/0319/032596.
2. UNDS Equipment Expert Meeting Minutes - Compensated Fuel Ballast. July 24,1996.
3. Naval Sea Systems Command, DD 963 - DDG 993 Class Advisory NR 04-94, Inport
Refueling / Operational Procedures, 2 May 1994.
4. Naval Sea Systems Command, DDG 51 Class Advisory NR 22-95, Fuel Tank Level
Indicator Alignment Procedures, 21 December 1995.
Compensated Fuel Ballast
8
-------
5. Report of Travel, Compensated Fuel Ballast System NCCOSC-NRaD, San Diego, 12
March 1997.
6. Oil Concentrations in Ballast Water During In-Port Refueling of USS Nicholson (DD
982). DTNSRDC Report TM-28-81-145 (December 1981).
7. Oil Concentrations in Ballast Water During At-Sea Refueling of USS Nicholson (DD
982). DTNSRDC Report TM-28-82-158 (December 1982).
8. Evaluation of DD-963 Class Fuel/Ballast Expansion Tank Modifications Aboard USS
JOHN HANCOCK (DD 981). DTNSRDC Report TM-28-83-171 (May 1984).
9. SEA 05Y32 Preliminary Trip Report/Test Brief. DDG 51 In-Port Refueling Test, August
12-14,1992.
10. SEA 05Y32 DDG 51 Post-PSA In-Port Fueling Test. August 4,1992.
11. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.
12. Committee Print Number 95-30 of the Committee on Public Works and Transportation of
the House of Representatives, Table 1.
13. The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23, 1995.
14. Compensated Ballast Sample Analysis Results from DDG 51 In-port Refueling, 27
January 97, Commanding Officer, Naval Surface Warfare Center, Carderock Division,
Philadelphia Site, Philadelphia, PA, letter 9593, Ser 631/63 of 14 February 1997.
15. UNDS Ship Database, August 1,1997.
16. The United States Navy, List of Homeports, Homeports and the Ships Assigned,
Effective May 22,1997.
General References
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFRPart 131.36.
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
-------
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
-------
KQ
Figure 1. Fuel Tank Group 3 and 4 (Typical) Compensated Seawater Ballast
Compensated Fuel Ballast
11
-------
Figure 2. Compensated Fuel Ballast Tank Layout
Compensated Fuel Ballast
12
-------
JWBH1K1HIR //
iM.amH.VAi.VE / I
/ I— OVOTOARD DISCHARGE
naming
DPWISION vm.
Figure 3. Typical Port and Starboard Tank Groups with Cross-connected Overflow
Compensated Fuel Ballast
13
-------
Table 1. Oil Concentrations in Compensated Ballast Waters (mg/L)
Previous Navy Studies
USS Nicholson
DD 9826
(in-port)
2 to 149
USS Spruance
DD 9637
(at-sea)
<60
USS John Hancock
DD 98I8
(in-port)
<1 to 370
USSArleighBuike
DDG5110'11
(in-port)
0.0 to 10.35 (lab)
mg/L - milligrams of oil per liter of fluid
(lab) - laboratory analysis results for physical samples taken during testing
Compensated Fuel Ballast
14
-------
Table 2. Summary of Detected Analytes for Compensated Ballast Discharge
Constituent ;
'' ' „
Log Normal
Mean
Frequency of
, Detection s
" Minimum
Concentration
Maximum
Concentration
Mass Loading'
- (Ibs/yr)
Classicals (mg/L)
ALKALINITY
AMMONIA AS NITROGEN
BIOCHEMICAL OXYGEN
DEMAND
CHEMICAL OXYGEN DEMAND
(COD)
CHLORIDE
HEXANE EXTRACTABLE
MATERIAL
SGT-HEM
SULFATE
TOTAL DISSOLVED SOLIDS
TOTAL KJELDAHL NITROGEN
TOTAL ORGANIC CARBON
(TOC)
TOTAL PHOSPHOROUS
TOTAL SULFIDE (IODOMETRIC)
TOTAL SUSPENDED SOLIDS
VOLATILE RESIDUE
46.72
0.26
6.82
429.25
16042.18
12.73
4.65
2005.74
27760.50
0.39
28.98
0.06
3.94
9.62
2506.27
4 of 4
4 of 4
Iof4
4 of 4
4 of 4
4 of 4
2 of 4
4 of 4
4 of 4
4 of 4
4 of 4
3 of 4
4 of 4
4 of 4
4 of 4
45
0.19
BDL
380
15400
8
BDL
1900
27000
0.28
21
BDL
3
4
1910
49
0.3
12
490
16800
36.5
12.5
2120
29300
0.58
40
0.34
5
18
3160
11,671
65
1,704
107,231
4,007,497
3,180
1,162
501,054
6,934,851
97
7,239
15
984
2,403
626,091
Hydrazine (mg/L)
HYDRAZINE 0.08 4 of 4 0.0705 0.089 20
Mercury (ng/L)
MERCURY
0.60 | 3 of 4
BDL
0.835
0.0001
Metals (|ig/L)
ALUMINUM Dissolved
Total
BARIUM Dissolved
Total
BORON Dissolved
Total
CALCIUM Dissolved
Total
COPPER Total
IRON Dissolved
Total
MAGNESIUM Dissolved
Total
MANGANESE Dissolved
Total
NICKEL Dissolved
Total
SILVER Dissolved
SODIUM Dissolved
Total
52.03
37.00
11.44
11.24
3098.77
3060.48
256841.05
291451.71
53.37
99.76
130.50
907229.15
938389.79
12.13
12.13
184.65
189.72
3.07
8225693.86
8039337.04
2 of 4
Iof4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
4 of 4
Iof4
4 of 4
4 of 4
BDL
BDL
10.35
10.25
2990
2990
203000
286000
43.7
37.45
74.95
881000
907000
11.15
10.7
137
144
BDL
8040000
7740000
120
135.5
12
11.8
3220
3175
292000
299000
86
159
202
923500
1024500
13.7
13.7
263.5
267.5
5.68
8450000
8550000
13
9
3
3
774
765
64,161
72,808
13
25
33
226,635
234,419
3
3
46
47
1
2,054,861
2,008,307
Compensated Fuel Ballast
15
-------
THALLIUM Dissolved
Total
ZINC Dissolved
Total
5.61
7.40
1220.18
4256.14
Iof4
Iof4
4 of 4
4 of 4
BDL
BDL
173
3840
10.8
24
4330
4845
1
2
305
1,063
Organics (ug/L)
2,3-DICHLOROANILINE
2,4-DIMETHYLPHENOL
2-METHYLBENZOTfflOAZOLE
2-METHYLNAPHTHALENE
2-PROPANONE
2-PROPENAL
4-CHLORO-2-NITROAMLINE
ACETOPHENONE
ANILINE
BENZENE
BENZOICACID
BENZYL ALCOHOL
BIPHENYL
ETHYLBENZENE
HEXANOICACID
ISOSAFROLE
LONGIFOLENE
M-XYLENE
N-DECANE
N-DOCOSANE
N-DODECANE
N-EICOSANE
N-HEXADECANE
N-OCTADECANE
N-TETRADECANE
NAPHTHALENE
CH-PXYLENE
0-CRESOL
O-TOLUTDINE
P-CRESOL
P-CYMENE
PHENOL
TfflOACETAMBDE
TOLUENE
TOLUENE.2A-DIAMINO-
6.09
312.10
8.07
61.34
41.18
42.20
12.04
21.99
6.58
89.99
75.62
12.16
9.76
38.59
16.93
6.69
54.02
58.13
7.28
7.11
10.01
20.35
39.36
24.98
21.19
19.54
100.66
181.10
40.24
110.73
5.53
69.70
19.75
164.46
72.44
Iof4
4 of 4
Iof4
4 of 4
2 of 4
Iof4
Iof4
4 of 4
Iof4
4 of 4
3 of 4
3 of 4
4 of 4
4 of 4
4 of 4
Iof4
Iof4
4 of 4
Iof4
Iof4
2 of 4
4 of 4
4 of 4
4 of 4
4 of 4
3 of 4
4 of 4
4 of 4
4 of 4
4 of 4
Iof4
4 of 4
Iof4
4 of 4
Iof4
BDL
180
BDL
58
BDL
BDL
BDL
21
BDL
31
BDL
BDL
7.5
20.5
7.5
BDL
BDL
41.5
BDL
BDL
BDL
14
26
16
14
BDL
71
84.5
8
46.5
BDL
59
BDL
63.5
BDL
11
430
34
63
73
203
21
23
15
153
146
24
11
59
28
16
545
73
22.5
20.5
36.5
51
99.5
64
60
47
127
296
95
192
10
83
152
269
227
2
78
2
15
10
11
3
5
2
22
19
3
2
10
4
2
13
15
2
2
3
5
10
6
5
5
25
45
10
28
1
17
5
41
18
Log normal means were calculated using measured analyte concentrations. When a sample set contained one or
more samples with the analyte below detection levels (i.e., "non-detect" samples), estimated analyte concentrations
equivalent to one-half of the detection levels were used to calculate the mean. For example, if a "non-detect" sample
was analyzed using a technique with a detection level of 20 mg/L, 10 mg/L was used hi the log normal mean
calculation.
Compensated Fuel Ballast
16
-------
Table 3. Estimated Total U.S. In-port Discharge of Compensated Ballast
(millions of gallons/year Fleetwide)
Ship Class
CG47
DD963
DD993
DDG51
, Number of Ships
25
28
4
18
Total In-port Discharge
10.0
11.2
1.6
7.2
Table 4. Estimated Annual Mass Loadings of Constituents
Constituent ,
* ; • •"'
Log Normal
Mean ~'"
Frequency of
:" Detection
Minimum
Concentration
Maximum
Concentration
Mass Loading
(Ibs/yr) „
Classicals (mg/L)
Anmionia As
Nitrogen
Hexane
Extractable
Material
Nitrate/
Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen3
Total
Phosphorous
0.26
12.73
-
0.39
0.39
0.06
4 of 4
4 of 4
-
4 of 4
4 of 4
3 of 4
0:19
8
-
0.28
0.28
BDL
0.3
36.5
-
0.58
0.58
0.34
65
3,180
-
97
97
15
Mercury (ng/L)
Mercury*
0.6
3 of 4
BDL
0.835
0.00015
Metals (ug/L)
Copper Total
Nickel Dissolved
Total
Silver Dissolved
Thallium Total
Zinc Dissolved
Total
53.37
184.65
189.72
3.07
7.40
1220.18
4256.14
4 of 4
4 of 4
4 of 4
Iof4
Iof4
4 of 4
4 of 4
43.7
137
144
BDL
BDL
173
3840
86
263.5
267.5
5.68
24
4330
4845
13
46
47
0.77
2
305
1,063 ...
Organics (ug/L)
2-Propenal
Benzene
42.2
89.99
Iof4
4 of 4
BDL
31
203
153
10
22
* - Mercury was not found in excess of WQC; mass loading is shown only because it is a bioaccumulator.
A - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
Compensated Fuel Ballast
17
-------
Table 5. Estimated Mass Loadings by Homeport (Ibs/yr)
Ships
HEM
SGT-HEM
Copper
Nickel
Zinc
Thallium
Silver
2-Propenal
Ammonia
Benzene
Nitrogen
Phosphorous
Total
75
Everett
4
Mayport
13
Norfolk
27
Pascagoula
2
Pearl Harbor
10
San Diego
19
LoadittR-'RaiiSfcs-''- v"*' •''';. .•-V"";.o^v ...•• ; ' - ."••
3180
1160
13.3
47.4
1063
2
0.77
10.3
65
22
97
15
170
62
0.7
2.5
56.7
0.11
0.04
0.55
3.5
1.2
1.7
0.8
551
201
2.3
8.25
184.25
0.35
0.135
1.8
11.3
3.8
17
2.6
1145
417
4.75
17.1
382.7
0.72
0.285
3.7
23.4
7.9
35
5.4
85
31
0.35
1.25
28.35
0.05
0.02
0.28
1.75
0.6
0.84
0.4
424
155
1.8
6.3
141.7
0.27
0.1
1.4
8.7
2.9
13
2.0
805
294
3.4
12
269.3
0.51
0.19
2.6
16.5
5.6
25
3.8
Compensated Fuel Ballast
18
-------
Table 6. Mean Concentrations of Constituents Exceeding Water Quality Criteria
Constituent „- \,
Log Normal
Mean
Ammonia As
Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen8
Hexane Extractable
Material
Total Phosphorous
0.26
-
0.39
0.39
12.73
0.06
Minimum
Concentration
Maximum
Concentration
FederaLAcute
, WQC
Most Stringent
State Acute WQC
Classicals (mg/L)
0.19
-
0.28
0.28
8
BDL
0.3
-
0.58
0.58
36.5
0.34
None
None
None
visible sheen3/
15b
None
0.006 (HI)A
-
0.2 (HI)A
5(FL)
0.025 (HI)A
Mercury (ng/L)
Mercury*
0.6
BDL
0.835
1800 25 (FL, GA)
Metals (ng/L)
Copper Total
Nickel Dissolved
Total
Silver Dissolved
Thallium Total
Zinc Dissolved
Total
53.37
184.65
189.72
3.07
7.40
1220
4256
43.7'
137
144
BDL
BDL
173
3840
Organics (u
2-Propenal
Benzene
42.2
89.99
BDL
31
86
263.5
267.5
5.68
24
4330
4845
2.9
74
74.6
1.9
None
90
95.1
2.5 (WA)
74 (CA, CT)
8.3 (FL, GA)
1.9 (CA, MS)
6.3 (FL)
90 (CA, CT, MS)
84.6 (WA)
g/L)
203
153
None
None
18 (HI)
71.28 (FL)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
* - Mercury was not found in excess of WQC; concentration is shown only because it is a bioaccumulator.
CA = California
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
a Discharge of Oil, 40 CFR 110, defines a prohibited discharge of oil as any discharge sufficient to cause a sheen
on receiving waters.
b International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 as
implemented by the Act to Prevent Pollution from Ships (APPS)
Compensated Fuel Ballast
19
-------
Table 7. Data Sources
NOD Section
2.1 Equipment Description and
Operation
22. Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
Data Source • ;- v>;v • •:•••/-:.•: -.--••-•
Reported
Data call responses
Data call responses
UNDS Database
Data call responses
Data call responses
Data call responses
Data call responses
X
Sampling
X
X
X
Estimated
X
X
Equipment Expert
X
X
X
X
X
X
X
Compensated Fuel Ballast
20
-------
NATURE OF DISCHARGE REPORT
Controllable Pitch Propeller Hydraulic Oil
1.0 INTRODUCTION
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
-------
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
-------
gallons of oil could be present in CPP hub cavities.2 It is unlikely that all of this oil is released
during a seal replacement because the hub cavity opening is required to be oriented to the 6
o'clock position; the hydraulic oil is buoyant and floats within the hub cavity, effectively
trapping the oil.6
Oil (0 to 5 gallons) could be released when oil is supplied to the assembly to displace
water before replacing the blade port cover.6 After the seals or the center post sleeve are
replaced, head pressure is applied from the head tank to force out any water that entered the hub.
The husbandry manual does not specify if oil is discharged when displacing water in the hub, but
it appears to be a reasonable probability. The blade port cover is then replaced, and the hub is
pressure tested at 20 psi. Leaks can appear if the seals are not properly seated, the mylar shims
(i.e., spacers) are not the proper thickness, or the bearing ring is worn.6 If the bearing ring
requires replacement the vessel must be put in a dry dock.
Small amounts of oil can be discharged when removing and replacing the seal, bearing
ring, blade seal base ring, and center post sleeve. Assuming the worst-case condition, five
gallons of oil are discharged from the CPP hub during each replacement. At most a total of 35
gallons of hydraulic oil could be discharged annually fleetwide based on an average of seven
replacements per year.
The BMP also requires the following precautionary measures:
a. Establish/install a floating oil boom in the vicinity of the work. Position this boom to
enclose the aft one-third of the vessel, with approximately 20 feet beyond the stern to
ensure that escaping oil is contained.11
b. Ensure that the oil recovery kit and personnel, who are trained in oil spill recovery,
are at the work site at all times during the propeller blade removal/ installation to
respond to any oil spill. The spill kit shall include a boom, absorbent pads, and other
materials that remove oil from water.11
c. Any released oil will be captured within the oil boom and subsequently removed by
the oil recovery team on the surface. A vacuum truck, equipped with a noncollapsible
hose, will be at the site to remove any visible oil on the surface.11
CPP Blade Replacement. For the replacement of a CPP blade, the only source of oil
release is from bleeding the Morgrip bolt power head tool. Each blade replacement results in
approximately twenty ounces of hydraulic oil bled from the power tool (e.g., 10 ounces for the
blade removal and 10 ounces for the blade replacement).12 For the estimated 30 replacements
that occur each year, this translates to approximately 600 ounces (4.7 gallons) of hydraulic oil
bled from power head tools.
3.3 Constituents
The expected constituents of the discharge are 2190 TEP hydraulic oil from the CPP and
Controllable Pitch Propeller Hydraulic Oil
5
-------
the hydraulic oil (e.g., Tellus #10) that is bled from the power head tool. Constituents of the oil
vary by manufacturer and are noted in Table 2. Hydraulic oils contain Cn (heptadecane,
heptadecene) and large paraffins and olefins.13 The 2190 TEP oil can also contain up to 1%
tricresylphosphate (TCP) as an antiwear additive.14 Shell Oil Tellus Oil #10 (Code 65203)
hydraulic oil contains solvent-refined, hydrotreated middle distillates and light hydrotreated
naphthenic distillates.15 CPP hydraulic oil can contain copper, tin, aluminum, nickel, and lead
that are leached from the piping, hub, and propeller.
Copper, nickel, and lead are priority pollutants that could be present in the hydraulic oil.
There are no known bioaccumulators in this discharge.
3.4 Concentrations
The released material is expected to be hydraulic oil with metals such as copper, tin,
aluminum, nickel, and lead from the piping, hub, and propeller. These metal constituents are
expected to be in low concentrations because metals have low corrosion rates when in contact
with oil. In addition, the hydraulic oil is continually processed through a filtration system to
prevent particulate matter and water from entering the CPP system and potentially causing
system failures.
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
4.1 Mass Loadings
4.1.1 Leaks From CPP Seals
As discussed in Section 3.2.1, the release rate of oil from CPP seals due to normal
operations is expected to be negligible. CPPs are designed not to leak and are tested prior to
delivery at 400 psi. In addition, the CPPs are inspected quarterly.7 The majority of those vessels
equipped with CPPs have dry-dock cycles of five years or less and CPPs are returned to the
manufacturer for inspection and overhaul during the dry dock period.3'7'9'10 Therefore, the mass
loading for oil leakage from CPPs is expected to be negligible.
4.1.2 Underwater Replacements
As estimated in Section 3.2.2, Armed Forces vessels could release up to 4.7 gallons of
hydraulic oil from the Morgrip tool and 35 gallons of hydraulic oil from blade port cover
removals each year. This quantity of oil has a mass of approximately 290 pounds based on a
Controllable Pitch Propeller Hydraulic Oil
6
-------
specific gravity of 0.88 for the hydraulic oil.
4.2 Environmental Concentrations
The quantities of hydraulic oil released can cause a sheen on receiving waters that violate
federal and state "no sheen" standards. The metal constituents (e.g., copper, tin, nickel, and lead)
in the oil can also be toxic, but it is anticipated that the concentrations, when dissolved in water,
will be below toxicity thresholds. Florida has a water quality criterion for oil and grease of 5
milligrams per liter (mg/L) that the estimated environmental concentration for underwater
replacement exceeds.
4.2.1 Leaks From CPP Seals
Because the release of oil from a CPP under routine operations is negligible, the resulting
environmental concentration is negligible.
4.2.2 Underwater Replacements
The underwater replacements are expected to result in periodic, batch releases of
hydraulic oil. Based upon the estimated release rates given in Section 3.2.2, the estimated
discharge volume during each replacement is five gallons. During a typical underwater
replacement requiring the removal of the port blade cover, the aft third of a vessel plus an
additional 20 feet are enclosed with an oil boom. The Navy vessels having CPPs are between
445 and 567 feet in length and between 45 and 67 feet in beam (i.e., width). The average
boomed length is approximately 190 feet and width of approximately 65 feet (e.g., average beam
of 55 feet plus an estimated 10 feet for proper deployment). The quantity of oil released from
CPPs during underwater replacements will result in free-phase oil that will result in localized
visible oil sheens on the surface of the water. The resulting visible oil sheens are prohibited
releases of oil under the Discharge of Oil (40CFR110) regulations of the Federal Water Pollution
Control Act.
4.3 Potential for Introducing Non-Indigenous Species
CPPs do not transport seawater; there is no potential for transporting non-indigenous
species.
5.0 CONCLUSIONS
5.1 Leaks From CPP Seals
The release of oil from CPPs during normal operation due to seal leakage is expected to
be negligible. This is due to the following:
1) CPPs are designed not to leak at 400 pounds per square inch (psi) when new or
Controllable Pitch Propeller Hydraulic Oil
7
-------
overhauled and are tested at 400 psi for leaks prior to delivery. There is a zero-leakage tolerance
under the 400 psi test.
2) CPP seals are designed with service lives of 5 to 7 years and leakage that can occur
due to wear or age occurs late within this operational life. The majority of vessels equipped with
CPPs have dry-docking cycles for overhauls of approximately 5 years such that the releases
occurring toward the end of the operational life of a CPP seal are avoided.
3) CPPs are inspected quarterly for damage and evidence of system failure (e.g., leaking
seals).
The amount of oil leakage of CPPs under routine operating conditions has a low potential
to cause an adverse environmental effect.
5.2 Underwater Replacements
CPP hydraulic oil discharge has the potential for causing adverse environmental effects
during underwater replacements because:
1) oil is released to receiving waters by the equipment used to perform the underwater
replacements, and
2) oil is released from the CPP hub assembly during underwater removals of the CPP
blade port covers.
Releases due to underwater replacements are periodic and occur approximately thirty
times per year. Those replacements that require the removal of the blade port cover release
sufficient oil to cause a visible oil sheen on receiving waters and also exceed state WQC. These
releases from waterborne CPP repairs are controlled using NAVSEA BMPs that reduce the
adverse effects of the oil releases to receiving waters.
6.0 DATA SOURCES AND REFERENCES
To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge. The resulting
environmental oil and grease concentrations were then estimated. Table 3 shows the sources of
data used to develop this NOD report.
