Summary of the VGP Vessel Universe:
   Information Submitted by Vessel Owner/Operators
for Coverage under the 2008 Vessel General Permit (VGP)
               U.S. Environmental Protection Agency
               Office of Water, Water Permits Division
                     EPA-833-K-11-102

                       March 2013

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The primary technical contacts for this document are:
                                   Kathryn Kelley
                              (202) 564-7004 (telephone)

                                    Ryan Albert
                              (202) 564-0763 (telephone)
                         U.S. Environmental Protection Agency
                          Office of Water (Mail Code: 4203M)
                            1200 Pennsylvania Avenue, NW
                                Washington, DC 20460
Cover Photo Credits

   1.  MS Nieuw Amsterdam - Holland America Inc.
   2.  MSC Beatrice - World Shipping Council
   3.  Nanticoke - Vane Line Bunkering
   4.  Maersk Magellan - A.P. Moller - Maersk Group
   5.  Donna Rushing - The American Waterways Operators

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Summary of the VGP Vessel Universe                                       March 2013


                                   Table of Contents

1   Introduction	6
  1.1        Purpose of Report	6
  1.2       NOT Requirements	6
  1.3        Uncertainty and Supplementing NOT information	7
2   NOT Vessel Universe	8
  2.1        Overview of Vessels by Vessel Type	8
  2.2       Comprehensive Summary and Analysis of NOT Vessel Universe	9
    2.2.1   Vessel General Characteristics and Voyage Related Information	10
       2.2.1.1    Vessel Subtypes	10
       2.2.1.2    Vessel size and age	11
       2.2.1.3    Dates of Dry Docking	13
       2.2.1.4    Home/Most Frequented Port and Geographical Area of Operation	13
       2.2.1.5    Crew and Passengers	21
    2.2.2   Ballast Water and Related Information	24
       2.2.2.1    Ballast Water Capacity	24
       2.2.2.2    Ballast water management, tank cleaning, and  sediment disposal	28
       2.2.2.3    Experimental ballast water treatment systems and discharge of residual
                biocides	32
    2.2.3   Applicable Discharges and Related Information	32
       2.2.3.1    Applicable discharges	32
       2.2.3.2    Onboard  treatment systems for generated waste streams	34
    2.2.4   Anti-fouling Hull Coatings and Related Information	35
       2.2.4.1    Type of coating	35
       2.2.4.2    Anti-fouling hull coating application and hull husbandry practices	35
  2.3        Characterization of Vessels with Missing Information	37
    2.3.7   Data Sources	37
    2.3.2   Methodology	38
    2.3.3   Summary and Analysis of NOI Vessels with Incomplete Information	39
3   Summary	40
4   References	43
Appendix A: Comparison of the NOI Universe of Vessels  versus the Universe of Vessels
     in the Final 2008 VGP Economic and Benefit Analysis	A-l
Appendix B: Summary of vessel characteristics where NOI information was incomplete	B-l
       Barges     	B-2
       "Other" Vessels	B-3
       Oil or Gas Tankers	B-4
       Miscellaneous Vessel Types	B-6

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Summary of the VGP Vessel Universe                                        March 2013


                                      List of Tables

Table 2.1. Number of respondents who further classified their vessel by writing in a subtype
       on their NOT	10
Table 2.2. Cargo carrier type specified within the "Other" vessel category	11
Table 2.3. Statistical distribution of tonnage (GT) of NOT vessels by vessel type	12
Table 2.4. Statistical distribution of length (feet) of NOT vessels by vessel type	12
Table 2.5. Statistical distribution of agea (years) of NOT vessels by vessel type	13
Table 2.6. Statistical distribution of the time interval since the last  dry docking by vessel type
       (by years)	13
Table 2.7. Top fifteen home/most frequent port cities for barges	14
Table 2.8. Top ten home/most frequented port cities for oil and gas tankers	16
Table 2.9. Home/most frequented port for large ferries	17
Table 2.10. Top seven home/most frequented port cities for research vessels	19
Table 2.11. Top 10 Home/most frequented port cities for "Other" vessels	20
Table 2.12. Summary statistics on maximum persons (crew and passengers) aboard NOT
       vessels	21
Table 2.13. Statistical summary  of ballast capacity for vessels in the NOT	24
Table 2.14. Percentage of vessels within a given type where use/non-use of a ballast water
       management plan (BWMP) has been indicated	28
Table 2.15. Summary of the frequency of ballast tank cleaning for  vessel types (Values
       reflect percentage of vessels for which a response was provided)	29
Table 2.16. Summary of ballast water sediment disposal methods for vessel types (Values
       reflect percentage of vessels for which a response was provided)	29
Table 2.17. Percentage of vessels where the applicable discharge listed is reported. (Note:
       the 26 applicable discharges listed represent the possible discharges listed on the 2008
       VGP NOT. The top five applicable discharges for each NOT vessel type are shaded.)	33
Table 2.18. Presence of onboard treatment systems per vessel type and a summary of the
       types of generated waste streams that were treated (values reflect percent of the total
       number of vessels for which response was provided, with the corresponding
       percentage within a class of vessels in parentheses)	34
Table 2.19. Summary of anti-fouling hull coatings used on vessels as reported on the
       vessels' NOIs. (Values reflect percent of the total number of vessels for which
       response was provided, with the corresponding percentage  within a class of vessels in
       parentheses)	35
Table 2.20. Summary statistics depicting number of years since last anti-fouling hull coating
       at time of NOT coverage	36
Table 2.21. Summary of the frequency with which hull  husbandry  practices were utilized for
       vessels. (Values represent actual number of responses)	36
Table 2.22. Summary of hull husbandry cleaning practices for NOT vessels. (Values represent
       actual number of responses)	37
Table 3.1. Summary of key vessel characteristics reported in the NOT database by vessel
       type	42

