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


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

Technical Development Document

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

                       and

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

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                                    FOREWORD

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

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                                  TABLE OF CONTENTS
EXECUTIVE SUMMARY	ES-1

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

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

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

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

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

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

GLOSSARY AND ABBREVIATIONS	GL-1
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                                 LIST OF TABLES

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

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

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

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

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

                                 LIST OF FIGURES

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

                                   APPENDICES

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

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

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

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

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

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

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

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

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

1.1 Background

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

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

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

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

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

1.2 Legal Authority and Statutory Requirements for the UNDS Regulations

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

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

1.2.2 Vessels

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

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

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

1.2.3 Waters

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

1.3 UNDS Development Requirements

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

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

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

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

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

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

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

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

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

1.4    References

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

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

2.1    Introduction

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

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

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

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

2.2 Description of Vessel Classes and Types

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

2.2.1.1 Navy Mission

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

2.2.1.2 Navy Vessel Description

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

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

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

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

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

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

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

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

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

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

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

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

2.2.2.1 Military Sealift Command Mission

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

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

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

2.2.2.2 Special Mission Support Force

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

2.2.2.3 Naval Fleet Auxiliary Force

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

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

NFAF

Class/Ship

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

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

Number
Active

5
4
9
2
1
1

.. 8
8
12
7

Class
Length "'
(ft).

234
285
442
455
595
502

563
523
677
240

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

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

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

2.2.3.1 Coast Guard Mission

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

2.2.3.2 Coast Guard Vessel Description

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

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



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

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

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

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

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

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

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

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

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

2.2.4.1 Army Mission

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

2.2.4.2 Army Vessel Description

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

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

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

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

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

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

2.2.5.2 Marine Corps Vessel Description

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

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

2.2.6.1 Air Force Mission

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

2.2.6.2 Air Force Vessel Description

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

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

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

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

2.2.7.1 Army Corps of Engineers Vessels

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

2.2.7.2 Maritime Administration Vessels

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

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

2.2.7.3 Vessels Preserved as Memorials and Museums

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

2.2.7.4 Time-and Voyage-Chartered Vessels

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

2.2.7.5 Vessels Under Construction

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

2.2.7.6 Vessels in Drydock

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

2.2.7.7 Amphibious Vehicles

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

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2.3 Locations of Armed Forces Vessels

2.3.1 Homeports

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

2.3.1.1 Navy Ports

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

2.3.1.2 Coast Guard Ports

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

2.3.1.3 Army Ports

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

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

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

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

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

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

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

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

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

-------




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

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

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

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

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

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

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

2.4    References

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

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

3.1    Introduction

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

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

3.2    Surveys

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

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

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

3.3    Consultations with Department of Defense Personnel Having Equipment Expertise

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

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

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

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

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

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

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

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

3.4.1 Initial State Consultation Meetings

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

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

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

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


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

3.4.3  Consultation with Environmental Organizations

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

3.4.4  UNDS Newsletter and Homepage

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

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

3.5    Sampling and Analysis

3.5.1  Approach to Identifying Discharges Requiring Sampling

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

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

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

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

X



X


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








X
PCBs
X


X
X
X
X

X
Mercury"

X



X


X
Hydrazine
X
X






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

3.5.3  Shipboard Sampling

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

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

3.5.4 Quality Assurance/Quality Control and Data Validation Procedures

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

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

-------
 a,

2
VI

 E?
 05
JS
 u
 09
vo

rn

 
1
P
g

X












vater Lay-Up
§




X



X
X
X



)ily Machinery
water
ll
X



X

X

X
X
X


J
ter Cooling Ovei
irge
3-|
CO P
X



X


X
X





Condensate
i
CO










X

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

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

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

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                 4.  DISCHARGE EVALUATION METHODOLOGY
4.1    Introduction

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

4.2    Environmental Effects Determination

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

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

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

4.2.1   Chemical Constituents

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

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

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

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

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

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

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

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

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

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


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

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

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

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


8.2
7.9


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

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

EPA, CA, CT
WA

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

WA
FL
GA

EPA, CA, MS
WA

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

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

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

4.2.2  Thermal Pollution

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

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

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

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

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

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

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

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

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

4.2.4   Nonindigenous Species

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

4.2.5  Discharge Evaluation

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

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

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

4.3 Nature of Discharge Analysis

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

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

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4.3.1 Nature of Discharge Report Contents