Specific References
1. Blank, David A.; Arthur E. Block; and David J. Richardson. Introduction to Naval
Engineering, 2nd Edition. Naval Institute Press, 1985.
Controllable Pitch Propeller Hydraulic Oil
8
-------
2.
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
-------
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
Deck Runoff
8
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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
Deck Runoff
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
Deck Runoff
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
Deck Runoff
11
-------
values are used for comparison to the Federal and most stringent state water quality criteria listed
in Table 12. The comparisons show that a number of the constituent concentrations in catapult
trough runoff exceed Federal and state acute water quality criteria, in addition to discharging oil
exceeding the Federal discharge limits.28 Chromium concentrations exceed the most stringent
state's water quality criteria. The detected metals that exceed the Federal and most stringent state
water quality criteria are: cadmium, nickel, and lead, hi addition, two metals, silver and copper,
which were not detected, have reported limits that are more than an order of magnitude higher
than their corresponding Federal and state water quality criteria. The reported phenols
concentration exceeded the most stringent state criteria. The oil and grease concentration
exceeds the Federal criterion and the concentrations reported are also likely to cause a visible
sheen on receiving waters. Discharges of oil that cause a visible sheen on receiving waters must
be reported.28
4.3 Potential For Introducing Non-Indigenous Species
The potential for non-indigenous species transport is insignificant. The runoff due to
rainfall and washdown has a low potential to contain non-indigenous species, and the runoff
from green water is discharged in the same location from which it came aboard.
5.0 CONCLUSION
Oil in the deck runoff discharge has the potential to cause an adverse environmental
effect. This conclusion is based upon observations of oil sheens on the water surface
surrounding certain vessels during and after rainfalls.
6.0 DATA SOURCES AND REFERENCES
Table 13 shows the sources of data used to develop this NOD report.
Specific References
1. "Deck Runoff from U.S. Naval Vessels", M. Rosenblatt & Son, Inc. Prepared for Naval
Sea Systems Command. September 1996.
2. Dye, J., Public Works Office, Naval Submarine Base, Bangor, WA. Response to UNDS
Questionnaire: Contained Washdowns and Deck Runoff.
3. Aivalotis, Joyce, USCG. Report Regarding USCG Outstanding hiformation, May 29,
1997, David Ciscon, M. Rosenblatt & Son, hie.
4. UNDS Equipment Expert Meeting Minutes - Catapult Troughs, Water Brake, Jet Blast
Deflector, Arresting Cables. August 22,1996.
Deck Runoff
12
-------
5. UNDS Equipment Expert Meeting Minutes - Catapult Discharges. July 26,1996.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
Commander, Naval Sea Systems Command. Memorandum to Commander, Naval Air
Systems Command. Pollution of Coastal Waters Attributable to Catapult Lube Oil.
December 16,1992.
LCDR Mills, Staff (N43), COMNAVAIRLANT. AIRLANT Policy Relative To Aircraft
Carrier Washdowns, August 21,1997, Randy Salyer, M. Rosenblatt & Son, Inc.
ABECS Gibson, Staff (N43), COMNAVAIRPAC. AffiPAC Policy Relative To Aircraft
Carrier Washdowns, August 21,1997, Randy Salyer, M. Rosenblatt & Son, Inc.
LT Carlos Castillo, Staff, Commander Amphibious Group Two. Norfolk - Little Creek,
VA. SURFLANT Policy Relative to Amphibious Assault Ship Flight Deck Washdowns,
November 5,1997, Jim O'Keefe, M. Rosenblatt & Son., Inc.
LCDR Southall, Staff (N42), Commander Surface Force, U.S. Pacific Fleet, San Diego,
CA. SURFPAC Policy Relative To Amphibious Assault Ship Flight Deck and Surface'
Ship Weather Deck Washdowns, November 6,1997, Jim O'Keefe, M. Rosenblatt &
Son., Die.
UNDS Equipment Expert Meeting Minutes - Catapult Wet Accumulator Steam
Blowdown Discharge. August 20,1996.
Stucka, Bob, MSC Field Engineer, Norfolk, VA. MSC Policy Relative To Flight Deck
Washdowns, September 9, 1997, Jim O'Keefe, M. Rosenblatt & Son, Inc.
Code of Federal Regulations, 33CFR155, Sub Part B, Vessel Equipment.
Hofinann, Hans, MR&S. Responses To Inquiries Regarding The Design Features hi The
T-AO 187 Class Oilers To Prevent Pollution, December 17, 1996, Clarkson Meredith,
Versar, Inc.
North, Dick, Puget Sound Naval Shipyard, Boston Detachment, Boston, MA. Status of
Pollution Preventative ShipAlts For Yard and Service Craft Oilers, September 3,1997,
Jim O'Keefe, M. Rosenblatt & Son, Inc. (MR&S).
Pentagon Ship Movement Data for Years 1991 -1995, Dated March 4,1997.
Ship Management Information System Report JQ02, U.S. Naval Battle Forces As Of 30
June 1997, June 13,1997. 20.
Weersing, Penny, MSC Engineer, Estimates of Time In U.S. Ports For MSC Vessels,
March 19,1997, Jim O'Keefe, M. Rosenblatt & Son, hie. U.S. Navy Public Affairs'
Home Page. List of U.S. Navy Ships and Their Homeports, March 1,1997.
Deck Runoff
13
-------
19. U.S. Coast Guard, Listing of Vessels and Permanent Stations, 1992.
20. Naval Sea Systems Command (NAVSEA), Data Book for Boats and Craft of the United
States Navy, NAVSEA 0900-LP-084-3010, Revision A. May 1988.
21. U.S. Army Combined Arms Support Command, Army Watercraft Master Plan,
November 1996.
22. Headquarters, Dept. of the Army. Watercraft Equipment Characteristics and Data,
Technical Manual TM 55-500, May 1992.
23. Sharpe, Richard. Jane's Fighting Ships. Jane's Information Group, Ltd.,1996.
I
24. Aivalotis, Joyce, USCG. USCG Ship Movement Data, May 27,1997,
Lee Sesler, Versar, Inc.
25. UNDS Ship Database, August 1,1997.
26. The World Almanac and Book of Facts. Mahwah: Funk & Wagnalls, 1995.
27. "Waste Buster" Test of Oily Waste Treatment Facility. NNS Laboratory Services. April
1994.
28. Code of Federal Regulations, 40 CFR110, EPA Regulations on Discharge of Oil.
General References
j
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
•
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
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
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Military Sealift Command
Kilauea Class Ammunition Ships (T-AE)
Mars Class Combat Stores Ship (J-AFS)
Sinus Class Combat Stores Ship (T-AFS)
Henry J. Kaiser Oilers (T-AO)
Hayes Class Acoustic Research Ship (T-AG)
Mission Class Navigation Research Ship (T-AG)
Observation Is. Class (T-AGM)
Stalwart Class Ocean Surveillance Ship (T-AGOS)
Victorious Class Ocean Surveillance Ships (T-AGOS)
Silas Bent Class Surveying Ships (T-AGS)
Waters Class Surveying Ship (T-AGS)
McDonnell Class Surveying Ships (T-AGS)
Pathfinder Surveying Ships (T-AGS)
Mercy Class Hospital Ships (T-AH)
Maersk Class Strategic Sealift Ships (T-AKR)
Gordon Class Strategic Sealift Ships (T-AKR)
Algol Class Fast Sealift Ships (T-AKR)
Zeus Class Cable Repairing Ship (TXARC)
Powhatan Class Meet Ocean lugs ( l-A l>)
31,494
31,461
25,140
51,222
15,005
34,808
33,375
7,513
21,949
10,682
24,453
7,301
14,861
73,637
78,215
79,042
78,232
28,612
7,869
45
45
45
50
45
45
45
60
120
45
45
45
45
365
320
320
320
45
120
8
5
3
12
1
1
1
5
4
2
1
2
4
2
3
2
8
1
7
774,534
483,587
231,853
2,099,533
46,129
107,004
102,600
153,975
719,741
65,674
75,172
44,888
182,746
3,672,277
5,129,551
3,455,850
13,681,694
87,959
451,557
USCG
Hamilton Class High Endurance Cutters (WHEC)
Famous Class Medium Endurance Cutters (WMEC)
Famous Class Medium Endurance Cutters (WMEC)
Reliance Class Medium Endurance Cutters (WMEC)
Reliance Class Medium Endurance Cutters (WMEC)
Polar Class Icebreaker (WAGB)
Bay Class Tugs (WTGB)
Point Class Patrol Craft (WPB)
Island Class Patrol Boats (WPB)
Juniper Class Seagoing Buoy Tender (WLB)
Balsam Class Buoy Tenders (WLB)
Keeper Class Buoy Tenders (WLM)
Red Class Buoy Tenders (WLM)
White Sumac Class Buoy Tenders (WLM)
Inland Buoy Tenders (WLI)
Inland Buoy Tenders (WLI)
River Buoy Tenders, 65 ft (WLR)
River Buoy Tenders, 75 ft (WLR)
River Buoy Tenders, 115 ft (WLR)
Pamlico Class Construction Tenders (WLIC)
Cosmos Class Construction Tenders (WLIC)
Anvil/Clamp Class Construction Tenders (WLIC)
Harbor Tugs (WYTL)
Motor Lifeboats
10,633
6,803
6,803
5,582
5,582
21,435
4,106
1,114
1,802
8,073
5,195
4,914
4,041
3,216
1,872
862
1,115
1,287
2,691
3,765
1,872
1,287
963
523
154
139
166
238
151
365
365
320
320
287
295
227
227
227
365
365
365
365
365
365
365
365
365
365
12
4
9
5
11
2
9
36
49
2
23
2
9
4
2
4
6
13
1
4
3
9
11
26
1,342,412
258,392
694,312
453,826
633,449
1,068,959
921,430
876,335
1,930,053
316,565
2,407,882
152,408
564,018
199,485
93,357
85,966
166,875
417,187
67,100
375,527
140,035
288,822
264,219
339,110
Armv
Frank Besson Class Logistic Support Ship (LSV)
Mechanized Landing Craft (LCM 8)
Utility Landing Craft (LCU 2000)
Utility Landing Craft (LCU 1600)
Lighter Amphibious Resupply, Cargo (LARC)
Large Tug (LT 128)
Large Tug (LT 100)
Barge Derrick, 1 1ST (BC)
Barge Derrick, 89T (BD)
Barge Cargo (BC)
6,547
511
2,412
1,292
92
3,594
2,212
13,125
9,800
3,520
183
320
320
320
365
320
320
365
365
365
6
104
34
14
23
10
15
5
7
3
491,105
1,161,183
1,792,495
395,403
52,992
785,730
725,240
1,636,359
1,710,541
263,314
Estimated Total Annual Runoff (gals): 54,638,410
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Table 11. Laboratory Results, Catapult Trough Drains Aqueous Phase Discharge*
Constituent
Date:
Phenols
Oil and grease
Silver
Cadmium
Chromium
Copper
Nickel
Lead
Zinc
Sample Results (mg/L)
4/13/94 <- „
4.6
9,683
<0.050
0.155
0.103
0.050
1.90
26.1
<0.050
. 4/14/94 :
5.3
13,919
O.050
0.141
0.088
<0.050
1.81
76.3
<0.050
Source: NNS Laboratory Services, 199428
* Data represent concentrations prior to processing through an oil water separator.
-------
Table 12. Comparison of Catapult Trough Drains Discharge to
Water Quality Criteria27
Constituent
Date:
Phenols
Oil and grease
Silver
Cadmium
Chromium
Copper
Lead
Nickel
Sample Results (mg/L)
4/13/94
4.6
9,683
O.050
0.155
0.103
O.050
26.1
1.90
4/14/94
5.3
13,919
<0.050
0.141
0.088
<0.050
76.3
1.81
Federal Acute WQC (rag/L)
none
Visible sheen Vl52
0.0019
0.042
1.1
0.0024
0.210
0.074
Most Stringent State Acute WQC
•-::^ -;:-:Mmg/L>^,,- > .,
0.17 (BO)
5(FL)
0.0012 (WA)
0.0093 (FL, GA)
0.05 (FL, GA)
0.0025 (WA)
0.0056 (FL, GA)
0.0083 (FL, GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.
FL =* Florida
GA m Georgia
HI - Hawaii
WA = Washington
I. The Federal Pollution Control Act, 40CFR110, defines a prohibited discharge of oil as any discharge sufficient to
cause a sheen on the receiving waters.
2. International Convention for the Prevention of Pollution from Ships (MARPOL 73/78). MARPOL 73/78 is
implemented by the Act to Prevent Pollution From Ships (APPS).
Table 13. Data Sources
NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3,1 Locality
3.2 Rate
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
43 Potential for Introducing Non-
Indigenous Species
Data Source
Reported
UNDS Database
Sampling
X
Estimated
X
X
X
Equipment Expert
X
X
X
X
X
X
-------
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
-------
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
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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
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(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
-------
gallons of seawater introduced into a distilling plant, 17 gallons of brine is produced. Knowing
that a total of approximately 2.47 billion gallons of distilling and RO plant brine discharges occur
annually within 12 n.m. of shore, the following calculation can be made to approximate the total
annual volume of seawater influent:
(18 gallons of seawater/17 gallons of brine) (2.47 billion gallons of brine)
= 2.62 billion gallons seawater .
Therefore, the influent flow rate is approximately 2.62 billion gallons, and the effluent
flow rate is approximately 2.47 billion gallons
3.3 Constituents
The three sources of the constituents of water purification plant discharge are: 1) influent
seawater; 2) anti-scaling treatment chemicals; and 3) the purification plant components,
including heat exchangers, casings, pumps, piping and fittings. /The primary constituents of the
brine discharge are identical to those in seawater. These include non-volatile dissolved and
suspended solids, and metals.
Distilling plants are made primarily of metal alloys that are corroded by seawater,
particularly at the elevated temperatures at which these plants operate. The metal alloys used for
heat transfer surfaces and other components include copper-nickel alloys, nickel/chromium
alloys, stainless steel, titanium, brass, and bronze. Based on the metallurgical composition of
these alloys, the corrosion process could be expected to introduce copper, chromium, nickel, and
zinc into the brine. The corrosion effect on the brine discharge metal loadings is less of a
concern for the RO plants, with non-metallic membranes and ambient seawater operating
temperatures.
The distilling plant anti-scaling compound used in Navy surface ships is Distiller Scale
Preventive Treatment Formulation. The military specification requires anti-scaling compound
products to contain organic polyelectrolytes such as polyacrylates, and an antifoaming agent in
aqueous solution.6 The polyelectrolyte chelates (ties-up) inorganic constituents (calcium,
magnesium, metals) to prevent them from depositing on equipment surfaces. Equipment supplier
material safety data sheets (MSDSs) indicate that the products contain about 10% to 20%
polyacrylate and low levels of antifoaming chemicals (e.g., one product contains 1%
polyethylene glycol). Ethylene oxide was identified on two of the MSDSs as potentially present
in trace amounts. One of the MSDSs also indicated that acrylic acid, acetaldehyde, and 1,4-
dioxane can also be present at trace levels.7
i
Distilling plant influent and effluent were sampled for materials that had a potential for
being hi the discharge. An aircraft carrier, an amphibious assault ship, and a landing ship dock
were sampled.8 Based on the brine generation process, system designs, and analytical data
available, analytes in the metals, organics, and classicals classes were tested. In addition, Bis(2-
ethylhexyl) phthalate, a semi-volatile organic compound, was specifically tested for, since it is
not covered in the three aforementioned analyte classes, but is a standard parameter in sampling
Distillation and Reverse Osmosis Brine
6
-------
for semi-volatile constituents. The results of the sampling are provided in reference 8. Table 2
provides a list of all constituents and their concentrations that were detected in the discharge. In
terms of thermal effects, this discharge is expected to be warmer than ambient water
temperatures with a maximum overboard discharge temperature of 120 °F.
Priority pollutants that were detected included copper, iron, lead, nickel, and zinc; and the
semi-volatile organic compound bis(2-ethylhexyl) phthalate. No bioaccumulators were detected.
3.4 Concentrations
The concentrations of detected constituents are listed in Tables 2 and 3.
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented hi Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria.
Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of non-
indigenous species is discussed.
4.1 Mass Loadings
The water purification plant brine annual discharge flow rate (Section 3.2) and constituent
concentration data (Tables 2 and 3) were used to develop brine constituent effluent mass loading
estimates. Similarly, constituent influent mass loadings were found by using the seawater annual
flow rate (Section 3.2) and constituent concentration data (Tables 2 and 3).
The following general formula was used to determine influent mass loading and effluent
mass loading:
Mass Loading (Ibs/yr) = : !
(concentration in figTL) (flow rate in gal/yr) (3.7854 L/gal) (2.21b/kg) (10"9 kg/ug)
For instance, the estimated effluent mass loading for copper generated by distilling plant
brine discharge is:
38 ug/I^ff^^
The estimated influent mass loading calculation for copper is:
(83.51 ng/L) (2.62 billion gal/yr) (3.7854 L/gal) (2:2 Ib/kg) (IP'9 kg/fig) = 1822^IMbs?yr
Distillation and Reverse Osmosis Brine
7
-------
The mass loading of the discharge was then determined by subtracting the influent mass
loading from the effluent mass loading for each constituent. Concentration values and mass
loadings are provided in Table 2. Log-normal average concentrations were used because the
sample data were assumed to approximate a log-normal distribution.
The mass loadings were calculated based upon flow from all distilling and RO plants and
assuming constituent concentrations in distiller and RO effluent are equal. Calculations using
this assumption are expected to overestimate mass loadings because constituent concentrations
will be lower in RO effluent because the operating temperature is lower, resulting in less
corrosion. Table 3 provides a water purification plant brine discharge mass loading summary.
4.2 Environmental Concentrations
Table 4 identifies distilling plant brine constituents that were detected at or above their
respective Federal or most stringent state water quality criteria (WQC). Copper and zinc
exceeded both Federal and most stringent state WQC. Nitrogen (as ammonia, nitrate/nitrite, and
total kjeldahl nitrogen), phosphorous, iron, lead, nickel, and zinc exceed the most stringent state
WQC.
4.3 Thermal Effects
The potential for distilling plant brine discharge to cause thermal environmental effects
was evaluated by modeling the thermal plume generated and then comparing it to plumes
representing state thermal discharge requirements. Thermal effects of distilling plant brine were
modeled using the Cornell Mixing Zone Expert System (CORMLX) to estimate the plume size
and temperature gradients in the receiving water body. The model was run under conditions that
would overestimate the size of the thermal plume (minimal wind, slack tide) for the largest
generator of distilling plant brine (aircraft carrier) and for a typical distillation brine generator
(cruiser). The plume characteristics were compared to thermal mixing zone criteria for Virginia
and Washington. Other coastal states require that thermal mixing zones be established on a case-
by-case basis.
The Washington thermal regulations state that when natural conditions exceed 16 °C, no
temperature increases will be allowed that will raise the receiving water temperature by greater
than 0.3 °C. The mixing zone requirements state that mixing zones shall not extend for a
distance greater than 200 feet plus the depth of the water over the discharge point, or shall not
occupy greater than 25% of the width of the water body. The Virginia thermal regulations state
that any rise above natural temperature shall not exceed 3 °C. Virginia requires that the plume
shall not constitute more than one-half of the receiving watercourse, and shall not extend
downstream at any time a distance more than five times the width of the receiving of water body
at the point of discharge.
The aircraft carrier distilling plant brine flow rate was determined to be 24,083 gallons
per hour at a temperature of 104 °F while the cruiser flow parameters were 120 °F and 6,375
gallons per hour for temperature and flow rate, respectively. The ambient water temperature was
Distillation and Reverse Osmosis Brine
8
-------
dependent upon location and varied between 40 and 60 °F. Both modeled discharges were
continuous and were assumed to emanate from a 6-inch diameter pipe located at the bottom of
the hulls. The results of this modeling are provided in Table 5.9
Some of the model parameter assumptions lead to a reduced amount of mixing within the
harbor. The assumptions are:
• wind velocity is at a minimum (1 m/s);
• the discharge will occur during a simulated slack tide event, using a minimum water
body velocity (0.03 m/s);
• the average depth of water at the pier is 40 feet.
Using the above parameters and assumptions, distilling plant brine discharges from
Armed Forces vessels do not exceed state thermal mixing zone criteria.
4.4 Potential for Introducing Non-Indigenous Species
The potential for introducing, transporting, or releasing non-indigenous species with this
discharge is low because the maximum retention time of water in these plants is short; therefore
the effluent is discharged in the same area from which the influent seawater is taken.
5.0 CONCLUSIONS
The discharge from vessel water purification plants has the potential to cause adverse
environmental effects because significant amounts of metals are discharged at concentrations
above WQC.
6.0 DATA SOURCES AND REFERENCES
Table 6 lists the data source of the information presented in each section of this NOD
report.
Specific References
1. Personal communication between Carl Geiling, Malcolm Pimie, Inc., and Chief Luedtke,
USS Carter Hall (LSD 50), 23 January, 1997.
2. Aerni, Walter, NAVSEA. Elements Present in Water, 19 November 1997, Greg
Kirkbride, M. Rosenblatt & Son, Inc.
3. UNDS Equipment Expert Meeting Minutes - Evaporator Brine & Reverse Osmosis (RO)
Plant. August 27, 1996.
Distillation and Reverse Osmosis Brine
9
-------
4. Aqua-Chem Marine, Inc. Marine Multi-Stage Flash Distilling Plants.
5. U.S. Navy. Commander, Naval Air Forces Pacific. Implementation of Uniform National
Discharge Standards. Letter to SEA OOT-E1,17 December 1996.
6. Specification for Distiller Scale Preventive Treatment Formulations (Metric), DOD-D-
24577(2), 19 December, 1986.
7. Ashland Chemical Company. Material Safety Data Sheets - Ameroyal Evaporator
Treatment, January 5,1996.
8. UNDS Phase 1 Sampling Data Report, Volumes 1-13, October 1997.
9. NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed
Services. Versar, Inc. July 3,1997.
General References
I
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
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
-------
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.
New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
Texas. Texas Surface Water Quality Standards, Sections 307.2-307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
UNDS Ship Database, August 1,1997.
Distillation and Reverse Osmosis Brine
11
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PRESSURE
REGULATING
VALVE
TO COM). SYSTEM <*•
OVERBOARD ^——•
TO STEAM DRAINS 4
Figure 1. Diagram of a Two Stage Flash-Type Distilling Plant
Distillation and Reverse Osmosis Brine
12
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d
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125895.89
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t-
t-;
Total Sulfide
-------
Table 3. Estimated Mass Loadings of Constituents
Constituent*
Ammonia as
Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total
Phosphorous
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Zinc
Total
Log-normal Mean
Influent (pg/L)
0.07
20
540
0.17
29.97
83.51
594.59
.6.77
44.43
18.49
Log-normal
Meant Effluent
(m/L)
0.17
20
470
0.23
59.21
217.38
1081.50
23.84
13.17
122.26
Influent Mass
Loading (Ibs/yr)
f "" */f
1527.33
436.38
11782.28
3709.24
653.92
1822.11
12973.39
147.71
969.42
403.43
Effluent Mass
,„ Loading
(Ibs/yr) "
'/
2262.68
411.39
9667.84
4731.07
1217.94
4471.48
22246.31 •
490.39
270.91
2514.87
Estimated Annual
Mass Loading
(Effluent -Influent)
' (ibs/yr)
735.35
-24.99
-2114.44
1021.83
564.02
2649.37
9272.92
342.68
-698.51
2111.14
Notes:
1. The table lists all constituents whose effluent log-normal mean concentration exceeds the Federal or most
stringent state water quality criteria. 2. The average total concentration is the log-normal mean for a constituent,
determined from Table 2, by subtracting the influent total average (background) concentration from the effluent
total average concentration.
3. Mass loadings are based on average total concentrations and a total fleet brine discharge flow estimate of 2.47
billion gallons per year to navigable waters less than 12 n.m. from shore (1.84 billion gallons per year in port and
0.62 billion gallons per year in transit, from Table 1). Mass loading was not determined for nickel, for which the
influent concentration exceeded the effluent concentration.
Distillation and Reverse Osmosis Brine
19
-------
Table 4. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituent
Classicals (ug/L)
Ammonia as
Nitrogen
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen8
Total Phosphorous
Metals (ug/L)
Copper
Dissolved
Total
Iron
Total
Lead
Total
Nickel
Total
Zinc
Total
Log-normal
Mean
Effluent
170
20
470
490
230
59.21
217.38
1081.5
23.84
13.17
122.3
Minimum
Concentration
Effluent
BDL
BDL
460
160
49.7
127
576.5
BDL
BDL
93.0
Maximum
Concentration
Effluent
330
220
490
270
71.15
325.5
1590
24.4
32
174
Federal
Acute WQC
None
None
None
None
None
2.4
2.9
None
217.2
74.6
95.1
Most Stringent
State Acute WQC
6 (HI)A
8iffl)A
-
200 (HI)A
25 (HI)A
2.4 (CT, MS)
2.5 (WA)
300 (FL)
5.6(FL, GA)
8.3 (FL, GA)
84.6 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
CA - California
CT ** Connecticut
FL - Florida
GA = Georgia
HI <** Hawaii
MS = Mississippi
WA — Washington
Distillation and Reverse Osmosis Brine
20
-------
Table 5. Summary of Thermal Effects of Distilling Plant Brine Discharge9
CASE
"V
Discharge
Temp(°F)
Discharge
Elow<,
(gallons per
hour)
Ambient
Water -
Temp (°F)
Predicted
Pin me
Length (m)
Allowable
Plume
Length (m)
Predicted
Plume Width
(«*>
Allowable
Plume Width
<«») j"
Predicted „
Plumr
Depth (m)
Virginia State (3.0°C AT) , , 1
4a (CV 63)
4b (CGN 36)
104
120
24,083
6,375
40
40
3.8
2,57
32,000
32,000
0.43
0,35
3,200
3,200
0.43
0.35
Washington State (ft3°C AT) -
4a(CV63)
4b (CGN 36)
104
120
24,083
6,375
50
50
16.42
7.72
73
73
1.83
19.28
400
400
1.83
0.96
Table 6. Data Sources
/
NOD Section
2,1 Equipment Description and
Operation ~
2.2 Releases to the Environinenf
/ *
s ^,
2.3 Vessels Producing tbe Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations 1
'4.1 Mass Loadings
4.2 Environmental Concentrations' «
4.3 Thermal Efiects
4.4 Potential for Introducing Non-
Indigenous Species
- ' Data Source
Reported
NSTMa
NSTMand
MSDSs3-"
UNDS Database
Design
Documentation
MSDS"
X
X
Sampling
X
X
Estimated
X
X
X
' Equipment Expert
X
X
X
X
X
X
X
NSTM - Naval Ships' Technical Manual
MSDS - Material Safety Data Sheet
Distillation and Reverse Osmosis Brine
21
-------
-------
DISTILLATION AND REVERSE OSMOSIS BRINE
MARINE POLLUTION CONTROL DEVICE (MPCD) ANALYSIS
Several alternatives were investigated to determine if any reasonable and practicable
MPCDs exist or could be developed for controlling distillation and reverse osmosis (RO) brine
discharges. An MPCD is defined as any equipment or management practice, for installation or
use onboard a vessel, designed to receive, retain, treat, control, or eliminate a discharge incidental
to the normal operation of a vessel. Phase I of UNDS requires several factors to be considered
when determining which discharges should be controlled by MPCDs. These include the
practicability, operational impact, and cost of an MPCD. During Phase I of UNDS, an MPCD
option was deemed reasonable and practicable even if the analysis showed it was reasonable and
practicable only for a limited number of vessels or vessel classes, or only on new construction
vessels. Therefore, every possible MPCD alternative was not evaluated. A more detailed
evaluation of MPCD alternatives will be conducted during Phase n of UNDS when determining
the performance requirements for MPCDs. This Phase n analysis will not be limited to the
MPCDs described below and may consider additional MPCD options.
MPCD Options
Distilling and RO plants generate freshwater from seawater for a variety of shipboard
applications, including potable water for drinking, hotel services, aircraft and vehicle washdowns,
boiler feedwater on steam-powered vessels, and auxiliary boiler feedwater on most vessels.
Discharges from distilling and RO plants contain influent seawater, contaminants from system
components, and anti-scaling treatment chemicals. Distilling plants boil seawater, and the
resulting steam is condensed into distilled water. During the distilling process, seawater
constituents form a scale on the heat transfer surfaces. Therefore, anti-scaling compounds are
continuously injected into the influent seawater to control the scaling. The remaining seawater
concentrate or "brine" that does not boil away is discharged overboard. RO systems separate
freshwater from seawater using semi-permeable membranes as a physical barrier, allowing a
portion of the influent seawater to pass through the membrane as freshwater, while capturing
suspended and dissolved constituents. These captured substances become concentrated in a
seawater brine that is subsequently discharged overboard.
Five potential MPCD options were investigated for controlling this discharge within 12
n.m. of shore. The MPCD options were selected based on screenings of alternate materials and
equipment, pollution prevention options, and management practices. They are listed below with
brief descriptions of each:
Option 1: Restrict operation of water purification plants in port - Eliminate or
minimize distilling and RO plant use in port. This would require alternate sources of
distilled/demineralized water for boiler feedwater for steam powered vessels.
Distillation and Reverse Osmosis Brine MPCD Analysis
1
-------
Option 2: Layup non-essential water purification plants with freshwater when in
port - Require the use of shore-supplied freshwater to layup all water purification plants
on non-steam powered vessels and the non-essential plants onboard steam powered
vessels, to reduce corrosion.
|
Option 3: Require RO systems on new ships - Specify RO plants instead of distilling
plants to meet freshwater requirements (except boiler feedwater production) for new
construction ships. RO plant discharges are expected to contain fewer heavy metals.
Option 4: Substitute freshwater for seawater to operate distilling plants onboard
steam-powered vessels while in port - Require freshwater from a shore connection,
instead of seawater, to provide feedwater for distilling plants on steam-powered vessels.
This option would reduce metal mass loadings in the brine discharge by reducing seawater
induced corrosion.
Option 5: Change distilling and RO plant construction materials - Specify water
purification plants that are constructed of materials that minimize or eliminate discharge of
harmful constituents.
MPCD Analysis Results
Table 1 shows the results of the MPCD analysis. It contains information on the elements
of practicability, effect on operational and warfighting capabilities, cost, environmental
effectiveness, and a final determination for each option. Based on these findings, Option 3 —
requiring RO systems on new construction ships - offers the best combination of these elements
and is considered to represent a reasonable and practicable MPCD.
Distillation and Reverse Osmosis Brine MPCD Analysis
2
-------
-.I-
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-------
REFERENCES
.' Memorandum from Mr. R. Bernstein (M. Rosenblatt & Son, Inc.), Subj: Estimate for
Freshwater Supply to Vessels While Inport, November 13,1997.
2 Naval Ship's Technical Manual, Chapter 531 - Desalination, Volume 1 - Low-Pressure Distilling
Plants, S9086-SC-STM-010/CH-531V1, First Revision, March 21,1996.
3 Naval Ship's Technical Manual, Chapter 533 - Potable Water Systems, S9086-SC-STM-
010/CH-533, Third Revision, March 15,1995.
!
4 Titanium Prices, e-mail from Mr. Sam Fisher, Principal Metals, Inc., November 13,1997.
5 Titanium Prices, personal communication with Mr. Bob Marsh, Titanium Industries, Inc.,
November 24,1997.
6 Metals Prices, MetalWorld, Inc., http://www.metalworld.com, August 29,1997.
Distillation and Reverse Osmosis Brine MPCD Analysis
6
-------
NATURE OF DISCHARGE REPORT
Elevator Pit Effluen/
1.0 INTRODUCTION
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.
Elevator Pit Effluent
1
-------
2.0 DISCHARGE DESCRIPTION
This section describes the discharge from elevator pits and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
2.1 Equipment Description and Operation
Most large surface vessels have at least one type of elevator; however, elevator
configurations vary between ship classes. On each ship, several different types and sizes of
elevators may be used to transport small packages, large cargo items, ordnance, food supplies,
and personnel.1 Elevators can service several decks depending on their purpose. Elevator doors
open at each deck for loading and unloading. The elevator operates using either cables, rails, or
hydraulic pistons. The elevators that raise and lower aircraft on aircraft carriers cannot produce
this discharge because they are open to the sea and do not have elevator pits. Elevators that
operate in shafts have a sump in the pit to collect liquids that may enter the elevator and shaft
area.1 If the elevator pit is located above the waterline, the sump is fitted with a drain that directs
the waste overboard. This drain is normally higher than the sump floor to prevent clogging from
solids. If the elevator pit is located below the waterline, the pit is educted dry using the firemain
water supply.
2.2 Releases to the Environment
For elevators with pits, deck runoff and elevator equipment maintenance activities are the
major sources of liquid that accumulate in the pit. Deck runoff occurs during heavy rains, rough
seas, and deck washdowns. During these events, water from the deck can enter the elevators and
elevator shafts when the elevator doors are open, or through worn seals when the doors are
closed (non-watertight). When water enters the elevator pit, it can contain materials that were on
the deck, including aviation fuel, hydraulic fluid, lubricating oil, residual water, and aqueous film
forming foam (AFFF).2 The runoff may also include lubricant applied to the elevator doors, door
tracks, and other moving elevator parts. Residue in the elevator car from the transport of
materials may also be washed into the elevator pit. The cleaning solvent used during
maintenance cleaning operations as well as liquid wastes generated by the cleaning process drain
into the elevator pit sump. This mixture of materials and liquid collects in the sump at the
bottom of the elevator pit.
Waste accumulated in the elevator pits is removed by gravity draining, by educting
overboard using firemain powered eductors, by using a vacuum or sponges to transfer the waste
to the ship's bilge system for treatment as bilgewater, or by containerizing it for shore disposal.3
Since elevator pit eductors use the firemain water supply, the elevator pit effluent can contain any
constituents present in the firemain water. The ratio of elevator pit waste to firemain supply can
vary from 1:1 to 3:1, depending on the type of eductor used to evacuate the elevator pit.
23 Vessels Producing the Discharge
Elevator Pit Effluent
2
-------
All of the ships listed in Tables 1, 2, and 3 have the potential to produce an elevator pit
discharge. Table 1 lists the MSC ships that have elevators. Tables 2 and 3 list the number and
types of major elevator systems on Navy surface combatants and support ships, respectively.4
U.S. Coast Guard (USCG), Air Force, and Army vessels do not produce this discharge because
they do not have elevator pits.
3.0 DISCHARGE CHARACTERISTICS
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 has the potential to occur within and beyond 12 nautical miles (n.m.) from
shore. Inspections of elevator pits on Navy ships in port revealed that elevator pits are generally
dry and that elevator pit effluent is not expected to be discharged in significant amounts within
12 n.m. because of current practices which educt the waste overboard prior to the ship coming
within 12 n.m. of shore.3 Without these practices, this effluent could be discharged while
pierside or underway.
3.2 Rate
The rate of this discharge is subject to frequency and amount of deck runoff (e.g.,
washdown water and rainfall), as well as the frequency of use of the elevators and the size of the
elevator opening. These factors vary greatly between vessel classes. Inspections were performed
on nine vessels to investigate the presence of accumulated waste in elevator pits. The inspections
revealed that elevator pits in each vessel were often dry when the vessel came into port, because
the accumulated waste had either been drained or educted overboard prior to the vessel coming
within 50 n.m. of land, containerized for shore disposal, or the waste had been transferred to the
bilge for treatment by the oil water separator (OWS) as bilgewater.3 Based on this information, it
is estimated that the discharge flow rates of elevator pit effluent within the 12 n.m. zone are
minimal.
3.3 Constituents
The constituents of elevator pit effluent are affected by the amount and type of materials
on deck, the agents used during cleaning and maintenance of the elevators, and to some degree
the material transported in the elevators. At any given time elevator pit effluent may contain the
following constituents:
• grease;
• lubricating oil;
Elevator Pit Effluent
3
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• solvent;
• soot;
• dirt;
• paint chips;
Additional constituents that may be carried into the elevator pit by deck runoff can
include fuel, AFFF, glycol, and sodium metasilicate. Material safety data sheet (MSDS)
information on these materials indicate that the constituents can include polymers, heavy
hydrocarbons, paraffinic distillates, silicone compounds, various organic acids, hydroxyl
compounds, naphtha compounds, various oils, and some metals such as lead and zinc.
When eductors are used to remove the waste accumulated in elevator pits, the effluent is a
combination of the pit waste and the flremain water that is used for eduction. It is not possible to
determine the percentages of each of these sources, because they would vary from ship to ship
depending upon a number of factors. Furthermore, effluent sampling would not help to
determine these percentages, as it would be impossible to isolate and analyze the three sources of
the discharge. The Firemain Systems NOD report contains a more complete discussion of those
constituents found in flremain water. The only constituents present in the firemain water that
were found to exceed water quality criteria were copper, iron, and nickel.
Of the constituents listed above, the expected priority pollutants in this discharge are
bis(2-ethylhexyl) phthalate, silver, chromium, copper, iron, nickel, lead, zinc, and phenols. Deck
runoff is the source of these pollutants, with the exception of bis(2-ethylhexyl) phthalate, copper,
iron, and nickel, which are also present in firemain water. Additional information concerning
these pollutants can be found hi the Deck Runoff NOD report.
No bioaccumulators are anticipated in this discharge.
3.4 Concentrations
Constituent concentrations of deck runoff resulting from precipitation will vary with a
number of factors. The following factors affecting deck runoff constituent concentrations are
dependent on time since the last rainfall or deck washdown:
• intensity and duration of rainfall;
• type, intensity, and duration of weather (high sea state and green water);
• season (which will affect glycol loading from deicing fluids);
• ship's adherence to good housekeeping practices; and
• ship's operations.
The periodicity of cleaning and lubrication of the mechanical components in the elevator
pit will also affect constituent concentrations. For example, if the guide rollers, bearings, etc.,
located in the bottom of the elevator shaft are cleaned and greased more often, the concentrations
of solvent and grease in the effluent could increase.
Elevator Pit Effluent
4
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The Firemain Systems NOD report contains a more detailed analysis of firemain water
constituent concentrations. As shown in Table 4, the firemain water constituents that exceeded
the most stringent water quality criteria were total nitrogen, bis(2-ethylhexyl) phthalate, copper,
iron, and nickel, where the total measured effluent log-normal mean concentrations were 500
micrograms per liter (ug/L), 22 ug/L, 62.4 ug/L, 370 ug/L, and 15.2 ug/L, respectively.5
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. A discussion of mass
loadings is presented in Section 4.1. In Section 4.2, the concentrations of discharge are
discussed, and in Section 4.3, the potential for the transfer of non-indigenous species is
evaluated.
4.1 Mass Loading
. Mass loadings cannot be calculated because the quantity of constituents released from
elevator pits cannot be estimated, and because the concentration of these constituents will vary as
discussed in Section 3.4. Inspections of elevator pits on Navy ships in port revealed that elevator
pits are generally dry and that elevator pit effluent is not expected to be discharged in significant
amounts within 12 n.m. because of current practices which educt the waste overboard prior to the
ship coming within 12 n.m. of shore.3
4.2 Environmental Concentrations
Concentrations of grease, oil, cleaning solvent, and other pollutants that might be present
in elevator pit effluent have not been estimated. The concentrations of total nitrogen, bis(2-
ethylhexyl) phthalate, copper, iron, and nickel in the firemain water used for eduction have been
found to exceed water quality criteria.
4.3 Potential for Introducing Non-Indigenous Species
The major sources of elevator pit effluent, deck runoff and maintenance activities, do not
have a significant potential to introduce non-indigenous species; therefore, this discharge does
not have a significant potential for transporting non-indigenous species.
5.0 CONCLUSION
Uncontrolled, elevator pit effluent could possibly have the potential to cause an adverse
environmental effect because oil could be discharged in amounts and concentrations high enough
to cause an oil sheen, especially when the vessel is pierside. There are currently no formalized
management practices in place regulating this discharge. However, surveys and inspections of
nine Navy ships indicated that the current practice is to containerize the waste for shore disposal,
Elevator Pit Effluent
5
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to transfer the waste to the ship's bilges for processing by the OWS, or to refrain from
discharging the waste overboard.3
6.0 DATA SOURCES AND REFERENCES
To characterize this discharge, information from various sources was obtained, reviewed,
and analyzed. Table 5 indicates the data source of the information presented in each section of
this NOD report.
Specific References
1. UNDS Equipment Expert Meeting Minutes - Elevator Pit Effluents. October 1,1996.
i
2. Round 2 Equipment Expert Meeting Minutes - Elevator Pit Effluent. April 3,1997.
3. Navy Fleet Technical Support Center Pacific (FTSCPAC) Inspection Report Regarding
Elevator Pit and Anchor Chain Locker Inspection Findings on Six Navy Ships, March 3,
1997.
4. Naval Surface Warfare Center, Carderock Division, Philadelphia Site (NSWCCD-SSES)
Report Regarding Number and Type of Elevators on Various Navy Vessels, Paul
Hermann, October 17,1997.
5. UNDS Phase I Sampling Data Report, Volumes 1-13, October 1997.
General References
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22, 1992.
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.
Elevator Pit Effluent
6
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Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.
Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Mississippi. Water Quality Criteria for rntrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.
New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
Texas. Texas Surface Water Quality Standards, Sections 307.2 -307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23, 1995.
Elevator Pit Effluent
7
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Table 1. Type of Elevators and Conveyors on MSC Ships
Vessel
Mars
AFS1
Niagara Falls
AFS3
Concord
AFS5
San Diego
AFS6
San Jose
AFS7
T-AFS 8 Class
3 Vessels
T-AH 19 Class
2 Vessels
T-AO 187 Class
10 Vessels
LKA-1 13 Class
2 Vessels
T-AE 28 Class
4 Vessels
T-AE 32 Class
4 Vessels
Passenger
Elevators
10 per vessel
1 per vessel
Carga Elevator
(1) 16,000 Ib CARGO
(2) 4,000 Ib (HYD)
HELO
(1) 16,000 Ib CARGO
(2) 10,000 Ib HELO
(2) 12,000 Ib CARGO
(1) 16,000 Ib CARGO
(2) 10,000 Ib HELO
(2) 12,000 Ib CARGO
(1) 16,000 Ib CARGO
(2) 10,000 HELO
(1) 16,000 Ib CARGO
(2) 10,000 Ib HELO
(2) 12,000 CARGO
(3) 4,000 Ib CARGO
8 per vessel
6 per vessel
6 per vessel
6 per vessel1
Stores Lift
(British)
1 per vessel
1. Number 6 elevator divides into two elevators.
Elevator Pit Effluent
8
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Table 2. Number and Type of Major Elevator Systems
(Navy Surface Combatants)
Ship Class
-< ?>* *
CG47
DD 9637
DDG 993
FFG7
CVN65
CVN68
CV67
CV63
Number of
Vessels -
27
35
48
1
7
1
2
Number of Elevators
-''x Per Vessel "' *:
2
2
1
14
9(CVN72-74)
10(CVN68,70,71)
11(CVN69)
9
11(CV63)
12 (CV 64)
Type of . f
r Elevator
Ammunition
Ammunition
Pallet
Weapons
Weapons
Weapons
Weapons
Elevator Pit Effluent
9
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Table 3. Number and Type of Major Elevator Systems
(Navy Auxiliary and Amphibious ships)
Ship Class
Jnderway
Replenishment
Ships
Material
Support
Ships
Amphibious
Warfare
Ships
Hull
AE27
AE28
AE29
AE32
AE33
AE34
AE35
AOE1
AOE2
AOE3
AOE4
AOE6
AOE7
AOE8
AO177
AO178
AO179
AO180
AO186
AS 36
AS 39
AS 41
LCC19
LCC20
LHA1
LHA2
LHA3
LHA4
LHA5
LHD1
LHD2
Number of
Elevators
6
6
6
7
7
7
7
9
9
9
9
6
1
6
1
7
1
1
1
1
1
8
2
2
8
2
1
8
2
1
1
1
5
1
5
1
5
1
5
1
5
1
6
1
6
1
r&r; '••'"•&**<* '•£•->* :
Elevator
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo
Cargo/Weapons
Cargo
Cargo/Weapons
Weapons
Weapons
Weapons
Weapons
Weapons
Cargo
Component
Weapons
Cargo
Component
Weapons
Cargo
Component
Weapons
Vehicle
Vehicle
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Elevator Pit Effluent
10
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Ship Class
_ ^
Amphibious
Warfare
Ships (continued)
Other Auxiliary
Ships
Hull
—
LHD3
LHD4
LHD5
LPD1
LPD2
LPD4
LPD5
LPD6
LPD7
LPD8
LPD9
LPD10
MCS12
LPD13
LPD14
LPD15
LPH3
LPH11
LPH12
LSD 41
LSD 42
LSD 43
LSD 44
LSD 45
LSD 46
LSD 47
LSD 48
LSD 49
LSD 50
LSD 51
AGF3
AGF11
•'Nandjerof
'Elevators
6
1
6
1
6
1
Decommissioned
Decommissioned
1
1
1
1
1
1
1
1
1
1
1
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
3
2
1
3
2
1
3
1
1
Type of
Elevator
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Medevac
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Cargo/Weapons
Weapons
Weapons
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Weapons
Cargo
Ammunition
Lift Platform
Cargo
Ammunition
Lift Platform
Cargo
Ammunition
Lift Platform
Cargo/Weapons/Stores
Cargo/Weapons
Elevator Pit Effluent
11
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Table 4. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituents
Classicals (ug/L)
Total Nitrogen
Organics (ug/L)
Bis(2-ethylhexyl)
phthalate
Metals (ug/L)
Copper
Dissolved
Total
Iron
Total
Nickel
Total
Log-normal
Mean
Effluent
500
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
WQC
None
None
2.4
2.9
None
74.6
Most Stringent
State Acute WQC
200 (ffl)A
5.92 (GA)
2.4 (CT, MS)
2.5 (WA)
300 (FL)
. 8.3(FL,GA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
A - Nutrient criteria are not specified as acute or chronic values.