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

Section 2.0- Discharge Description

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

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

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

Section 3.0 — Discharge Characteristics

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

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

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

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

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

Section 4.0 - Nature of Discharge Analysis

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

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

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

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

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

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

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

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

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

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

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

4.4.1   MPCD Practicability, Operational Feasibility, and Cost Report Contents

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

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

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

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4.5 References

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

5.1 Discharges Determined To Require MPCDs

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

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

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

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

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

X


X
X
X
X

X

X


X






X
X

X
Metals








X

X


X



X





X

Organic
Chemicals











X
X






X






Thermal
Pollution

















X








Bioaccum-
, ulative
Chemicals
of Concern


























Nonindigenous
Species



X










X








X

«
Other
(b)

(c)












(d)
(d)

(e)

(c)




                                      5-2

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

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

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

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

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

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

5.1.2 Catapult Water Brake Tank and Post-Launch Retraction Exhaust

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

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

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

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

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

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

5.1.3 Chain Locker Effluent

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

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

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

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

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

5.1.4 Clean Ballast

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

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

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

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

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

5.1.5 Compensated Fuel Ballast

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

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

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

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

5.1.6 Controllable Pitch Propeller Hydraulic Fluid

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

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

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

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

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

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

5.1.7 Deck Runoff

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

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

5.1.8 Dirty Ballast

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

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

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

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

5.1.9 Distillation and Reverse Osmosis Brine

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

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

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

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

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

5.1.10 Elevator Pit Effluent

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

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

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

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

5.1.11 Firemain Systems

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

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

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

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

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

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

5.1.12 Gas Turbine Water Wash

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

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

5.1.13 Graywater

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

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

5.1.14 Hull Coating Leachate

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

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

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

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

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

5.1.15 Motor Gasoline Compensating Discharge

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

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

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

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

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

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

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

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

5.1.17 Photographic Laboratory Drains

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

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

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

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

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

5.1.18 Seawater Cooling Overboard Discharge

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

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

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

5.1.19 Seawater Piping Biofouling Prevention

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

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

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

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

5.1.20 Small Boat Engine Wet Exhaust

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

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

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

5.1.21 Sonar Dome Discharge

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

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

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

5.1.22 Submarine Bilgewater

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

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

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

5.1.23 Surface Vessel Bilgewater/OWS Discharge

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

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

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

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

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

5.1.24 Underwater Ship Husbandry

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

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

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

5.1.25 Welldeck Discharges

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

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

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

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

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

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

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

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

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

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

5.2.1 Boiler Slowdown

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

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

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

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

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

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

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

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

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

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

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

5.2.3 Cathodic Protection

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

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

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

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

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

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

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

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

5.2.4 Freshwater Lay-Up

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

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

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

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

5.2.5 Mine Countermeasures Equipment Lubrication

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

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

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

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

5.2.6 Portable Damage Control Drain Pump Discharge

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

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

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

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

5.2.7 Portable Damage Control Drain Pump Wet Exhaust

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

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

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

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

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

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

5.2.8 Refrigeration and Air Conditioning Condensate

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

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

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

5.2.9 Rudder Bearing Lubrication

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

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

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

5.2.10 Steam Condensate

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

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

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

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

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

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

5.2.11 Stern Tube Seals and Underwater Bearing Lubrication

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

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

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

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

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

5.2.12 Submarine Acoustic Countermeasures Launcher Discharge

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

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

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

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

5.2.13 Submarine Emergency Diesel Engine Wet Exhaust

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

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

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

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

5.2.14 Submarine Outboard Equipment Grease and External Hydraulics

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

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

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

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

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

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

5.3    References

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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                                     Appendix A

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

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

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

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

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

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

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

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

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

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2.0 DISCHARGE DESCRIPTION

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

2.1 Equipment Description and Operation

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

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

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

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

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

Aqueous Film Forming Foam (AFFF)
2

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

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

2.2 Releases to the Environment

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

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

2.3 Vessels Producing the Discharge

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

This section contains qualitative and quantitative information that characterizes the
discharge. Section 3.1 describes where the discharge occurs with respect to harbors and near-
shore areas, Section 3.2 describes the rate of the discharge, Section 3.3 lists the constituents in
the discharge, and Section 3.4 gives the concentrations of the constituents in the discharge.

Aqueous Film Forming Foam (AFFF)
3

-------
       3.1    Locality

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

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

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

       3.2    Rate

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

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

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

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

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

3.3 Constituents

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

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

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

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

3.4 Concentrations
Aqueous Film Forming Foam (AFFF)
5

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

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

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

4.1 Mass Loadings

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

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

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

4.2 Environmental Concentrations

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

Aqueous Film Forming Foam (AFFF)
6

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

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

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

4.3 Potential for Introducing Non-Indigenous Species

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

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

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

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

Aqueous Film Forming Foam (AFFF)
7

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

                         Aqueous Film Forming Foam (AFFF)
                                        8

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Anil Giri, M. Rosenblatt & Son, Inc.

General References

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

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

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

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

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

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

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

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

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

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

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

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