CT e Connecticut
FL =• Florida
GA ** Georgia
MS = Mississippi
WA s Washington
Table 5. Data Sources
NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
Data Source
Reported
X
UNDS Database
X
X
MSDS
Sampling
Estimated
unknown
unknown
unknown
Equipment Expert
X
X
X
X
X
X
Elevator Pit Effluent
12
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NATURE OF DISCHARGE REPORT
Firemain* Systems
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.
Firemain Systems
1
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2.0 DISCHARGE DESCRIPTION
This section describes the firemain discharges and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
2.1 Equipment Description and Operation
Firemain systems distribute seawater for fire fighting and secondary services. The
firefighting services are fire hose stations, seawater sprinkling systems, and foam proportioning
stations. Fire hose stations are distributed throughout the ship. Seawater sprinkling systems are
provided for spaces such as ammunition magazines, missile magazines, aviation tire storerooms,
lubricating oil storerooms, dry cargo storerooms, living spaces, solid waste processing rooms,
and incinerator rooms. Foam proportioning stations are located in rough proximity to the areas
they protect, but are separated from each other for survivability reasons. Foam proportioners
inject fire fighting foam into the seawater, and the solution is then distributed to areas where
there is a risk of flammable liquid spills or fire. Foam discharge is covered in the aqueous film
forming foam (AFFF) NOD report. The secondary services provided by wet firemain systems
are washdown countermeasures, cooling water for auxiliary machinery, eductors, ship
stabilization and ballast tank filling, and flushing for urinals, commodes and pulpers. The
washdown countermeasure system includes an extensive network of pipes and nozzles, to
produce a running water film on exterior ship surfaces. Not all these services are provided on all
vessels.
Firemain systems fall under two major categories: wet and dry firemains. Wet firemains
are continuously pressurized so that the system will provide water immediately upon demand.
Dry firemains are not charged with water and, as a result, do not supply water upon demand.
Most vessels in the Navy's surface fleet operate wet firemains.1 Most vessels in the Military
Sealift Command (MSC) use dry firemains.1 All U.S. Coast Guard (USCG), and U.S. Army
vessels use dry firemains.
For the purposes of the Firemain Systems NOD report, the firemain system includes all
components between the fire pump suction sea chest and the cutout valves to the various
services. If the discharge from the service is not covered by its own NOD report, it is included in
this Firemain Systems NOD report. The components of the firemain system are the sea chests,
fire pumps, valves, piping, fire hose, and heat exchangers.
Seawater from the firemain is discharged over the side from fire hoses, or directly to the
sea through submerged pipe outlets. Seawater discharges from secondary services supplied from
the firemain are described in the pertinent NOD reports; see Section 2.2 below.
The sea chest is a chamber inset into the hull, from which seawater flows to a fire pump.
The fire pump sea chests are constructed of the hull material - steel - and are coated with durable
epoxy paints. They also contain steel waster pieces or zinc sacrificial anodes for corrosion
protection. The fire pumps are constructed of titanium, stainless steel, copper alloyed with tin or
Firemain Systems
2
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nickel, or non-metallic composites. The pipes in wet firemain systems are primarily copper-
nickel alloys and fittings are bronze that are connected by welding or by silver-brazed joints. Dry
firemain systems can be constructed of these same materials but are normally constructed of
steel.
Fire pumps are centrifugal style pumps driven by steam turbines, electric motors, and/or
diesel engines. The pumps are located in the lower levels of vessels and are sized to deliver
required flow and pressure to equipment or systems on the upper decks. Pump sizes range from
50 to 250 gallons per minute (gpm) on small vessels to 2,000 gpm on large vessels.1 To prevent
overheating when firemain load demands are low, Navy fire pumps are designed to pass 3 to 5%
of the nominal flow rate back to the sea suction or overboard.2 This also provides flow to the
pump's seals.
The firemain piping layout (architecture) is governed by the mission or combatant status
of the ship. The simplest architecture consists of a single main run fore and aft in the ship, with
single branches to the various services supplied from the firemain. More complex architectures
incorporate multiple, widely separated mains with cross connects, and feature multiple pipe paths
to vital services. Regardless of the architecture, all firemain systems include pipe sections which
may contain stagnant water. For example, except during fire fighting, the valves at the fire plugs
are closed and sprinkling systems do not flow.
Navy firemain system capacity is designed to meet peak demand during emergency
conditions, after sustaining damage. This capacity is determined by adding the largest fire
fighting demand, the vital continuous flow demands, and a percentage of the intermittent cooling
demands. The number of fire pumps required to meet this capacity is increased by a 33% margin
to account for battle damage or equipment failure.2 As a result, Navy firemain systems have
excess capacity during routine operations.
Firemain capacity on most MSC, U.S. Coast Guard (USCG), and Army ships is designed
to commercial standards as prescribed by regulations pertinent to each ship type.3'4 Ships
acquired from naval or other sources satisfy other design criteria, but the firemain capacity
requirements meet or exceed commercial standards. A minimum of two pumps is required. The
required firemain capacity is less than would be required on Navy ships of similar type and size.
Dry firemains are not charged and do not provide instantaneous water pressure. These
systems are periodically tested as part of the planned maintenance system (PMS) and are
pressurized during training exercises.
2.2 Releases to the Environment
Seawater discharged overboard from the firemain contains entrained or dissolved
materials, principally metals, from the components of the firemain system. Some traces of oil or
other lubricants may enter the seawater from valves or pumps.
Firemain Systems
3
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Fire fighting, space dewatering using eductors, counterflooding, and countermeasure
washdown constitute emergency discharges from the firemain, and are not incidental to the
vessel's operation. Some auxiliary machinery is provided with backup emergency cooling from
the firemain. Use of the firemain for backup emergency cooling is not an incidental discharge.
Seawater from the firemain is released to the environment as an incidental discharge for the
following services:
• Test and maintenance;
• Training;
• Cooling water for auxiliary machinery and equipment, for which the firemain is the
normal cooling supply. Examples are central refrigeration plants, steering gear
coolers, and the Close In Weapon System;
• Bypass flow overboard from the pump outlet, to prevent overheating of fire pumps
when system demands are low; and
• Anchor chain washdown.
The following are incidental services provided from the firemain, but the release to the
environment is discussed separately as shown:
• Ballast tank filling (Clean Ballast NOD report);
• Flushing water for commodes (Black Water[sewage]; not part of the UNDS study);
• Flushing water for food garbage grinders (Graywater NOD report);
• Stem tube seals lubrication (Stern Tube Seals & Underwater Bearing Lubrication
NOD report); and
• AFFF (AFFF NOD report).
2.3 Vessels Producing the Discharge
All Navy surface ships use wet firemain systems with the exception of two classes of
oceanographic research ships. Submarines use dry systems. Boats and craft are not equipped
with firemain systems and generally use portable fire pumps or fire extinguishers for fire
fighting. Most ships operated by the MSC use dry firemain systems, so they do not continuously
discharge water overboard as part of normal operations; however, two classes of ships use wet
firemains. These classes are ammunition ships (T-AE) and combat stores ships (T-AFS). The
USCG and Army use dry firemain systems, so they do not continuously discharge water
overboard as part of normal operations. Table 1 lists the ships and submarines in the Navy,
MSC, USCG, and Army, and notes whether their firemain systems are the wet or dry type.
3.0 DISCHARGE CHARACTERISTICS
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.
Firemain Systems
4
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3.1 Locality
Firemain discharge occurs both within and beyond 12 nautical miles (n.m.) of shore.
3.2 Rate
The flow rates for wet firemain discharge depend on the type, number, and operating time
of equipment and systems that use water from the firemain. Operating times of many systems are
highly variable. Some connected services, such as refrigeration plants, are operated
continuously; others, such as hydraulics cooling or aircraft carrier jet blast deflectors, are
operated only during specific ship evolutions. Ships with auxiliary seawater cooling systems
tend to have relatively few services that draw continuous flow from the firemain. For these
ships, the firemain discharge will be small compared to the discharge from the seawater cooling
system. Table 2 shows the theoretical upper bound estimate of discharge from wet firemain
systems, with an estimated total annual volume of approximately 18.6 billion gallons. The
estimate is considered an upper bound because, for most ships, all flow from the fire pumps is
assumed to be an environmental release attributable to the firemain system.
Sample calculation for Table 2:
ISVjC^ffii^*^ 12 n.m./yjr) ~ gal/yr
The discharge from dry firemains is approximately 0.1% of the discharge from wet
firemains because none of the discharge is continuous. A theoretical upper bound estimate for
discharges from dry systems within 12 n.m. is given in Table 3.
Sample calculation for Table 3:
(Qty of ships)(Flow rate (gpm))(tO minute$/wk)(Days within 12 n.m./yr)(l wk/7 days) = gal/yr
The 10 minutes/week is based on a minimum of 2 pumps required by USCG regulations,
in addition to a run time of 5 minutes/week per pump based upon equipment expert
knowledge.5'6'7
3.3 Constituents
The water for firemain services is drawn from the sea and returned to the sea. Metals and
other materials from the firemain and its components can be dissolved by the seawater. Table 4
lists such metals and other materials. Where seawater flow is turbulent, particles of metal will be
eroded from pump impellers, valve bodies, and pipe sections, and carried in the firemain as
entrained particles.8 Electrochemical corrosion attacks at the junctions of dissimilar metals to
produce both dissolved and particulate metals. Any wetted material in the system can contribute
dissolved or particulate constituents to the firemain discharge. These constituents can include
copper, nickel, aluminum, tin, silver, iron, titanium, chromium, and zinc. Based on knowledge
Firemain Systems
5
-------
of the system, the principal expected constituents that are priority pollutants would be copper,
nickel, and zinc. Copper and nickel are found in the piping of wet firemain systems, and
sacrificial zinc anodes are placed in some sea chests and heat exchangers. None of these
expected constituents are bioaccumulators.
Most dry type firemain systems are constructed of steel pipe, without zinc anodes.
Therefore, copper, nickel and zinc are not expected constituents of dry type firemain systems.
3.4 Concentrations
The firemain systems of three ships were sampled for 26 metals (total and dissolved),
semi-volatile organic compounds, polychlorinated biphenyls (PCBs), and classical constituents.
Only wet firemains were sampled because the volumes discharged by wet firemains comprise the
vast majority of the total volume of the discharge. The firemains were sampled both at the inlet
and at the discharge to determine what constituents were contributed by the firemain system.
The three ships sampled were a dock landing ship, an aircraft carrier, and an amphibious assault
ship. Details of the sampling effort and the sampled data are described in the Sampling Episodes
Report for seawater cooling. Table 4 summarizes the results.
Variability is expected within this discharge as a result of several factors including
material erosion and corrosion, residence times, passive films, and influent water variability.
Pipe erosion is caused by high fluid velocity, or by abrasive particles entrained in the seawater
flowing at any velocity. In most cases of pipe erosion, the problematic high fluid velocity is a
local phenomenon, such as would be caused by eddy turbulence at joints, bends, reducers,
attached mollusks, or tortuous flow paths in valves. Passive films inhibit metal loss due to
erosion. Corrosion is influenced by the residence time of seawater hi the system, temperature,
biofouling, constituents hi the influent, and the presence or absence of certain films on the pipe
surface. All of these influences on metallic concentrations are variable within a given ship over
time, and between ships.
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented hi Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria.
Section 4.3 discusses thermal effects. In Section 4.4, the potential for the transfer of non-
indigenous species is discussed.
4.1 Mass Loadings
Mass loadings are shown hi Table 5. The concentrations of constituents contributed by
the firemain system were combined with the estimated annual firemain discharge from Table 2
for wet firemains to determine mass loadings by the equation:
Firemain Systems
6
-------
Mass Loading (Ibs/yr) = (Table 4 net log normal mean concentration ;. „
(Table 2 discharge volume (IS.o" biiBonga!/yr))(3.785 L/gal)(2.205 lbs/kg)(10'9kg/^g).
Dry firemains were not sampled. Most dry firemain systems are constructed of steel, so
the principal expected metallic constituent will be iron. The discharge rate from dry firemain
systems is about 0.1% of the rate from wet firemain systems, so the mass loadings should also be
much less. Accordingly, the mass loadings from dry firemain systems were not included in the
mass loading estimates.
4.2 Environmental Concentrations
Table 6 compares measured constituent concentrations with Federal and the most
stringent state chronic water quality criteria (WQC). The comparison in Table 6 shows that the
effluent concentrations of bis(2-ethylhexyl) phthalate, nitrogen (as nitrate/nitrite and total
nitrogen), copper, iron, and nickel exceed WQC. The copper and nickel contributions each
exceed both the Federal and most stringent state criteria. The ambient copper concentration in
most ports exceeds the chronic WQC. As mentioned previously, copper and nickel constitute the
major construction materials for wet firemains in the Navy. Bis(2-ethylhexyl) phthalate, nitrogen,
and iron concentration exceeds the most stringent state chronic criterion.
4.3 Thermal Effects
As mentioned previously, portions of the firemain are used for seawater cooling purposes
and will discharge excess thermal energy to receiving waters. The thermal plume from firemains
was not modeled directly; however, firemain discharge can be compared to a discharge that was
modeled, such as seawater cooling water from an Arleigh Burke Class (DDG 51) guided missile
destroyer. The use of DDG51 flow parameters for seawater cooling will overestimate the size of
the thermal plume because all vessels have firemain discharge rates less than the estimated
pierside seawater cooling rate of 1,680 gpm for a DDG 51 class ship. Additionally, the
temperature difference (delta T) between the effluent and influent for firemain is lower
(measured at 5°F) than the delta T for seawater cooling from a DDG 51 class ship (measured at
The seawater cooling water discharge was modeled using the Cornell Mixing Zone
Expert System (CORMK) to estimate the plume size and temperature gradients in a receiving
water body using conditions tending to produce the largest thermal plume. Thermal modeling
was performed for the DDG 51 in two harbors (Norfolk, Virginia; and Bremerton, Washington).
Of the five states that have the largest presence of Armed Forces vessels, only Virginia, and
Washington have established thermal mixing zone criteria.9 The discharge was also assumed to
occur in winter when the discharge would produce the largest thermal plume. Based on
modeling for a DDG 51 class ship, the resulting plume did not exceed the thermal mixing zone
requirements for Virginia or Washington.9
All vessels.have firemain discharge rates less than the seawater cooling discharge rate,
and delta T's less than the measured temperature difference associated with a DDG 51.
Firemain Systems
7
-------
Therefore, the heat rejection rate from any firemain system will be lower than that of a DDG 51
class ship for seawater cooling water. Accordingly, the resulting thermal plume for the firemain
discharge is not expected to exceed the thermal criteria for, Virginia or Washington and adverse
thermal effects are not anticipated.
4.4 Potential for Introducing Non-Indigenous Species
.•
Wet and dry firemain systems have a minimal potential for transporting non-indigenous
species, because the residence times for most portions of the system are short. Some portions of
the system lie stagnant where marine organisms may reside. However, these areas tend to
develop anaerobic conditions quickly, except at the junctions with the active portions of the
system, where oxygenated water continuously flows by and through the ship. Anaerobic
conditions are not hospitable to most marine organisms. Additionally, firemain systems do not
transport large volumes of water over large distances.
5.0 CONCLUSIONS
Firemain discharge has the potential to cause an adverse environmental effect because the
concentrations of Bis(2-ethylhexyl) phthalate, nitrogen, copper, nickel, and iron exceed federal or
most stringent state water quality criteria and the estimated annual mass loadings for these metals
are significant. The thermal effects of this discharge were reviewed and are not significant. The
potential for introducing non-indigenous species is minimal.
6.0 REFERENCES
To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge and sampling was
performed to gather results related to the constituents and concentrations of the discharge. Table
7 shows the sources of data used to develop this NOD report.
Specific References
1. UNDS Equipment Expert Meeting Minutes. Firemain System Discharge. 8 October,
1996.
2. Naval Sea Systems Command, Design Practice and Criteria Manual for Surface Ship
Firemain Systems, 1988.
3. Naval Sea Systems Command, Commercial General Specifications for T-ships of the
United States Navy, 1991 Ed. 15 March 1991.
4. Code of Federal Regulations, 46 CFR Parts 34, 76, and 95.
Firemain Systems
8
-------
5.
6.
7.
8.
9.
Code of Federal Regulations, 46 CFR Part 34. 10-5.
Weersing, Penny, Military Sealift Command Central Technical Activity. Dry firemain
discharge within 12 n.m., 17 March 1997, David Eaton, M. Rosenblatt & Son.
Fischer, Russ, Army. Dry Firemain Discharge within 12 n.m., 13 March 1998, Ayman
Ibrahim, M. Rosenblatt & Son.
The International Nickel Company, Guidelines for Selection of Marine Materials 2nd
Ed., May 1971.
NAVSEA. Thermal Effects Screening of Discharges from Vessels of the Armed
Services. Versar, Inc. July 3,1997.
General References
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
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.
Firemain Systems
9
-------
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).
Van der Leeden, et al. The Water Encyclopedia, 2nd Ed. Lewis Publishers: Chelsea, Michigan,
1990.
Malcolm Pirnie, Inc. UNDS Phase 1 Sampling Data Report, Volumes 1 through 13, October
1997.
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register,?. 15366. March23,1995.
ii
UNDS Ship Database, August 1,1997.
Firemain Systems
10
-------
Table 1. Wet and Dry Firemains of the Navy, MSC, USCG, and Army
, Class
{
SSBN
SSN
SSN
SSN
SSN
cv
CVN
CV
CVN
CGN
CG
CGN
DDG
DDG
DD
FFG
LCC
LHD
LHA
LPH
LPD
LPD
LPD
LSD
LSD
LSD
MCM
MHC
PC
AGF
AGF
AO
AOE
AOE
ARS
AS
AS
AGOR
AGOR
T-AE
T-AFS
T-ATF
T-AO
Description - " ; x
/* , * \
Navy Ships
Ohio Class Ballistic Missile Submarines
Sturgeon Class Attack Submarines
Los Angeles Class Attack Submarines
Narwhal Class Submarine
Benjamin Franklin Class Submarines
Forrestal Class Aircraft Carrier
Enterprise Class Aircraft Carrier
Kitty Hawk Class Aircraft Carriers
Nimitz Class Aircraft Carriers
Virginia Class Guided Missile Cruiser
Ticonderoga Class Guided Missile Cruisers
California Class Guided Missile Cruisers
Kidd Class Guided Missile Destroyers
Arleigh Burke Class Guided Missile Destroyers
Spruance Class Destroyers
Oliver Hazard Perry Guided Missile Frigates
Blue Ridge Class Amphibious Command Ships
Wasp Class Amphibious Assault Ships
Tarawa Class Amphibious Assault Ships
Iwo Jima Class Assault Ships
Austin Class Amphibious Transport Docks
Amphibious Transport Docks
Amphibious Transport Docks
Whidbey Island Class Dock Landing Ships
Harpers Ferry Dock Landing Ships
Anchorage Class Dock Landing Ships
Avenger Class Mine Countermeasure Vessels
Osprey Class Minehunter Coastal Vessels
Cyclone Class Coastal Defense Ships
Navy Auxiliary Ships
Raleigh Class Miscellaneous Command Ship
Austin Class Miscellaneous Command Ship
Jumboised Cimarron Class Oilers
Supply Class Fast Combat Support Ships
Sacramento Class Fast Combat Support Ships
Safeguard Class Salvage Ships
Emory S Land Class Submarine Tenders
Simon Lake Class Submarine Tender
Gyre Class Oceanographic Research Ship
Thompson Class Oceanographic Research Ships
Military Sealift Command
Kilauea Class Ammunition Ships
Mars Class Combat Stores Ships
Powhatan Class Fleet Ocean Tugs
Henry J Kaiser Class Oilers
Quantity of
Vessels
17
13
56
1
2
1
1
3
7
1
27
2
4
18
31
43
2
4
5
2
3
2
3
8
3
5
14
12
13
1
1
. 5
3
4
4
3
1
1
2
8
8
7
13
Wet/Dry
Dry
Dry
Dry
Dry
Dry
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Wet
Dry
Dry
Wet
Wet
Dry
Dry
Firemain Systems
11
-------
Class
T-AGM
T-ARC
T-AKR
T-AKR
T-AGOS
T-AGOS
T-AG
T-AGS
T-AGS
T-AGS
T-AGS
WHEC
WMEC
WMEC
WMEC
WMEC
WMEC
WMEC
WAGE
WAGE
WTGB
WPB
WPB
WLB
WLB
WLB
WLB
WLM
WLM
WLI
WLR
WLR
WLR
WLX
WLIC
WLIC
WLIC
WLIC
WYTL
FMS
LSV
LCU
LT
Description >
Compass Island Class Missile Instrumentation Ships
Zeus Class Cable Repairing Ship
Maersk Class Fast Sealift Ships
Algol Class Vehicle Cargo Ships
Stalwart Class Ocean Surveillance Ships
Victorious Class Ocean Surveillance Ships
Mission Class Navigation Research Ships
Silas Bent Class Surveying Ships
Waters Class Surveying Ship
McDonnell Class Surveying Ships
Pathfinder Class Surveying Ships
Coast Guard
Hamilton and Hero Class High Endurance Cutters
Storis Class Medium Endurance Cutter
Diver Class Medium Endurance Cutter
Famous Class Medium Endurance Cutters, Flight A
Famous Class Medium Endurance Cutters, Flight B
Reliance Class Medium Endurance Cutters, Flight A
Reliance Class Medium Endurance Cutters, Flight B
Mackinaw Class Icebreaker
Polar Class Icebreakers
Bay Class Icebreaking Tugs
Point Class Patrol Craft
Island Class Patrol Craft
Juniper Class Seagoing Buoy Tenders
Balsam Class Seagoing Buoy Tenders, Flight A
Balsam Class Seagoing Buoy Tenders, Flight B
Balsam Class Seagoing Buoy Tenders, Flight C
Keeper Class Coastal Buoy Tenders
White Sumac Class Coastal Buoy Tenders
Inland Buoy Tenders
River Buoy Tenders, 1 15-foot
River Buoy Tenders, 75-foot
River Buoy Tenders, 65-foot
Eagle Class Sail Training Cutter
Inland Construction Tender, 115-foot
Pamlico Class Inland Construction Tenders
Cosmos Class Inland Construction Tenders
Anvil and Clamp Classes Inland Construction Tenders
65 ft. Class Harbor Tugs
Army
Floating Machine Shops
Frank S. Besson Class Logistic Support Vessels
2000 Class Utility Landing Craft
Inland and Coastal Tugs
Quantity of
Vessels
1
1
3
8
5
4
2
2
1
2
4
12
1
1
4
9
5
11
1
2
9
36
49
2
8
2
13
2
9
6
1
13
6
1
1
4
3
7
11
3
6
48
25
Wet/Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Firemain Systems
12
-------
Table 2. Theoretical Upper Bound-Estimate of Annual Wet Firemain Discharge
Class
cv
CVN
CV
CVN
CGN
CG
CGN
DDG
DDG
DD
FFG
LCC
LHD
LHA
LPH
LPD
LPD
LPD
LSD
LSD
LSD
MCM
MHC
PC
AGF
AGF
AO
AOE
AOE
ARS
AS
AS
T-AE
T-AFS
Description, /-, .:
'"'" - ~ ;
-------
Table 3. Theoretical Upper-Bound Estimate of Annual Dry Firemain Discharge
Class
SSBN
SSN
SSN
SSN
SSN
AGOR
AGOR
T-ATF
T-AO
T-AGM
T-AH
T-ARC
T-AKR
T-AKR
T-AGOS
T-AGOS
T-AG
T-AGS
T-AGS
T-AGS
T-AGS
WHEC
WMEC
WMEC
WMEC
WMEC
WMEC
WMEC
WAGB
WAGE
WTGB
WPB
WPB
WLB
Description
Navy
Ohio Class Ballistic Missile Submarines
Sturgeon Class Attack Submarines
Los Angeles Class Attack Submarines
Narwhal Class Submarine
Benjamin Franklin Class Submarines
Navy Auxiliary
Gyre Class Oceanographic Research Ship
Thompson Class Oceanographic Research Ships
Military Sealift Command
Powhatan Class Fleet Ocean Tugs
Henry J Kaiser Class Oilers
Compass Island Class Missile Instrumentation Ships
Mercy Class Hospital Ships
Zeus Class Cable Repairing Ship
Maesrk Class Fast Sealift Ships
Algol Class Vehicle Cargo Ships
Stalwart Class Ocean Surveillance Ships
Victorious Class Ocean Surveillance Ship
Mission Class Navigation Research Ships
Silas Bent Class Surveying Ships
Waters Class Surveying Ship
McDonnel Class Surveying Ships
Pathfinder Class Surveying Ships
Coast Guard
Hamilton and Hero Class High Endurance Cutters
Storis Class Medium Endurance Cutter
Diver Class Medium Endurance Cutters
Famous Class Medium Endurance Cutters, Flight A
Famous Class Medium Endurance Cutters, Flight B
Reliance Class Medium Endurance Cutters, Flight A
Reliance Class Medium Endurance Cutters, Flight B
Mackinaw Class Icebreaker
Polar Class Icebreaker
Bay Class Icebreaking Tugs
Point Class Patrol Craft
Island Class Patrol Craft
Juniper Class Seagoing Buoy Tenders
Flow
(GPM)
250
250
250
250
250
50
100
100
200
100
400
100
400
400
200
200
200
200
200
200
200
250
250
250
250
250
250
250
250
250
250
50
50
200
Quantity
ofVessels
17
13
56
1
2
1
2
7
13
2
2
1
3
8
5
4
2
2
1
2
4
12
1
1
4
9
5
11
1
2
9
36
49
16
Days
within
•:'I;2Eum. •
183
183
183
183
183
113
113
127
78
133
184
8
59
350
70
107
151
44
7
96
96
151
167
98
137
164
235
149
365
365
365
157
157
290
Estimated
Annual Volume
- ::.
-------
Class
WLB
WLB
WLB
WLM
WLM
WLI
WLR
WLR
WLR
WIX
WLIC
WLIC
WLIC
WLIC
WYTL
FMS
LSV
LCU
LT
Description
'' ' " * f ~ ~ s
"*. " ' •j. ^
Balsam Class Seagoing Buoy Tenders, Flight A
Balsam Class Seagoing Buoy Tenders, Flight B
Balsam Class Seagoing Buoy Tenders, Flight C
Keeper Class Coastal Buoy Tenders
White Sumac Class Coastal Buoy Tenders
Inland Buoy Tenders
River Buoy Tenders, 115-foot
River Buoy Tenders, 75-foot
River Buoy Tenders, 65-foot
Eagle Class Sail Training Cutter
Inland Construction Tenders, 115 foot
Pamlico Class Inland Construction Tenders
Cosmos Class Inland Construction Tenders
Anvil and Clamp Classes Inland Construction
Tenders
65 ft. Class Harbor Tugs
Army
Floating Machine Shops
Frank S. Besson Class Logistic Support Vessel
2000 Class Utility Landing Craft
Inland and Coastal Tugs
HOW
(GPM)
200
200
200
100
100
100
100
100
100
50
50
50
50
50
50
400
564
500
640
"Quantity
,ofVesse!s
8
2
13
2
9
6
1
13
6
1
1
4
3
27
14
3
6
48
25
Days
within
12 n.m.
290
220
223
323
223
365
365
365
365
188
365
365
365
365
350
350
180
335
295
Total
Estimated
Annual
Volume,
(gal):
Estimated
Annual Volume
(&A)
662,857
125,714
828,286
92,286
286,714
312,857
52,143
677,857
312,857
13,429
26,071
104,286
78,214
703,929
350,000
600,000
870,171
11,485,714
3,371,429
35,992^85
Note:
1. Estimates assume that all discharge is due to maintenance or testing. All fire fighting exercises are assumed to occur
at sea beyond 12 n.m. Maintenance is assumed to occur weekly while vessels are in port, with seawater flowing at the
design rate of the pumps for 5 minutes each week.
Firemain Systems
15
-------
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PHTHALATE
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-------
Table 5. Estimated Annual Mass Loadings of Constituents
Constituent*
Bis(2-ethylhexyl)
phthalate
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen*
Copper
Dissolved
Total
Iron
Total
Nickel
Dissolved
Total
Log-normal Mean
InfluentJug/L)
-
60
310
8.43
16.82
348.48
-
-
Log-normal Mean
Effluent (Mg/I;)
22
20
480
24.9
62.4
370
13.8
15.2
Log-normal Mean
Concentration (Mg/L)
22.04
-40
170
16.46
45.59
21.28
13.8 (b)
15.2 (b)
Estimated Annual
Mass Loading (Ibs/yr)
3,414
(a)
26,330
26,330
3,111
8,618
4,022
2,142 (b)
2,360 (b)
1 Mass loadings are presented for constituents that exceed WQC only. See Table 4 for a complete listing of mass
loadings.
Notes:
* Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
(a) - Mass loading was not determined for parameters for which the influent concentration exceeded the effluent
(b) - No background concentration is given for the parameter
Firemain Systems
18
-------
Table 6. Mean Concentrations of Constituents that Exceed Water Quality Criteria
Constituents
#
T N
Classicals (ng/L)
Nitrate/Nitrite
Total Kjeldahl
Nitrogen
Total Nitrogen8
Organics (|ig/L)
Bis(2-ethylhexyl)
phthalate
Metals (fig/L)
Copper
Dissolved
Total
Iron
Total
Nickel
Dissolved
Total
Log-normal
• Mean
Effluent
20
480
500
22
24.9
62.4
370
13.8
15.2
Minimum
'Concentration
Effluent
BDL
230
BDL
BDL
34.2
95.4
BDL
BDL
Maximum
Concentration
-Effluent
400
840
428
150
143
911
38.9
52.1
, ,- Federal
Chronic WQC
None
None
None
None
2.4
2.9
None
8.2
8.3
Most Stringent State
», Chronic WQC
8(HI)A
-
200 (ffl)A
5.92 (GA)
2.4 (CT, MS)
2.9 (GA, FL)
300 (FL)
8.2 (CA, CT)
7.9 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4,1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
BDL-Below Detection Level
CA = California
CT = Connecticut
FL = Florida
GA = Georgia
HI = Hawaii
MS = Mississippi
WA = Washington
Firemain Systems
19
-------
Table?. Data Sources
NOD Section
2.1 Equipment Description and
Operation
2.2 Releases to the Environment
23 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
4.1 Mass Loadings
4.2 Environmental Concentrations
43 Thermal Effects
4.4 Potential for Introducing Non-
Indigenous Species
Data Sources . •. , :•-• -. -• ;•?" • ••:-•
Reported
UNDS Database
X
Sampling
X
X
X
Estimated
X
X
X
Equipment Expert:
X
X
X
X
X
Firemain Systems
20
-------
NATURE OF DISCHARGE REPORT
Freshwater Layup
1.0 INTRODUCTION
The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)]. UNDS is being developed hi three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.
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.
Freshwater Layup
1
-------
2.0 DISCHARGE DESCRIPTION
This section describes the freshwater layup discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
I
i
2.1 Equipment Description and Operation
j
I
Seawater cooling systems on vessels provide cooling water for propulsion plant and
auxiliary system heat exchangers. Heat exchangers remove heat directly from the main
propulsion machinery and the electrical generating plants, and directly or indirectly from all other
equipment requiring cooling. The primary purpose of the main seawater system is to provide the
coolant to condense low pressure steam from the main turbines and the generator turbines.1
!!
When nuclear-powered submarines and aircraft carriers remain for an extended period
and the seawater cooling systems are not circulated, the main condensers are placed in a
freshwater layup.1 The purpose of placing the condensers in a freshwater layup is to prevent the
accumulation of biological growth and the resultant loss of condenser efficiency while the
seawater cooling system is not in use. The propulsion plants of nuclear-powered vessels
generally require a 2- to 3-day cooling down period prior to being laid up.1
The layup is accomplished by blowing the seawater from the main condensers with low
pressure air and isolating the condensers.1 The condensers are then filled with potable water
from port facilities, a process that takes 1 to 2 hours, or more, to complete.2 The potable water
remains in the condensers, uncirculated, for approximately 2 hours. After this period of time, the
potable water fill is blown overboard with low pressure air, which takes approximately an hour to
accomplish.112 The condensers are then considered flushed of any residual seawater (seawater or
potable water). The condensers are then refilled with potable water for the actual layup. This
process can be referred to as a double fill and flush cycle.
j
' i
After 21 days, the initial fill water is discharged overboard and replaced. The layup is
discharged and refilled on a 30-day cycle thereafter.1 This process can be referred to as a refill
cycle. The freshwater layup may be terminated at any point during these cycles to support
equipment maintenance or ship's movement.
During a ship check and sampling episode aboard USS Scranton (SSN 756), it was
observed that the main seawater condensers were filled indirectly with freshwater from port
facilities.3 The crew filled the forward potable water tank from the pier connection and then
transferred the freshwater to the aft potable water tank.3 The main condensers were then put in
freshwater layup from the aft potable water tank.3 The initial freshwater layup process lasted
greater than 5 hours (e.g., from the beginning of initial fill to initiating the low pressure air blow
to remove the initial freshwater flush).3
!|
The main steam condensers on submarines are constructed either of titanium or 70/30
copper/nickel alloy.4 Aircraft carrier main seawater condensers are constructed of 90/10
Freshwater Layup
2
-------
copper/nickel alloy. The condenser boxes for the 70/30 copper/nickel alloy condensers are
constructed of a nickel/copper alloy and can be lined with a tin/lead solder and have zinc anodes
installed for corrosion control.4 The seawater piping that carries cooling water from the
condensers to overboard discharge is constructed of 70/30 copper/nickel piping.4
2.2 Releases to the Environment
These discharges occur in port at pierside when the submarine's nuclear power plant has
cooled and the main seawater cooling system is unable to be circulated for more than 3 days.
Also, this discharge can occur if the ship will be hi port for greater than 7 days (i.e., It takes 72
hours to cool down a reactor and 72 hours to ramp up a reactor which translates to six days, or
roughly one week.) and the seawater cooling system can not be circulated. The freshwater is
discharged from the seawater cooling piping openings located below the waterline of the ship.
The discharge occurs when the fresh water is pushed out by low pressure air applied to the
seawater cooling piping system. It is expected that this discharge will contain many of the
constituents found in the fresh water (typically supplied by port facilities) used for the layup, as
well as metals leached from the ship's piping system while the water is held during the layup,
and any residual seawater remaining in the system after the double fill and flush.
2.3 Vessels Producing the Discharge
All attack submarines (SSNs), ballistic missile submarines (SSBNs), and nuclear-
powered carriers (CVNs) generate this discharge. A total of 89 SSNs and SSBNs, and eight
CVNs are currently in service in the Navy. While the three existing nuclear guided missile
cruisers (CGNs) also produce this discharge, these are scheduled to be removed from service by
2003/2004, and therefore, will not be considered further. The Navy is the only member of the
Armed Forces that operates nuclear-powered vessels.
3.0 DISCHARGE CHARACTERISTICS
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 hi
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.
3.1 Locality
This discharge only occurs when vessels are in port.
3.2 Rate
The volume of the initial fill and flush of a nuclear-powered submarine is approximately
6,000 gallons of freshwater. This 6,000 gallons of freshwater is discharged overboard after a 1-
to 2-hour layup in the main seawater condensers and refilled with an additional 6,000 gallons of
Freshwater Layup
3
-------
freshwater as described in Section 2.1.5 The total volume of freshwater required for the fill,
flush, and refill of the condenser for freshwater layup on nuclear submarines is approximately
12,000 gallons, of which 6,000 gallons is discharged overboard.5 The volume of this discharge
will vary with the volumes of the main steam condensers for each submarine class.5
The amount of time that a submarine is in port, and hence, the number of layup cycles
required, is dependent upon many factors, the most critical being the submarine's current
mission. Each mission requires varying times in port for preparation, repairs, or modifications to
support the mission specifics. In addition, many submarines undergo overhauls or other
maintenance and/or repair activities that extend their time in port (e.g., must put their seawater
systems into a dry layup condition).
i
i!
Attack submarines (SSNs) average about 10 layup cycles per year, including five double
fill and flush cycles and five refill cycles.5 Each double fill and flush cycles and each refill cycle
discharges approximately 6,000 gallons of freshwater per evolution. This results in 60,000
gallons of freshwater for each of the Navy's 72 SSNs per year. Therefore, fleet-wide discharge
for the SSNs is 4,320,000 gallons of freshwater layup discharge per year, of which half is from
the initial fill and half is from the refill cycles, or 2,160,000 gallons for each.
Ballistic missile submarines (SSBNs) have extended layovers of 1 to 1 1/2 months
approximately three or four tunes per year. The volume of seawater systems in ballistic missile
submarines are comparable to those of attack submarines. These submarines have an estimated
three initial flush and fill cycles per year and approximately six refill cycles per year. For an
SSBN, this totals 54,000 gallons per submarine per year. The Navy operates 17 SSBNs.
Therefore, the total freshwater layup discharged for all SSBNs is estimated to be 918,000 gallons
per year, of which 306,000 gallons is from the initial fill and flush and 612,000 gallons is from
refill cycles.
A total estimated volume of 5,238,000 gallons of freshwater layup is discharged in U.S.
ports from the 89 SSN and SSBN hulls. The initial fill cycle accounts for 2,466,000 gallons and
the refill cycles account for 2,772,000 gallons.
Nuclear powered aircraft carriers do establish freshwater layups in their various
condensers, but the effluent is dumped into the bilges of the ship rather than being discharged
directly overboard. Hence, the residual water from the aircraft carriers' layup is covered under
the Surface Vessel Bilgewater/OWS Nature of Discharge report.
3.3 Constituents
The freshwater used hi the freshwater layup can contain disinfectants from potable water
treatment. The most common disinfectant is chlorine. Some municipalities, however, are
switching over to chloramine disinfection to reduce the amount of disinfectant by-products
formed. This switch could be permanent or seasonal, with the chloramines added during the
warmer months when formation of disinfectant by-products are more prevalent. It is noted that
Freshwater Layup
4
-------
the constituent make-up of the freshwater used to conduct the layup will have a significant effect
on the discharge.
The constituents that can be present in freshwater layup from nuclear-powered
submarines include: copper, lead, nickel, chlorine, ammonia, nitrogen (as nitrate/nitrite, and total
kjeldahl nitrogen), phosphorous and related disinfectants, chromium, tin, titanium and zinc.
Chromium, copper, lead, nickel, and zinc are priority pollutants. None of these constituents are
bioaccumulators. The freshwater layup of a single submarine was sampled to determine the
constituents that are present in the discharge.
3.4 Concentrations
The water used to fill the main condensers, the initial layup discharge, and an extended,
21-day discharge were sampled from USS Scranton (SSN 756).3 A total of 17 metals were
measurable in the initial and extended layup discharges from the sampling event. The vast
majority of the metals detected have sources from either the materials within the main steam
condenser or from the domestic water treatment/distribution system. The metals and classical
parameters detected in the discharge are compiled in Table 1. In addition, the mass loadings are
estimated for those constituents that were detected in either the 2-hour or 21-day layup
discharges. Three priority pollutant metals, copper, nickel and zinc, were detected in the
discharge at elevated concentrations. Total chlorine was also detected in the initial layup
discharge (28 |ig/L), but not in the discharge after 21 days. The domestic water from the pier
connection was also sampled for total and free residual chlorine levels and contained 1,200 jj.g/L
and 1,000 p.g/L, respectively.3 Nitrogen (as nitrate/nitrite, and total kjeldahl nitrogen), ammonia,
and phosphorous were detected in both the 2-hour layup and the 21-day layup discharges.
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
4.1 Mass Loadings
Based upon the concentrations of the metals reported for the layup effluents in Table 1
and the estimated discharge volumes in Section 3.2, the mass loadings were calculated using the
estimated volumes of freshwater layup discharge in Table 2 for those constituents that exceeded
either Federal or most stringent state water quality criteria (WQC). Table 3 highlights the
constituents that exceed WQC. The estimated mass loadings, provided in Table 2, are derived by
adding together contributions from both the initial fill volumes and the refill cycle volumes,
because the two portions of the effluent have different concentrations.
Freshwater Layup
5
-------
(cone. ug/L)(g/l,000,000 jig) (lbs/453.593 g) (annual volume gal/yr) (3,785 Vgal) ••
mass loading (Ibs/yr)
Based on the sampling data, the total fleet-wide loadings of ammonia, nitrogen, chlorine,
copper, nickel, phosphorous, and zinc from this discharge are approximately 41, 55,1, 7, 36, 8,
and 29 pounds per year, respectively.
i
. . !
4.2 Environmental Concentrations
The discharge concentrations presented hi Table 3 are compared to Federal and most
stringent state WQC.
Copper was present in the fill water from the aft potable water tank, but it is unknown if
copper was present in domestic water from the pier connection. The fill water copper
concentrations exceeded Federal and the most stringent state. Copper is normally present in the
domestic water supply in concentrations that exceed WQC because of the presence of copper-
constructed components in drinking water distribution systems. The levels of copper can be
partially attributable to the construction of the potable water systems on board the submarine
through which the domestic water was routed prior to filling the main seawater condensers.
These systems have copper piping and brass valves that can contribute copper to the water.
Table 3 shows the concentrations of the three priority pollutant metals (copper, nickel,
and zinc) that exceed Federal and most stringent state WQC. The chlorine concentration from
the initial 2-hour layup exceeds the most stringent state criterion. Ammonia, total nitrogen (as
nitrate/nitrite, and total kjeldahl nitrogen), and total phosphorous concentrations in the two layup
discharges exceed the most stringent state criterion. The presence of phosphorous in the effluent
appears to be from the domestic water as the effluent concentrations for total phosphorous shows
no increase over the fill water concentrations.
i
4.3 Potential for Introducing Non-Indigenous Species
There is no movement of the vessel during the layup process and the water used for the
layup is chlorinated domestic water from shore facilities. As such, there is no potential for
transporting non-indigenous species.
5.0 CONCLUSION
Freshwater layup of seawater cooling systems has a low potential of adverse
environmental effects for the following reasons.
i
1. The mass loadings of chlorine, copper, nickel, and zinc are small although the
concentrations exceed Federal and most stringent state WQC. The mass loadings
of ammonia, nitrogen, and phosphorous are also small, but concentrations exceed
the most stringent state WQC. The total annual mass loadings for ammonia,
i
Freshwater Layup
6
-------
2.
nitrogen, chlorine, copper, nickel, phosphorous, and zinc contribute
approximately 41, 55,1, 7, 36, 8, and 29 pounds, respectively. The 89 submarines
producing this discharge are geographically dispersed over seven ports.
There is no potential for the transfer of non-indigenous species.
6.0 DATA SOURCES AND REFERENCES
Process knowledge and sampling of this discharge were used in preparing this NOD
report. Table 4 shows the sources of data used to develop this NOD report. The specific
references cited in the report are shown below.
Specific References
1. Kurz, Rich, NAVSEA 92T251. UNDS Equipment Expert Meeting Structured Questions.
Main Sea Water System Freshwater Layup. September 5,1996.
2. Versar Notes, UNDS Freshwater Layup Sampling Meeting. NAVSEA. May 23,1997.
3. UNDS Phase I Sampling Data Report, Volumes 1 - 13. October 1997.
4. Bredehorst, Kurt, NAVSEA 03L. Materials Within the Seawater Side of Main
Condenser. September 1996. Miller, Robert B, M. Rosenblatt & Son, Inc.
5. Miller, Robert B., M. Rosenblatt & Son, Inc. Personal Communications on Nature of
Discharge Report: Freshwater Layup, Submarine Main Steam Condensers. January
1997.
General References
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
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.
Freshwater Layup
7
-------
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.
i
New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
;i
Virginia, Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
i
UNDS Equipment Expert Meeting Minutes. Seawater Cooling Water Overboard. August 27,
1996.
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
ii
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, pg. 15366. March 23,1995.
Kurz, Rich, NAVSEA 92T251. Submarine Main Steam Condenser Freshwater Layup E-mail.
November 1996. H. Clarkson Meredith, HI, Versar, Inc.
Jane's Fighting Ships, Capt. Richard Sharpe, Ed., Jane's Information Group, Sentinel House:
Surrey, United Kingdom, 1996.
!l
UNDS Ship Database, August 1,1997.
Freshwater Layup
8
-------
Table 1. Summary of Detected Analytes
Constituent .
Classicals *
Alkalinity
Ammonia as Nitrogen
Chemical Oxygen Demand (COD)
Chloride
Nitrate/Nitrite
Sulfate
Total Chlorine
Total Dissolved Solids
Total Kjeldahl Nitrogen
Total Organic Carbon (TOC)
Total Phosphorous
Total Recoverable Oil and Grease
Total Sulfide (lodometric)
Volatile Residue
Metals '-"
Aluminum
Dissolved
Total
Arsenic
Dissolved
Barium
Dissolved
Total
Beryllium
Dissolved
Boron
Dissolved
Total
Calcium
Dissolved
Total
Copper
Dissolved
Total
Lead
Dissolved
Total
Magnesium
Dissolved
Total
Manganese
Dissolved
Total
Nickel
Dissolved
Freshwater
Influent
• (mg/L)
26
0.17
12
20
0.62
21
1.2
140
0.70
2.70
0.22
1.0
6
76
(Hg/L> -
BDL
109
BDL
35.5
36.2
BDL
BDL
BDL
15700
16000
135
136
BDL
2.3
2720
2860
BDL
6.3
BDL
2-Btour
Freshwater
Effluent
(mg/L)
27
1.3
BDL
63
0.68
22.8
0.028
232
0.63
2.7
0.19
BDL
3.0
165
"(vsM
57.7
43.9
0.8
27.5
28.10
BDL
36.8
37.5
17050
16750
137
150
BDL
2.0
6880
6890
19.7
21.8
409
21-Day
Freshwater
Effluent
(mg/L)
46
0.6
48
34
0.4
17
BDL
82
0.81
25
0.19
1.0
BDL
BDL
Oig/L)
BDL
BDL
BDL
25.6
26.3
0.75
BDL
BDL
19800
20400
107
148
3.45
4.75
5185
5495
276
310
1175
Frequency of
Detection
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
•\
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
lofl
•Mass Loading
• (Ibs/yr) '
1,616
41
1,108
2,078
23
861
0.58
6,657
32
633
8.3
23
62
3,388
(Ibs/yr)
1.19
0.90
0.016
1.16
1.19
0.017
0.76
0.77
807
815
5.3
6.5
0.08
0.15
261
268
6.8
7.6
35.6
Freshwater Layup
9
-------
Total
Selenium
Dissolved
Total
Sodium
Dissolved
Total
Thallium
Dissolved
Total
Tin
Dissolved
Total
Zinc
Dissolved
Total
Organics
BSs(2-ethylhexyl) phthalate
BDL
BDL
BDL
10500
10500
BDL
1.3
5.1
4.2
137
127
Otg/L)
137
433
BDL
BDL
39200
37550
&
0.75
BDL
BDL
BDL
463
451
-------
Table 2: Estimated Annual Mass Loadings for Freshwater Layup Discharge
s /
~ , ^Analyte
Annual Volume (gal/yr):
Copper
Dissolved
Total
Nickel
Dissolved
Total
Zinc
Dissolved
Total
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*"
Total Chlorine
Total Phosphorous
2-hr Layup
•Cone. .,
-------
Table 3: Mean Concentrations of Constituents Exceeding Water Quality Criteria
Constituent
Metals (ug/L)
Copper
Dissolved
Total
Nickel
Dissolved
Total
Zinc
Dissolved
Total
Classical (rag/L)
Ammonia as Nitrogen
Nitrate/Nitrite
Total Kjeldahl Nitrogen
Total Nitrogen*
Total Chlorine
Total Phosphorous
2-Hour Layup
Concentration
137
150
409
433
463
451
1.3
0.68
0.63
1.31
0.028
0.19
21-Day Layup
Concentration
107
' 148
1175
1175
784
851
0.6
0.4
0.81
1.21
-
0.19
Federal Acute
woe
2.4
2.9
74
74.6
90
95.1
None
None
None
None
None
None
Most Stringent State
Acute WQC
2.4 (CT, MS)
2.5 (WA)
74 (CA, CT)
8.3 (FL, GA)
90 (CA, CT, MS)
84.6 (WA)
--•"'--. '-.-••- •'• •'•-••-•>-'••:• •'•:•,':
0.006 (ffl)A
0.008 (ffl)A
-
0.2 (HI)A
0.010 (FL)
0.025 (HI)A
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
A - Nutrient criteria are not specified as acute or chronic values.
B - Total Nitrogen is the sum of Nitrate/Nitrite and Total Kjeldahl Nitrogen.
CA = California
CT =• Connecticut
FL = Florida
GA = Georgia
HI «* Hawaii
MS = Mississippi
WA •" Washington
Freshwater Layup
12
-------
Table 4. Data Sources
V
NOD Section
2.1 Equipment Description and
3Operation / - -
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge *
3.1 Locality
3.2 Rate
3,3 Constituents _ - ,
3.4 Concentrations
4.1 Mass Loadings - - -
4.2 Environmental Concentrations
4.3 Potential for Introducing Noa- ''
Indigenous Species
- Data Source * .
Reported
UNDS Database
X
Sampling
X
X
X
Estimated
Equipment Expert
X
X
X
X
X
X
X
Freshwater Layup
13
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-------
NATURE OF DISCHARGE REPORT
Gas Turbine Water Wash
1.0 INTRODUCTION
The National Defense Authorization Act of 1996 amended Section 312 of the Federal
Water Pollution Control Act (also known as the Clean Water Act (CWA)) to require that the
Secretary of Defense and the Administrator of the Environmental Protection Agency (EPA)
develop uniform national discharge standards (UNDS) for vessels of the Armed Forces for
"...discharges, other than sewage, incidental to normal operation of a vessel of the Armed Forces,
..." [Section 312(n)(l)j. UNDS is being developed in three phases. The first phase (which this
report supports), will determine which discharges will be required to be controlled by marine
pollution control devices (MPCDs)—either equipment or management practices. The second
phase will develop MPCD performance standards. The final phase will determine the design,
construction, installation, and use of MPCDs.
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.
Gas Turbine Water Wash
1
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2.0 DISCHARGE DESCRIPTION
This section describes the gas turbine water wash and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
2.1 Equipment Description and Operation
Shipboard gas turbine systems are used on certain vessels to provide propulsion power,
provide initial mechanical starting power for large gas turbine propulsion systems, and to
generate electricity. Power is generated by combusting fuel in a "gas generator" (commonly
referred to as a "combustor"). The combustor exhaust gas rotates the "power turbine," providing
the mechanical energy to either drive a propulsion shaft, start a larger turbine, or generate
electricity.1
Over extended periods of operation, residual lubrication oil and hydrocarbon combustion
by-product deposits can form on gas turbine internals. Since naval vessels operate in a marine
environment, salt water introduced with intake air can also lead to salt deposits on the gas turbine
internals. Washing the gas turbine internals periodically with a solution of freshwater and
cleaning compound maintains operating efficiency and prevents corrosion of the metallic
components. The cleaning compound that is currently used for this purpose is a petroleum-based
solvent referred to as "gas path cleaner."1
Two types of water wash systems exist on vessels with gas turbines. One is a dedicated
"hard-piped" system; the other type requires manual attachment of a hose to a hot water source
and placement of the other hose end into the turbine plenum. Both of these systems are designed
to introduce water wash into the turbine housing while the turbine starter motor is slowly rotated,
(i.e., cranked without combustion). The hard-piped system includes a rinse tank where
distilled/demineralized water and cleaning compound are mixed. The contents of the tank are
sprayed into the gas turbine under pressure, either by using a pump or by pressurizing the tank
with compressed air.1 Immediately following the wash, the engine is sprayed with water.
i|
Gas turbine engines are enclosed in a "module" with floor drains designed to remove
minor leakage of fuel and synthetic lube oil that may occur during normal turbine operation. The
floor drains also remove any water wash introduced into the turbine that is not discharged to the
atmosphere. Water wash from external scrubbing of the gas turbine also flows to these floor
drains. Inadvertent spills of synthetic lube oil that occasionally occur during turbine maintenance
activities are potentially capable of entering the drains; however, standard procedure is for ship
personnel to immediately contain and wipe up any spillage that occurs.1
i
On most Navy ships, gas turbine water wash effluent and any drainage of residual
material from leaks and spills are collected and held in a dedicated tank system for shore
disposal. The Navy refers to this system as the "Gas Turbine Waste Drain Collecting System."
The dedicated system includes a centrifugal pump and piping to transfer the water wash to a hose
connection topside. A hose is used to transfer the water wash to a pierside collection facility. On
Gas Turbine Water Wash
2
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vessels without this system, the drainage is discharged to the environment as a component of
other UNDS discharges (i.e., Surface Vessel Bilgewater/OWS, Welldeck, and Deck Runoff).1
The wash water effluent discharge from U.S. Coast Guard (USCG) vessel gas turbine
washing operations is to the bilge, from where it is processed as bilgewater (along with other
bilgewater contributors) through the shipboard OWS prior to overboard discharge. The gas
turbine water wash effluent for USCG vessels is addressed as a component of the Surface Vessel
Bilgewater/OWS Discharge NOD Report.
Gas turbine propulsion engines are also used aboard Navy landing craft air cushion
(LCAC) amphibious landing crafts. Two gas turbine auxiliary power units (APUs) are also
installed on LCACs to provide starter air. The LCAC gas turbine washwater discharge is
addressed as a component of the Welldeck Discharges NOD Report.
Water wash cleaning of aircraft gas turbine engines aboard an aircraft carrier is addressed
as a component of the Deck Runoff NOD Report.
2.2 Releases to the Environment
The water wash introduced into Navy propulsion turbines contains water and solvent-
based gas path cleaner. The discharge could be expected to contain components of the cleaner,
oil and grease (O&G), petroleum-derived fuel and lubricant constituents, synthetic lubricating
oil, constituents introduced into the turbine system with the incoming sea air, hydrocarbon
combustion by-products, and metals leached from gas turbine components. On most gas turbine
Navy and MSC ships, gas turbine washwater is collected in a dedicated tank and not discharged
overboard within 12 n.m. On ships without a dedicated collecting tank, this discharge is a
component of deck Runoff, welldeck runoff, or bilgewater as described in the previous section.
2.3 Vessels Producing the Discharge
Table 1 lists the vessel classes that have shipboard gas turbine systems. Vessel classes
equipped with a Gas Turbine Waste Drain Collecting System are denoted in Table 1. For the
other vessel classes listed in Table 1, the gas turbine water wash is discharged as a component of
another UNDS discharge. The maximum number of vessels with Gas Turbine Waste Drain
Collecting System is 127. Army and Air Force vessels do not have gas turbine engines and do
not generate this discharge.
3.0 DISCHARGE CHARACTERISTICS
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.
Gas Turbine Water Wash
3
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3.1 Locality
Vessels with Gas Turbine Waste Drain Collecting Systems collect and store drainage
from normal turbine operations and water wash effluent for pierside disposal. On most gas
turbine Navy and MSC ships, gas turbine washwater is collected in a dedicated collecting tank
and not discharged overboard within 12 n.m. On ships without a dedicated collecting tank, this
discharge is a component of deck Runoff, welldeck runoff, or bilgewater as described in the
previous section.
3.2 Rate
I
I
Available information on gas turbine water wash usage rates is contained in gas turbine
IJI o •j A
design and operations and maintenance documentation. '' The frequency of water wash
cleanings and the quantity of water wash consumed per washing event is different between
USCG, Navy, and Military Sealift Command (MSC) vessels.
Navy and MSC vessel gas turbines used for propulsion are washed after each 48 hours of
operation or at least once per month.5 Two gallons of the gas path cleaner are initially mixed
with 38 gallons of distilled/demineralized water. Immediately following the wash, the turbine is
spray rinsed with 80 gallons of water. An additional 2 gallons of detergent/water mixture is used
to clean external turbine surfaces, as necessary. Each cleaning of the propulsion turbines
produces 122 gallons of water wash. Therefore a vessel with four propulsion gas turbines each
cleaned once every 48 hours of operation would generate an average of 244 gallons of water
wash per day.
3.3 Constituents
The chemicals used in gas turbine operation and maintenance that could potentially
contribute to contamination of turbine water wash are gas path cleaner, Naval distillate fuel F-76,
gas turbine fuel, JP-5, synthetic lube oil, copper, cadmium, and nickel.
6-10
The gas path cleaners used by the Navy include petroleum distillates (aromatic and
aliphatic hydrocarbons), assorted glycols, detergents, soaps, and water.6'7 The composition of
one such cleaner used by the Navy can be found hi its material safety data sheet (MSDS).6
According to the MSDS sheet, the cleaner can contain the aromatic hydrocarbon naphthalene at
concentrations of up to 3.9%. Other petroleum distillate hydrocarbon constituents that could be
present include aliphatic volatile organic compounds and other semivolatile compounds that are
priority pollutants. The priority pollutants that are potential constituents of gas turbine water
wash are cadmium, copper, nickel, and naphthalene. None of the constituents is a
bioaccumulator.
3.4 Concentrations
I
The addition of gas path cleaner containing 3.9% naphthalene to the wash water at a 2%
gas path cleaner concentration yields an estimated water wash naphthalene concentration of 800
Gas Turbine Water Wash
4
-------
milligrams per liter (mg/L). The following shows this calculation.
-' ,, > Naphthalene Concentration (mg/L) ==?
(% of cleaner in water)(% of naphthalene in cleaner)(density of naphthalene)
.where, " • .,"",' -v-; '• ,«-'/,'>,-_ ;- , : - '" -
% of cleaner in water = 2 ^ ,, ' I,' k?- '-**, - ' ,, -• " ^ x
% of naphthalene in cleaner=3.9 / '•• : ,''"••>„ -* -., ' -, ~
density_of naphthalene = (1.0253 g/cm3)(1000 mg/g)(iOOO cm3/L) = 1.025 * LO6 mg/L
Naphthalene Concentration = (0702X0.039X1.025 * 106) « 800 mg/L
Because naphthalene is a semivolatile organic compound that is not expected to volatilize
while the water wash is sprayed into the turbine, the maximum water wash effluent naphthalene
concentration is also estimated at 800 mg/L. Other constituents are variable and were not
estimated.
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. hi Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
4.1 Mass Loadings
The water wash volume estimate for a Navy ship propulsion turbine cleaning operation
and naphthalene concentration estimate of 800 mg/L were used to estimate the maximum annual
mass loading. The estimate is based on the assumption that one turbine cleaning for each vessel
is performed each day within 12 n.m.
Mass Loading of Naphthalene (Ibs/yr) ==
(naphthalene conc.)(discharge vol.)(365days/yr)(# vessels) (3.7854 L/gal) (2.2 Ib/kg) (10"6 kg/mg) -
(800 mg/L)(244 gal/day)(365 days/yr)(127)(3.7854 L/gal)(2.2 lb/kg)(10 kg/mg) « 75,400 Ibs/yr
The mass loading of O&G that can be introduced into the water wash effluent from
within the gas turbine depends on (a) the amount of residue present; and (b) the degree to which
the water wash spray removes the residue as it passes through the turbine.
4.2 Environmental Concentrations
Gas Turbine Water Wash
5
-------
Table 2 shows that the estimated naphthalene concentration exceeds the most stringent
state water quality criteria (WQC) for naphthalene. Concentrations of oil and grease are
expected to exceed WQC because the source of this discharge (gas turbine cleaning) is designed
to dissolve fuel, lubricant, and other hydrocarbon deposits.
4.3 Potential for Introducing Non-Indigenous Species
There is no potential of introduction, transport, or release of non-indigenous species
between different geographical areas, because the water wash system does not use seawater and
therefore does not involve the discharge of seawater originating hi another geographical region.
5.0 CONCLUSIONS
If discharged, gas turbine water wash has the potential to cause an adverse environmental
effect within 12 n.m. because:
1) Estimated concentrations of naphthalene exceed and the most stringent state WQC
and the mass loading of this priority pollutant would be significant; and
2) Concentrations of oil and grease are expected to be significant because the source of
this discharge (gas turbine cleaning) is designed to dissolve fuel, lubricants and other
deposits.
6.0 DATA SOURCES AND REFERENCES
To characterize this discharge, information from the following sources was obtained to
develop this NOD report. Table 3 shows the sources of data used to develop this NOD report.
Specific References
1. UNDS Equipment Expert Meeting Minutes. June, 20,1997.
2. Uniform Maintenance Procedure Card (MFC), WAGE 400 Main Gas Turbine, MPC M-
C-062, Amendment 3.
3. Uniform Maintenance Procedure Card (MPC), WHEC 378 Main Gas Turbine, MPC M-
C-017, Amendment 0.
4. Uniform Maintenance Procedure Card (MPC), WHEC 378 Emergency Generator, MPC
A-W-001, Amendment 0.
5. Maintenance Requirement Card (MRC), OPNAV 4790 (Rev. 2-82).
Gas Turbine Water Wash
6
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6. Gas Path Cleaner Material Safety Data Sheet, supplied by M. Galecki of DDG 51 Flight
Upgrade Office via facsimile to Malcolm Pirnie (C. Geiling) on June 12,1997.
7. Military Specification MIL-C-85704, "Cleaning Compound, Turbine Engine Gas Path".
8 Military Specification MDL-F-16884, "Fuel, Naval Distillate".
9. Military Specification MIL-F-5624, "Turbine Fuel, Aviation, Grades JP-4, JP-5, and JP-
5/JP-8 ST".
10. Military Specification MIL-L-23699, "Lubricating Oil, Aircraft Turbine Engine,
Synthetic Base, NATO Code Number 0-156".
General References
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4,1995.
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
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
Gas Turbine Water Wash
7
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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.
i
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC), 9 VAC
25-260.
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register,?. 15366. March23,1995.
Gas Turbine Water Wash
8
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Table 1. Vessels With Gas Turbine Systems
Branch
Navy
MSC
USCG
Class
AOE6
CG47
DD963
DDG51
DDG 993
FFG7
MCM1
T-AKR310
WAGE 399
WHEC378
No.'
3
27
31
18
4
43
14
1
2
12
.Vessel Type
Fast Combat Support Ship
Guided Missile Cruiser
Destroyer
Guided Missile Destroyer
Guided Missile Destroyer
Guided Missile Frigate
Mine Countermeasure Vessel
Fast Sealift Ship
Icebreaker
High Endurance Cutter
Comment
Dedicated collection system
Dedicated collection system
Dedicated collection system
Dedicated collection system
Dedicated collection system
Dedicated collection system
Unknown configuration
Dedicated collection system
Discharged to bilge
Discharged to bilge
No. = number of vessels in class
Table 2. Comparison of Gas Turbine Water Wash
Estimated Concentration and Water Quality Criteria (jig/L)
Constituent
Naphthalene
Maximum Estimated -
\ Concentration
800,000
Federal Acute
WQC ' _:
None
Most Stringent State.
Acute WQC
780 (HI)
Notes:
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.
HI = Hawaii
Table 3. Data Sources
NOD Section
2.1 Equipment Description and
Operation
2,2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate
3.3 Constituents
3.4 Concentrations
4.1 Mass Loadings
4.2 Environmental Concentrations
4.3 Potential for Introducing Non-
Indigenous Species
• - Data Source
Reported
Equipment Literature
OPNAVINST5090.1B
UNDS Database
Standard Operating
Procedures
MSDS
MSDS
Sampling
Estimated
X
X
X
X
X
Equipment Expert
X
X
X
X
X
X
X
Gas Turbine Water Wash
9
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-------
NATURE OF DISCHARGE REPORT
, „''/; Graywater
1.0 INTRODUCTION
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.
Graywater
1
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2.0 DISCHARGE DESCRIPTION
This section describes the graywater discharge and includes information on: the
equipment that is used and its operation (Section 2.1), general description of the constituents of
the discharge (Section 2.2), and the vessels that produce this discharge (Section 2.3).
!
2.1 Equipment Description and Operation
ij
Graywater is defined in section 312(a) of the Clean Water Act as wastewater from
showers, baths and galleys. On vessels of the Armed Forces, drainage from laundry, interior
deck drains, lavatory sinks, water fountains, and miscellaneous shop sinks is often collected
together with graywater. Therefore, this discharge covers graywater as well as mixtures of
graywater with wastewater from these additional sources.1 In this report, the term "graywater"
will be used to describe all of these related discharges. Graywater is distinct from "blackwater",
the sewage generated by toilets and urinals.
While pierside, most classes of Navy vessels direct graywater to the vessel's blackwater
Collection, Holding, and Transfer (CHT) tanks, via segregated graywater plumbing drains. Some
recently built ships (such as CVN 73 and CVN 74) do not have segregated blackwater/graywater
drains. These ships collect the blackwater/graywater mixture while inside 3 nautical miles
(n.m.). The blackwater and graywater mixture is then pumped to pierside connections for
treatment ashore. A typical CHT system is shown in Figure 1. Most navy surface vessels
without CHT systems have dedicated graywater tanks and pumps to collect and transfer this
discharge to shore facilities. Some vessels lack the means to collect all the graywater that is
generated while pierside. On these vessels a portion of the graywater plumbing drains run
directly overboard.1"4
I
While operating away from the pier, most Navy surface vessels that collect graywater in
CHT tanks divert graywater drains overboard to preserve holding capacity for blackwater in the
tanks. Vessels equipped with separate graywater collection and transfer systems are not designed
to hold graywater for extended periods of time and therefore drain or pump their graywater
overboard while operating away from the pier.
Submarines collect their graywater in the ship's sanitary tank while pierside and within 3
n.m. of land. Pierside, graywater mixed with blackwater is discharged to a shore facility for
treatment; when outside 3 n.m., graywater is discharged directly overboard. Unlike surface
vessels, holding capacity in the submarines' sanitary tanks is generally sufficient to allow
collection of graywater and blackwater up to 12 n.m. from shore.1
i
All Military Sealift Command (MSC) vessels are equipped with U.S. Coast Guard
(USCG) certified Marine Sanitation Devices (MSDs) designed to treat sewage to EPA and
USCG standards. On some MSC vessels, graywater can be collected and sent to the MSD for
processing, or diverted overboard. On other MSC vessels, graywater is neither collected nor
treated, but is discharged directly overboard.
Graywater
2
-------
Most USCG vessels are similar to Navy vessels since they can collect graywater while
pierside. However, some USCG vessels currently cannot collect graywater, but continually
discharge it overboard.
The majority of Army vessels collect graywater together with blackwater (sewage)* for
treatment by a USCG certified MSD. The MSD effluent is either sent overboard, held in an
effluent holding tank, or discharged to a shore facility.
2.2 Releases to the Environment
Contributions to graywater are described below. Three sources comprise the majority of
graywater flow: Galley and scullery (18% in port, 22% at sea); laundry (22% in port, 33% at
sea); and showers and sinks (60% in port and 45% at sea).5 In addition, other minor sources
include: filter cleaning discharges, deck drains, and medical/dental waste discharges.1
2.2.1 Galley
Food preparation occurs in a vessel's galley. Large Navy vessels have several galley
compartments. In smaller vessels, the galley can be a shared space with related functions (e.g.,
the scullery), and have a single sink through which wastewater is discharged. Galley discharges
specifically exclude food/garbage grinder wastes. Garbage grinders are required to be secured
inside 3 n.m.6
Wastewater from the galley is generated through food preparation, disposal of cooking
liquids, and cleaning of surfaces (bulkheads, appliances, sinks, and working surfaces). The
generation and discharge are periodic, with the majority of the flow occurring during the hours
preceding meal times. Galley graywater can contain highly biodegradable organics, oil and
grease, and detergent residuals.
2.2.2 Scullery
The scullery can be separate from or integral with the galley and is used for the cleaning
of dishes and cookware. Scullery wastewater also specifically excludes garbage grinder wastes,
as garbage grinders are required to be secured inside 3 run.6 Scullery graywater can contain food
residuals and detergents.
2.2.3 Showers and Lavatory Sinks
Lavatory sinks and showers drain to the vessel's graywater system and can contain soap
residues, shampoos, shaving cream, and other products resulting from personal hygiene.
Detergent residuals similar to those used in the galley can also be present.
2.2.4 Laundry
* The Army usually refers to bilgewater as "blackwater" and sewage as "sewage".
Graywater
3
-------
Graywater derived from laundering crew uniforms, linens, and other articles of clothing
can contain laundry detergents, bleaches, oils and greases, and traces of other constituents.
Detergent residuals similar to those used in the galley, lavatory sinks, and showers can also be
present.
2.2.5 Other Discharges
I
Other minor discharges which are collected with graywater include filter cleaning
discharges, deck drains, and medical/dental waste discharges. These discharges combined
represent less than 1% of the total shipboard generated graywater.5 Filter cleaning discharges
consist of detergents and small amounts of oil from commercial dishwashing machines or sinks
used to wash ship ventilation system air filters. Deck drains contribute small and intermittent
flows which can include detergents used for floor cleaning and other general space cleaning.
Small amounts of medical/dental wastes are collected with graywater on only a few Navy ships
with extensive medical and dental facilities such as aircraft carriers (CV/CVNs) and amphibious
assault ships (LHD/LHA/LPHs). This would include wastes from dental spit sinks and small
blood samples less than 7.5 milliliters (mL).7
2.3 Vessels Producing the Discharge
Vessels in the Navy, MSC, Army, Air Force, and USCG generate graywater. However,
there are some vessels that do not produce a separate and distinct graywater discharge. These are
the vessels not equipped with segregated graywater collection systems. Instead, they collect
graywater together with blackwater for combined treatment with a MSD.
3.0 DISCHARGE CHARACTERISTICS
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
Discharges of graywater incidental to normal operations occur under three circumstances:
(1) at the pier, for the ship classes lacking the means to collect graywater for shore treatment; (2)
between 0 and 3 n.m. for most Navy and USCG vessels and for some MSC vessels; and (3)
outside 3 n.m., where most graywater is discharged overboard.
3.2 Rate
The Navy uses a design figure of 30 gallons per capita-day (gal/cap/day) when designing
graywater collections systems.8
Graywater
4
-------
Table 1 presents estimates of discharge rates by vessel class for Navy, MSC, USCG, and
Army ships. The following assumptions are inherent in the table:
With the few exceptions noted in Section 2.1 and 2.3, vessels discharge graywater overboard
at all times when not pierside. It is assumed, for purposes of calculation, that USCG, MSC,
and Army vessels also discharge graywater overboard at all times when not pierside.
A typical vessel is estimated to require about four hours to transit 12 n.m. from shore, with a
per capita average rate of 1.25 gallons/hour (30 gal/cap/day). If this vessel undergoes 20
transits a year and has a crew size of 400, the annual graywater discharge rate while in transit
would be:
t ' s ' s *• « ^ v
(20 transits/year) (4*hours/transit) (L25 gal/capita-hour) (400 personnel) — 40,000 gallons/year
Some vessels of the USCG and Army operate on a routine basis within 12 n.m. of shore.
Annual graywater discharge rate calculations for these vessels are based, in part, on the number
of days each ship operates within 12 n.m. A vessel's graywater discharge that results from
operating within 12 n.m. is calculated by using the following general formula:
(personnel) (hours in operation/year) (L25gaUcapitd-Mowr) — gallons/year
USCG vessels that operate within 12 n.m. include: Mackinaw Class Icebreakers (approx.
150 days/year, 24 hours/day), Bay Class Icebreaking Tugs (approx. 150 days/year, 24 hours/day),
and Balsam Class Seagoing Buoy Tenders (approx. 100 days/year, 24/hours/day). Army vessels
that operate within 12 n.m. include: Logistic Support Vessels (approx. 30 days/year, 10
hours/day) and Landing Craft Utility (approx. 60 days/year, 10 hours/day). Due to the fact that
the majority of Army vessels collect most of their graywater with blackwater, approximately only
10% of the graywater generated is discharged separately.9
As shown in Table 1, the total estimated amount of graywater discharged overboard
annually inside 12 n.m. is 39 million gallons. Of that volume, 15.3 million gallons are
discharged pierside.
3.3 Constituents
hi graywater, soaps, shampoos, detergents, and cleaners contribute organics as well as
inorganic compounds such as nitrogen and phosphorous. Food waste will contribute oxygen
demand (as measured by Biochemical Oxygen Demand (BOD) and Chemical Oxygen Demand
(COD)), nutrients, and oil and grease. Metals, pesticides, and organics from adhesives, sealants,
lubricants, and cleaners can also be present in graywater. The constituents that have been
measured in previous graywater studies are shown in Tables 2 and 3. The priority pollutants
Graywater
5
-------
cadmium, chromium, copper, lead, nickel, silver, and zinc were identified. Mercury, a
bioaccumulator, was also identified. It is possible that certain parameters not tested for, and thus
not listed in Tables 2 and 3, could also be present in graywater.
,i
]
3.4 Concentrations
Table 2 shows the average values measured for classical water quality parameters in
various shipboard streams that contribute to graywater based on samples collected from three
classes of vessels. Data are shown for the following graywater discharge components: wash
basins and showers, food preparation, laundry, and dishwasher and deep sink. The ranges of the
average measured values are: pH (6.74 -10), total suspended solids (TSS)(94 - 4,695 milligrams
per liter (mg/L)), total dissolved solids (TDS)(225 - 8,064 mg/L), BOD (144 - 2618 mg/L), COD
(304 - 7,839 mg/L), total organic carbon (TOC)(59 - 1,133 mg/L), oil and grease (5 -1,210
mg/L), methylene blue active substances (MBAS) (0.1 - 4.1 mg/L), ammonia nitrogen (0.17 -
669 mg/L), phosphate (1.03 - 28.2 mg/L), and coliform bacteria (178 - >2,000,000 per 100 mL).
Flow-weighted average concentrations of these constituents are calculated in Table 2, based upon
the data presented therein and the relative contribution of the three major sources of graywater.
I
Table 3 shows the mean concentrations of metals in various graywater components based
on samples collected from three classes of vessels. Data are shown for the following graywater
components: potable water sink, galley drams, sink, and scullery. The ranges of the average
measured values are: silver (.007 - 0.012 mg/L), cadmium (0.004 - 0.017 mg/L), chromium
(0.002 - 0.03 mg/L), copper (0.25 - 3.4 mg/L), lead (0.042 - 1.56 mg/L), mercury (.0002 - .0095
mg/L), nickel (0.025 - 0.113 mg/L), and zinc (0.19 - 2.36 mg/L). Flow-weighted average
concentrations of these metals are calculated in Table 3, based upon the data presented therein
and the relative contribution of graywater sources involved.
4.0 NATURE OF DISCHARGE ANALYSIS
Based on the discharge characteristics presented hi Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented hi Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria, hi
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
4.1 Mass Loadings
Total flow, and therefore mass loadings, are influenced by the number of personnel
aboard, tune spent hi transit, and time spent operating within 12 n.m. Total loadings can be
estimated by multiplying concentration data by the total annual flow of graywater. Based on
typical constituent concentrations and the estimated total flow calculated in Table 1, annual
loadings of constituents are presented hi Table 4.
4.2 Environmental Concentrations
Graywater
6
-------
Screening for constituents was accomplished by comparing measured levels of
constituents to the lowest applicable water quality criteria. For graywater, the only constituents
for which both data and water quality criteria are available are metals. Parameters such as BOD
and nutrients are at levels that would be expected to cause localized adverse environmental
effects.
As shown in Table 5, concentrations of the priority pollutants copper, lead, nickel, silver,
and zinc (measured as total metals), in one or more graywater components, exceed the most
stringent water quality criteria. The bioaccumulator, mercury, exceeds the most stringent water
quality criteria. Ammonia also exceeds the most stringent water quality criteria.
4.3 Potential for Introducing Non-Indigenous Species
Graywater originates from potable water rather than seawater. Therefore, the potential
for introduction of non-indigenous species is not significant.
5.0 CONCLUSIONS
Graywater has the potential to cause adverse environmental effects because measured
concentrations and estimated loadings of nutrients and oxygen-demanding substances are
significant.
6.0 DATA SOURCES AND REFERENCES
To characterize this discharge, information from various sources was obtained. Process
information and assumptions were used to estimate the rate of discharge. Based on this estimate
and on the reported concentrations of constituents, the mass loadings to the environment
resulting from this discharge were then estimated. Table 6 shows the source of the data used to
develop this NOD report.
Specific References
1. UNDS Equipment Expert Meeting Minutes - Graywater Discharge. 29 July 1996.
2. Aivalotis, Joyce, USCG. Personal Communication: USCG Photo Labs/Film Processing
and X-ray Capabilities, 14 April 1997, David Eaton, M. Rosenblatt & Son, Inc.
3. Aivalotis, Joyce, USCG. Personal Communication: USCG Ship Description for
Medical/Dental Waste Discharge, 14 April 1997, David Eaton, M. Rosenblatt & Son, Inc.
4. Cassidy, Brian. "Zero Discharge Study." February 1996.
Graywater
7
-------
5.
6.
7.
8.
9.
10.
11.
Whelan,Mary. "Graywater Characterization." TM-28-89-01. March
1989.
Naval Ship's Technical Manual (NSTM), Chapter 593, Pollution Control (Revision 3),
page 2-2. 1 September 1991.
UNDS Equipment Expert Meeting Minutes - Medical/Dental Waste Discharges. 15
October 1996.
NAVSEA Design Practices and Criteria Manual for Surface Ship Freshwater Systems,
Chapter 532. NAVSEA T9500-AA-PRO-120. October 1987.
I
I
SSG Huckabee, U.S. Army 7th Transportation Group, Fort Eustis. Personal
Communication: Information on Army Vessels' Graywater Discharge, 16 March 1998,
Russell Fisher, Booz, Allen & Hamilton.
UNDS Ship Database, August 1,1997.
Pentagon Ship Movement Data for Years 1991 - 1995, Dated March 4, 1997.
12. Tails, A. and D. R. Decker. Naval Ship Research and Development Center. "Nonoily
Aqueous Waste Streams on the USS Sierra (AD18), Volume 1." Bethesda, Maryland.
Report 4182, April 1974.
13. Naval Ship Research and Development Center. "Nonoily Aqueous Waste Streams on
USS Seattle (AOE 3), Volume I." Bethesda, Maryland. Report 4192, June 1974.
j
14. Van Hees, W., D. R. Decker, and A. Talts. Naval Ship Research and Development
Center. "Nonoily Aqueous Waste Streams on USS O'Hare (DD 889), Volume I."
Bethesda, Maryland. Report 4193, June 1974.
15. Attachment to Letter, Commander, Carderock Division, Naval Surface Warfare Center,
Philadelphia, PA., 9593 Ser 6222/291, December 6,1993, "Investigation of Metals From
Industrial Processes, Intake Waters & Pipe Corrosion Onboard U.S. Navy Vessels at
Norfolk Naval Base, Norfolk, VA.," November 22 1993.
i
General References
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
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.
Graywater
8
-------
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 (WAC).
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
Graywater
9
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o
o
fli
^
.a
oo
0
o
o
o
o
o
ts
T— 1
o
o"
^H
T^^
o
CJ
oo
§
o
0)
o
o
r--
o
t-l
-H
\o
es
o
o
CO
o
CO
CO
CN
o\
o
1
03
I
O
rs/s
sinl
-------
Table 4. Mass Loadings of Constituents*
Parameter
Copper
Lead
Mercury
Nickel
Silver
Zinc
TSS
BOD
COD
Oil and Grease
MBAS
N-Ammonia
N-NO3
N-Kjeldahl
P- Phosphate
Flow-Weighted Average
Concentration (mg/L)
0.936
0.247
0.0013
0.042
0.008
0.501
802
540
1443
164
1.1
102
3.2
140
6.5
Loading (Ifo/yr.)
:.- "• ' '- ••'/' . ,-
304
80.3
.423
13.7
2.60
163
260,900
175,600
469,400
53,340
358
33,180
1,040
45,540
2110
* Based on flow-weighted average constituent concentrations. See Tables 2 and 3
Graywater
14
-------
Table 5. Comparison of Graywater Concentration Data Versus Acute Water Quality
Criteria
/ Parameter
Ammonia
Copper
Lead
Mercury**
Nickel
Silver
Zinc
Concentration*
102
3,404
1,559
9.5
113
12
2,363
Federal Acute
WQC
None
2.4
210
1.8
74
1.9
90
^Most Stringent State Acute
WQC (State)
6(HI)A
2.4 (CT, MS)
5.6 (FL, GA)
0.025 (FL, GA)
8.3 (FL, GA)
1.2 (WA)
84.6 (WA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
Where historical data were not reported as dissolved or total, the metals concentrations were compared to the most
stringent (dissolved or total) state water quality criteria.
A - Nutrient criteria are not specified as acute or chronic values.
CT = Connecticut
FL = Florida
GA = Georgia
MS = Mississippi
WA = Washington
(*) Highest concentration for any individual component from Table 3.
(**) Bioaccumulator
Table 6. Data Sources
. NOD Section
2.1 Equipment Description and
Operatioa
2.2 Releases to the Environment
2.3 Vessels Producing the Discharge
3.1 Locality
3.2 Rate „ ,
33 Constituents
3.4 Concentrations
4.1 Mass Loadings
4;2 Environmental Concentrations
r4.3 Potential for fotroducingNon- .
Indigenous Species
Data Source '
Reported
UNDS Database
Data call
responses
X
X
Sampling
Estimated
X
X
X
Equipment Expert
X
X
X
X
X
Graywater
15
-------
In Port
Blackwater and Graywater to Tank, Discharge to Pier
TO PIER
OVBD-* O 4 *•
•~*=rr*m
0-3 n.m. from shore
Blackwater to Tank, Graywater Overboard
Beyond 3 n.m. from shore
Blackwater Overboard, Graywater Overboard
GRAYWATER
BLACKWATER
COMBINED GRAYWATER
AND BLACKWATER
DIVERTER VALVE
Figure 1. A Typical Collection, Holding, and Transfer System
Graywater
16
-------
NATURE OF DISCHARGE REPORT
Hull Coating Leachate
1.0 INTRODUCTION
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.
Hull Coating Leachate
1
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2.0 DISCHARGE DESCRIPTION
This section describes the hull coating leachate discharge and includes information on the
coating systems used and how they function (Section 2.1), a general description of the
constituents of the discharge (Section 2.2), and the vessels that produce this discharge (Section
2.3).
2.1 System Description and Operation
I
Underwater hull coating systems typically include a base anticorrosive (AC) coating
covered by an antifouling (AF) coating. The function of the AC coat, in conjunction with
cathodic protection (described in the Cathodic Protection NOD report), is to prevent hull
corrosion. The AC coat also provides bonding between the hull and the AF topcoats. Since the
AC coating is not exposed directly to the seawater, unless the AF coating has been damaged, the
AC coatings do not leach. The AF topcoat inhibits the development of marine growth on the
hull. Marine fouling is undesirable because it increases drag and fuel consumption, while
decreasing vessel speed.1
ii
2.1.1 Types of AF Topcoats
:i
Several different types of AF topcoats, qualified to MIL-PRF-24647 or MEL-P-15931, are
used on the hulls of the Armed Forces vessels.2'3 Within MIL-PRF-24647, they are categorized
by:
• action;
• type of substrate;
• volatile organic compound (VOC) content of the coating; and
• service life requirement and color.
ii
Action - The coating may work through ablative (Type I) or nonablative (Type IT) action.
An ablative coating thins as it erodes or dissolves. Through this action, a fresh layer of
antifouling agent (e.g., copper) is exposed, maintaining the antifouling properties of the paint.
Type n nonablative AF coatings do not thin during service. Some of these coatings function by
leaching metals that prevent marine fouling.1
Type of Substrate - Most hulls of major vessels in the Armed Forces are steel. Hulls of
smaller vessels and some specialty vessels (e.g., minesweepers and minehunters) are often
constructed of alternate materials such as aluminum, fiberglass sheathing, glass reinforced plastic
(GRP), rubber, or wood. The coating system applied will vary with the hull material. For
instance, steel, fiberglass, GRP, and wood hulls are typically coated with copper-based coatings,
and aluminum hulls with tributyltin (TBT) or biocide-free silicone-based coatings.1'4 Rubber
craft are left unpainted and, therefore, do not contribute to this discharge.
Hull Coating Leachate
2
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VOC Content - Coalings are classified into four grades based on their maximum VOC
content. The upper limits for each grade are 3.4 pounds per gallon (Ibs/gal), 2.8 Ibs/gal, 2.3
Ibs/gal, and zero Ibs/gal.2
Service Life Requirement and Color - Coatings are also classified based on the desired
service life of the coating system and their color. A vessel's coating system may have a five-,
seven-, or ten-year service life. Vessels also may use either red, black, or gray coatings (and
white on some smaller craft). Therefore, there are a number of different coating combinations,
based on service life and color.1
2.2 Releases to the Environment
AF topcoats control biological growth by ablating and/or releasing antifouling agents into
the surrounding water. This release is gradual and continuous. The release rate depends on the
type of paint, water temperature, vessel speed, frequency of vessel movement in and out of port,
and coating age. The type of material released is dependent on the type of topcoat employed.
Most hulls use copper-based coatings; therefore, copper and zinc (another biocide commonly
found in antifouling paints) are the most common releases. Those aluminum-hulled vessels with
TBT-containing coatings will release TBT and small amounts of zinc, and may release copper,
depending on the TBT coating formulation.l
2.3 Vessels Producing the Discharge
Most vessels of the Armed Forces use AC paints or AC/AF coating systems. Selected
boats and craft may not be coated with AF paint if they spend most of their time out of the water.
The Navy, Military Sealift Command (MSC) and United States Coast Guard (USCG) use paint
systems qualified to MIL-PRF-24647. The Army uses paint systems with AF topcoats qualified
to MIL-P-15931. Additional guidance for Navy vessels is contained in Naval Ships' Technical
Manual (NSTM) Chapter 631.5'6 It should be noted that paint types and applications vary for
each vessel, depending on where the vessels are docked and the port in which they are painted,
which influences paint availability.
2.3.1 Copper-Based Coatings
Most Navy, MSC, USCG, and Army ships have steel hulls with copper-based AF
coatings. The Navy ships that do not have steel hulls are the mine countermeasure vessels
(MCM 1 and MHC 51 Classes), consisting of 26 ships. MCM 1 Class vessels have wood hulls
sheathed with fiberglass and MHC 51 Class vessels have GRP hulls.7 However, these vessels are
still protected with AC coats and copper ablative AF paints similar to those applied to steel
vessels.1
MSC vessels use two types of Navy-approved copper-based AF paints, ablative and
nonablative. Approved MSC underwater hull coatings are listed in MSC Instruction 4750.2C.8
The USCG utilizes Navy-approved hull coating systems qualified to MIL-PRF-24647, as listed
in the USCG Coatings and Color Manual.9 The Air Force uses copper ablative paints similar to
Hull Coating Leachate
3
-------
those used by the Navy. AF topcoats used on Army watercraft are qualified to MIL-P-15931,
as listed in Department of the Army Technical Bulletin TB 43-0144.3
j
2.3.2 TBT-Based Coatings
i
The predominant use of TBT-based coatings in the Armed Forces has been on aluminum-
hulled vessels. Copper-based AF paints can accelerate the rate at which aluminum hulls corrode,
especially if defects or damage to the AC coating are present. Currently, all Navy ships with
aluminum hulls (i.e., hydrofoils) have been decommissioned.1 However, the Navy does have
approximately 280 small boats and craft with aluminum hulls. Approximately 10-20% of the
aluminum-hulled small boats and craft in the Navy (28-56 vessels; e.g., special warfare patrol
craft) could still have TBT-based hull coatings.11 The USCG estimates that 50 aluminum-hulled
small boats and craft are coated with AF paint containing TBT.12 The MSC has no vessels with
aluminum hulls.13 The Air Force has six large vessels with aluminum hulls, the MR Class
missile retrievers. These vessels are coated with TBT-free, copper-based coatings.7'10 The Air
Force also has approximately 50 small craft that may have TBT-containing coatings. The Army
has approximately 11 small boats and craft that may have TBT coatings.13 The numbers of
vessels from the respective Armed Forces branches estimated to have TBT coatings are listed
below.
Navy - 56
USCG-50
MSC-0
Air Force - 50
Army- 11
3.0 DISCHARGE CHARACTERISTICS
This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists
the discharge, and Section 3.4 gives the concentrations of the constituents in the
3.1 Locality
harbors and near-
constituents in
discharge.
the i
This discharge occurs within harbors, rivers, and coastal waters from every surface vessel
and submarine, as well as most boats and craft. This discharge is continuous and will occur any
time a painted vessel is waterborne.
i
3.2 Rate
This discharge is not a flow; rather, it is the release of AF agents from hull coatings into
the surrounding water. This rate of release, which is the combined effect of ablation and
leaching, has been the subject of previous Navy studies. In these studies, painted panels were
Hull Coating Leachate
4
-------
submerged in San Diego Bay and copper and zinc release rates were calculated for two of the
most frequently used ablative copper AF paint systems.
Dynamic exposure tests included intervals of simulated vessel movement (cruising) at 17
knots followed by periods of no movement, in order to simulate actual vessel operations. The
calculated long-term average release rates (from both test coatings) for simulated vessel
operation exposures were 17.0 micrograms per square centimeter-day ((|j.g/cm2)/day) for copper
and 6.7 (ug/cm2)/day for zinc. Release rates were highest at the initial stages of the exposures,
when the coatings were new.14
Long-term average release rates for panels remaining in a static position (no simulated
movement) for the entire test were 8.9 (|j.g/cm2)/day for copper and 3.6 (fig/cm2)/day for zinc.14
It is assumed that the static tests underestimate the actual average release rate from vessels
because they do not account for vessel movement and the resulting ablation effects.
A comparison of the above dynamic and static release rates shows that dynamic
conditions resulted in increased release of copper and zinc. The higher release rates are
presumably caused by continuous re-exposure of fresh copper and zinc. The dynamic tests may,
however, overestimate actual conditions for some vessels, as the dynamic intervals used in the
test may have been more aggressive than in actual practice.
rn-situ release rates of TBT from vessels in Pearl Harbor were collected by the Navy in
1987 and 1988.15 These studies reported an average steady-state TBT release rate of 0.38
(|ig/cm2)/day.
3.3 Constituents
The primary antifouling agent in most AF topcoats is copper. Because copper is toxic to
marine organisms, it inhibits their accumulation and growth on the hull. Other than copper
compounds, the constituents that can be released from approved, underwater hull paint systems
include acrylate (in ablative coatings), vinyls (in non-ablative coatings), rosin, zinc compounds,
and anticorrosive compounds.16'17 The discharge from aluminum-hulled vessels may also
contain TBT. Of the known constituents in AF coatings; copper, zinc, TBT, and ethyl benzene
are priority pollutants, and there are no known bioaccumulators.
3.4 Concentrations
Most copper-based AF coatings contain 40 to 50 weight percent (wt%) cuprous oxide.16
Some ablative AF paints also contain as much as 20 wt% zinc, which may act as a mild co-
biocide.16 Concentrations within TBT-based AF coatings range from less than 5 wt% to 25 wt%
for TBT compounds and 25-50 wt% for copper. Some TBT-based coating formulations contain
1-10 wt% ethyl benzene.18
4.0 NATURE OF DISCHARGE ANALYSIS
Hull Coating Leachate
5
-------
Based on the discharge characteristics presented in Section 3.0, the nature of the
discharge and its potential impact on the environment can be evaluated. The estimated mass
loadings are presented in Section 4.1. In Section 4.2, the concentrations of discharge constituents
after release to the environment are estimated and compared with the water quality criteria. In
Section 4.3, the potential for the transfer of non-indigenous species is discussed.
i
4.1 Mass Loadings
|
4.1.1 Copper and Zinc Loadings
The mass loadings for copper and zinc were calculated for Navy, MSC, USCG, Army,
and Air Force vessels based on the reported release rates.14 Loading for a single vessel was
calculated by the following equation:
Copper Loading = (release rate)(surface area)(time)
•where: release rate = dynamic release of copper and zinc (Section 3,2)
surface area=wetted surface area of vessel
time =» number of days vessel is within 12 nauticalmiles (run.)
The wetted surface area of the vessels were either taken directly from a naval manual or
were estimated by the following formula presented in the same source:19
S-L7(LXd)-f-(V/d)
where: S = wetted surface area (ft2)
L = length between perpendiculars (ft)
d ^ molded mean draft at full displacement (ft)
V = molded volume of displacement (for seawater, 35 ft3 per tort displacement)
Calculations were performed for each vessel class. A sample calculation of the mass
loading of copper from a destroyer is provided in Calculation Sheet 1 at the end of the report.
From actual vessel movement data compiled for 1991 through 1995, the sum of the average
number of days in port, the average number of transits, and time of operation within 12 n.m. was
determined for each vessel class.20 The number of vessels in each class are listed in conjunction
with the total calculated loadings per vessel class hi Table 1. A total annual copper loading of
216,657 Ibs (98,257 kilograms (kg)) and a total annual zinc loading of 85,389 Ibs (38,725 kg)
were calculated. The mass loadings calculated represent the worst-case conditions.
The approach used overestimates the mass loading for the following reasons:
Hull Coating Leachate
6
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• Calculations were based on the dynamic release rate, and vessels are not in motion
while pierside.
• All vessels were assumed to be deployed at ports within the jurisdiction of the United
States, while many are actually deployed overseas.
• All vessels are assumed to be fully operational; that is, no reduction was made to
account for the number of vessels which may be in dry dock during the year.
• All small workboats and utility craft were assumed to be in the water at all times,
when they may actually be stored on land.
• Amphibious assault craft of both the Army and Navy, which are capable of being
transported or otherwise held within larger amphibious ships, were assumed to be in
the open water at all times.
4.1.2 TBT Loadings
Table 2 presents mass loadings of TBT from Navy, USCG, Army, and Air Force vessels,
based on the study of TBT concentration measurements from five vessels in Pearl Harbor.15 The
average release rate measured during this study was 0.38 (|j,g/cm2)/day. The mass loading value
was estimated to be 24 Ibs/yr (11 kg/yr) based on the following assumptions:
• Small boats and craft were estimated to be within 12 n.m. at all tunes and to spend
10% of the year out of the water. This assumption leads to an overestimate of the
mass loadings for TBT because many small boats and craft spend much more than
10% of their time out of the water.
• Twenty percent of the Navy's aluminum-hulled small boats and craft were assumed to
still have TBT-based AF coatings, although the actual number may be as low as 10%.
• All of the 50 Air Force and 11 Army small craft were assumed to be painted with
TBT coatings.
Use of these assumptions also overestimates the potential TBT loading since the use of
TBT coatings is being phased out, and the number of TBT coated craft hi the Armed Forces is
continually declining.
4.2 Environmental Concentrations
The estimated quantities of constituents released to the environment are shown in Tables
1 and 2. Using the mass loadings and a tidal prism model for analyzing mixing within specific
harbors, the resulting concentration of constituents in the environment were estimated hi the
manner described below.
_
4.2.1 Copper and Zinc Concentrations
Table 3 lists the Federal and most stringent state water quality criteria for the constituents
of the hull coating leachate discharge. Using the annual copper and zinc loadings and annual
tidal excursion volumes, the average copper and zinc concentrations caused by these vessels were
calculated for each port. The approach used to estimate concentrations uses a simplified dilution
Hull Coating Leachate
7
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model based on tidal flow in three major Armed Forces ports and hereafter referred to as the
"tidal prism" approach. The tidal prism approach uses the mass of the constituent generated by
vessels and mixes this mass with a volume of water. The mass is calculated by determining the
number of vessels in a particular homeport, the wetted surface area of each vessel's hull, and the
number of hours each vessel spends in port (both pierside and in transit). Together, these factors
are used to calculate an annual loading to the harbor. The water volume used is the sum of all
outgoing tides over a year times the surface area of the harbor. The sum of outgoing tides is
called the "annual tidal excursion." This can be calculated by subtracting the annual mean low
tide from the annual mean high tide and multiplying the difference by the number of days in the
year. Annual tidal excursion data is readily available from the National Oceanographic and
Atmospheric Agency (NOAA) and the 1996 data 21 was used for these calculations. The
following is the equation used to estimate concentrations of copper and zinc contributed to
harbors by hull coating leachate:
Concentration increase = Annual load /Annual tidal prism volume
where: annual load = (kg/yr)/(109 jig/kg) = (ng/yr)
annual tidal prism volume = (m3/yr) (103 i/m3) = (L/yr)
Concentration increase = p.g/L
The three ports used for the tidal prism model are Mayport, FL, San Diego, CA, and Pearl
Harbor, HI. These ports were selected because they have minimal river inflow, small but well-
defined harbor areas, and a high number of vessels of the Armed Forces. Each of these factors
will tend to provide higher concentrations of copper and zinc, either due to less volume of water
or higher numbers of potential sources. Other major ports, such as Norfolk (VA) and Bremerton
(WA), were considered, but not included because of large river effects and very large harbor
areas. The 1996 annual tidal volumes (annual tidal excursion times the harbor surface area) for
the three ports are shown below:
San Diego, CA,
Mayport, FL,
3.78 xlO10 m3 per year;
6.7 x 108 m3 per year; and
• Pearl Harbor, HI, 3.42 xHrnr per year.
The tidal prism model assumes steady-state conditions, where copper and zinc are
completely mixed with the harbor water and are removed solely by discharge from the port
during ebb tides. The outgoing tidal volumes are assumed to be carried away by long-shore
currents (i.e., those moving parallel to shore) and do not re-enter the harbor. The tidal prism
model also does not assume removal or concentration by other factors such as river flow,
precipitation, evaporation, or sediment exchange. By not accounting for removal or dilution due
to river flow, precipitation, and sediment exchange, the results depict a higher water column
concentration than expected. The effect of evaporation could be to increase concentration due to
water loss, or the effect could be neutral since water loss by evaporation is replaced by
(additional) water inflow from the sea. While the model assumes complete mixing, there will be
areas in the harbors with higher concentrations, primarily near the source vessels, along with
areas of lower concentration.
Hull Coating Leachate
8
-------
To estimate the annual load for the same three ports, the number and types of vessels in
each of these locations were obtained.22 The ratios of Navy vessels at each of these ports to the
total number of vessels per respective ship class were multiplied by the copper and zinc mass
loadings of Table 1 and summed. The estimated contribution of Armed Forces' AF paint to the
existing copper and zinc concentrations in each port is provided in Table 4. The actual annual
load attributable to hull coating leachate for each of these ports should be smaller than estimated
for two reasons. First, the calculated mass loadings are based upon dynamic release rates, yet the
vessels in port are primarily static. Also, the mass loadings of copper and zinc were determined
using the total amount of time that the vessels are within 12 n.m., not just in port. Therefore, the
actual concentrations in port will be lower than stated.
The calculated copper concentration increases are shown in Table 5 and range from 0.19
ug/L at San Diego to 3.0 |ag/L at Mayport, the latter of which exceeds Federal and state water
quality criteria. Copper from AF paint adds to the ambient copper concentrations from other
sources. In other words, these concentrations represent the ambient copper concentration if hull
coating leachate were the only source of copper in each harbor. Ambient copper concentrations
in San Diego Harbor have been reported to average near 3.7 pg/L, with locally impacted areas
near vessels at twice the average.23
As demonstrated by Table 5, the estimated copper contributions from hull coating
releases are a significant contributor to total copper levels within the Navy ports analyzed. In
addition, some of these ports are already near or above ambient water quality criteria levels for
copper. Therefore, dilution of copper to levels below the water quality criteria cannot be
expected. By contrast, the three ports analyzed were all well below the water quality criteria for
zinc, and estimated zinc concentration increases were not large enough to cause the zinc levels in
these ports to approach the zinc water quality criteria.24
4.2.2 TBT Concentrations
As discussed in Section 2.3.2, only small boats and craft of the Armed Forces still use
TBT-containing coatings. A tidal prism approach can also be used to estimate TBT
concentrations, assuming that the TBT loading in each harbor is proportional to the copper
loading, as might be the case if the locations of small boats and craft parallel that of larger
vessels. As shown hi Calculation Sheet 2, TBT is estimated to range from 0.02 nanograms per
liter (ng/L) to 0.30 ng/L in the harbors analyzed. TBT does not have specific Federal water
quality criteria at the present; however, criteria have been proposed.25 Table 3 lists the proposed
Federal and most stringent state water quality criteria for TBT.
4.3 Potential for Introducing Non-Indigenous Species
Although it is possible for non-indigenous species to be transported on vessel hulls, AF
coatings reduce the amount of marine growth on vessel hulls. The discharge itself (released
components of AF coatings) does not provide the opportunity for transport of non-indigenous
species.
Hull Coating Leachate
9
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5.0 CONCLUSIONS
Hull coating leachate has the potential to cause an adverse environmental effect because
estimated mass loadings of copper from hull coatings are significant and could cause
environmental copper concentrations to exceed water quality criteria in some ports.
6.0 DATA SOURCES AND REFERENCES
i
I
To characterize this discharge, information from various sources was obtained, reviewed,
and analyzed. Process information and assumptions were used to estimate the rates of discharge.
Table 6 shows the sources of data used to develop this NOD report.
Specific References
'!
1. UNDS Equipment Expert Meeting Minutes - Hull Coating Leachate, 20 August 1996.
2. Military Specification, MIL-PRF-24647B, Paint System, Anticorrosive and Antifouling,
Ship Hull, August 1994.
i.
3 . Department of the Army Technical Bulletin, Painting of Watercraft, TB 43-0144, 5
October 1990.
4. Material Safety Data Sheets for Courtaulds Coatings Inc. International Paint Mersleek®
Tie Coat BXA 386/BXA 390/BXA 391 and rntersleek® Finish BXA 816/BXA 821/BXA
822, June 1992.
5. Naval Ships' Technical Manual (NSTM) Chapter 631, Vol. 3, Preservation of Ships in
Service, Section 8, Shipboard Paint Application, 1 November 1992.
6. Naval Sea Systems Command (NAVSEA), Advance Change Notice (ACN) No. 3/A, to
Naval Ships' Technical Manual Chapter 631, S9086-VD-STM-030, Preservation of Ships
in Service. September 1996.
7. Polmar,N. The Naval Institute Guide to the Ships and Aircraft of the U.S. Fleet.
Sixteenth Edition. Naval Institute Press, Annapolis, MD, 1997.
i
8. Commander Military Sealift Command, COMSC Instruction 4750.2C, Preservation
Instructions for MSC Ships, Appendix A, 3 November 1989.
i
9. United States Coast Guard, Coatings and Color Manual, Commandants Instruction
M10360.3A, August 1995.
10. Department of the Air Force, HQUSAF/ILTV, Memo to M. Rosenblatt and Son, Inc., 21
August 1997.
Hull Coating Leachate
10
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11. Holmes, B. S., Naval Sea Systems Command. Vessels with TBT Coatings based on
conversations with Fleet representatives, June 1997, K. Thomas, M. Rosenblatt and Son,
Inc.
12. Aivalotis, J., USCG, TBT on USCG Ships, 28 May 1997, L. Panek, Versar, Inc.
13. UNDS Ship Database, 1 August 1997.
14. Marine Environmental Support Office, Naval Command, Control & Ocean Surveillance
Center, RDT&E Division (NRaD), UNDS Hull Coating Evaluation, 28 February 1997.
15. Naval Command, Control & Ocean Surveillance Center (NRaD). "Butyltin
Concentration Measurements in Pearl Harbor, Hawaii, April 1986 to January 1988, Pearl
Harbor Case Study," April 1989.
16. Material Safety Data Sheets for the following products:
17.
18.
19.
Product/Trade Name:
Manufacturer:
Product/Trade Name:
Manufacturer:
Product/Trade Name:
Manufacturer:
Product/Trade Name:
Manufacturer:
Product/Trade Name:
Manufacturer:
BRA 640 Interviron, Red Antifouling Paint
Courtaulds Coatings
283S5772 ABC #3 - Red Ablative Antifouling Paint
Product Number 406940
Ameron Protective Coatings Group
283S5773 ABC #3 - Black Ablative Antifouling Paint
Product Number 407150
Ameron Protective Coatings Group
Epoxy Adhesives 2216 B/A Gray, 2216 B/A Tan NS, and
2216 B/A Translucent
3M Scotch-Weld™, March 1995
Epoxy Adhesives
3M Innovation, March 1996
Qualified Products List (QPL-15931-14) of Products Qualified Under Military
Specification MDL-P-15931, Paint, Antifouling, Vinyl (Formulas No. 121, 121A, 129, and
129A). January 1995.
Material Safety Data Sheets for International Paint Intersmooth Hisol Plum BFA254,
November 1996; and Devoe Coating Company ABC #2 Red Ablative Antifouling
Coating, September 1995.
Naval Ships' Technical Manual (NSTM) Chapter 633, Section 4.3.1 and Table 633-5.
Cathodic Protection. 1 August 1992.
Hull Coating Leachate
11
-------
20. Pentagon Ship Movement Data for Years 1991-1995, Dated 4 March 1997.
21. National Oceanic and Atmospheric Administration, 1997.
22. United States Navy, List of Homeports, Effective 30 April 1997.
I
23. Valkirs, A.O., B.M. Davidson, L.L. Kear, R.L. Fransham, A.R. Zirino, and J.G.
Grovhoug; Naval Command, Control and Ocean Surveillance Center, RDT&E Division.
"Environmental Effects from In-Water Hull Cleaning of Ablative Copper Antifouling
Coatings." Tech. Doc. 2662. 1994.
24. U.S. Environmental Protection Agency, Office of Wetlands, Oceans and Watersheds,
Assessment and Watershed Protection Division, Retrieval from STORET Database,
1997.
25. Proposed Water Quality Criteria, 62 Federal Register 42554, 7 August 1997.
i
ii
General References
i
I
USEPA. Toxics Criteria for Those States Not Complying with Clean Water Act Section
303(c)(2)(B). 40 CFR Part 131.36.
USEPA. Interim Final Rule. Water Quality Standards; Establishment of Numeric Criteria for
Priority Toxic Pollutants; States' Compliance - Revision of Metals Criteria. 60 FR
22230. May 4, 1995.
i
i
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants. 57 FR 60848. December 22,1992.
|
USEPA. Water Quality Standards; Establishment of Numeric Criteria for Priority Toxic
Pollutants for the State of California, Proposed Rule under 40 CFR Part 131, Federal
Register, Vol. 62, Number 150. August 5,1997.
Connecticut. Department of Environmental Protection. Water Quality Standards. Surface Water
Quality Standards Effective April 8,1997.
i
i
Florida. Department of Environmental Protection. Surface Water Quality Standards, Chapter
62-302. Effective December 26,1996.
i
Georgia Final Regulations. Chapter 391-3-6, Water Quality Control, as provided by The Bureau
of National Affairs, Inc., 1996.
I
Hawaii. Hawaiian Water Quality Standards. Section 11, Chapter 54 of the State Code.
Hull Coating Leachate
12
-------
Mississippi. Water Quality Criteria for Intrastate, Interstate and Coastal Waters. Mississippi
Department of Environmental Quality, Office of Pollution Control. Adopted November
16,1995.
New Jersey Final Regulations. Surface Water Quality Standards, Section 7:9B-1, as provided by
The Bureau of National Affairs, Inc., 1996.
Texas. Texas Surface Water Quality Standards, Sections 307.2 - 307.10. Texas Natural
Resource Conservation Commission. Effective July 13,1995.
Virginia. Water Quality Standards. Chapter 260, Virginia Administrative Code (VAC) , 9 VAC
25-260.
Washington. Water Quality Standards for Surface Waters of the State of Washington. Chapter
173-201 A, Washington Administrative Code (WAC).
Naval Command, Control and Ocean Surveillance Center, RDT&E Division, San Diego, CA.
"Dynamic and Static Exposure Tests and Evaluations of Alternative Copper-Based
Antifouling Coatings." September 1993.
Military Specification, MIL-PRF-15931, Paint, Antifouling, Vinyl, January 1995.
Qualified Products List (QPL-24647-3) of Products Qualified Under Military Specification MTT.-
PRF-24647, Paint System, Anticorrosive and Antifouling, Ship Hull. 2 April 1996.
Aivalotis, J., United States Coast Guard, USCG Ship Movement, 27 May 1997, L. Sesler,
Versar, Inc.
UNDS Equipment Expert Round 2 Meeting Minutes - Hull Coating Leachate, 1997.
Committee Print Number 95-30 of the Committee on Public Works and Transportation of the
House of Representatives, Table 1.
The Water Quality Guidance for the Great Lakes System, Table 6A. Volume 60 Federal
Register, p. 15366. March 23,1995.
_
Hull Coating Leachate
13
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_
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Table 3. A Comparison of Estimated Concentrations Versus Water Quality Criteria
Constituent
Copper
(dissolved)
Zinc
(dissolved)
TBT
Estimated Environmental
Concentration (ug/L)a
0.19-3.0
5.0-12.8
0.00002 - 0.0003
Federal Chronic Water
Quality Criteria (pg/L)
2.4
81
0.01"
Most Stringent State Chronic
Water Quality Criteria (ug/E)
2.4 (CT, MS)
76.6 (WA)
0.001 (VA)
Notes:
Refer to federal criteria promulgated by EPA in its National Toxics Rule, 40 CFR 131.36 (57 FR 60848; Dec. 22,
1992 and 60 FR 22230; May 4, 1995)
:i
l|
CT - Connecticut
MS - Mississippi
VA83 Virginia
WA- Washington
* Range is for three high use Navy ports: San Diego, CA; Mayport, FL; and Pearl Harbor, HI.
b Proposed water quality criteria, August 7,1997
-------
Table 4. Copper and Zinc Loading into San Diego, Pearl Harbor, and Mayport for Use in
Concentration Estimate
>**• :'\'.^&f*^i^^^-
CG47
CV63
DD963
DDG51
LHA1