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Summary of the VGP Vessel Universe                                        March 2013


                                     List of Figures

Figure 2.1- 1: NOT vessels by vessel type	9
Figure 2.2- 1: Distribution of barges by geographic region	15
Figure 2.2-2: Distribution of large ferries by geographic region	17
Figure 2.2- 3: Primary area of operation reported for large cruise ships	18
Figure 2.2- 4: Primary area of operation for medium cruise ships	19
Figure 2.2- 5: Distribution of maximum persons (crew and passengers) aboard vessels of a
       given type	22
Figure 2.2- 6: Distribution of maximum persons (crew and passengers) aboard vessels of a
       given type (continued)	23
Figure 2.2- 7: Relationship between vessel tonnage (GT) and ballast water capacity for
       vessels identified in the NOT database	25
Figure 2.2- 8: Relationship between vessel tonnage (GT) and ballast water capacity for
       vessels identified in the NOT database (continued)	26
Figure 2.2- 9: Relationship between vessel length and ballast water capacity for vessels
       identified in the NOT database	27
Figure 2.2- 10: Relationship between vessel  length and ballast water capacity of for vessels
       identified in the NOT database (continued)	28
Figure 2.2- 11: Sediment disposal methods based on NOT submittals	30
Figure 2.2- 12: Sediment disposal methods based on NOT submittal (continued)	31
Figure 2.3- 1: MISLE and NB 1C compatible vessels	39

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Summary of the VGP Vessel Universe                                        March 2013


1   Introduction

The United States Environmental Protection Agency's (EPA) National Pollutant Discharge
Elimination System (NPDES) vessel program regulates incidental discharges from the normal
operation of vessels operating in a capacity as a means of transportation. In 2008, EPA issued its
first Vessel General Permit (VGP) (EPA, 2008a). When finalizing that permit, EPA estimated
that approximately 70,000 vessels would be eligible for coverage under the VGP. Part 1.5.1.1 of
the 2008 VGP requires owners or operators of vessels that are greater than or equal to 300 gross
[registered] tons or have the capacity to hold  or discharge more than 8 cubic meters (2,113
gallons) of ballast water to submit a complete and accurate Notice of Intent (NOI) in accordance
with Part 10 of the VGP to obtain authorization to discharge. Owners and operators of existing
vessels had until September 19, 2009 to submit an NOI to seek coverage under the VGP.l
Vessels less than 300 gross tons that do not have the capacity to hold or discharge more than 8
cubic meters (m3) of ballast water are authorized to discharge without having to submit an NOI.

1.1   Purpose of Report

The purpose of this report is to provide a summary of the characteristics and conditions of vessel
discharges based on information submitted in NOIs filed under the 2008 VGP. This report
presents NOI data reported by owners/operators (respondents/permittees) who applied for
coverage under the VGP during the period of June 1, 2009 (the launch of the electronic NOI
system (eNOI)) through August 5, 2010, and  represents the first comprehensive summary of
vessel information for vessels authorized to discharge under the VGP. This information is stored
within an EPA NOI database. Information about individual NOIs is available to the public at
http://cfpub.epa.gov/npdes/vessels/vesselsnoisearch.cfm

1.2   NOI Requirements

Submission of NOIs requires the following information: vessel type, Employer Identification
Number  (EIN), company  International Maritime Organization (EVIO) number, vessel identifier,
certifying official data, vessel weight, vessel ballast water capacity, frequency and location of
ballast tank sediment disposal, waste discharges generated by the vessel, hull husbandry best
management practices (BMPs),  indication of travel outside the U.S. exclusive economic zone
(EEZ), etc. For NOIs submitted that were missing a significant amount of mandatory data, EPA
retained the option to contact the responder to collect the missing data for that vessel
owner/operator to secure coverage under the VGP.
Note that because the eNOI system does not automatically verify user entries (e.g., to identify
and correct misspellings), for the purpose of this analysis, EPA has:
    •   unified terminology or classification used by responders when necessary, and
    •   made other minor modifications for clarity or to facilitate data summary when entries
       contained obvious errors.
1 EPA's NPDES vessels program regulates incidental discharges from the normal operation of vessels. The NPDES
vessels program does not regulate discharges from military vessels or recreational vessels. Instead, those are
regulated by other EPA programs under section 312 of the Clean Water Act (CWA).

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Summary of the VGP Vessel Universe                                         March 2013


For example, EPA standardized entries for "NOLA" and New Orleans, LA as a home/most
frequented port. EPA also developed a coding system to sort and categorize reported information
on hull husbandry practices and frequency with which those practices were implemented.

1.3   Uncertainty and Supplementing NOI information

In the VGP (Part  1.5.1.1), EPA limited which vessels had to submit an NOI to focus data
collection on vessels with larger volumes of permitted discharges (see Part 3.7.1 of the VGP Fact
Sheet for further discussion) (EPA, 2008b). As of August 5, 2010, approximately 43,431
uniquely identified vessels,  owned/operated by 3,430 different permittees, had active NOI
coverage.  There is uncertainty as to the exact number of permittees because of different spellings
that in fact may be the same permittee.

In summarizing and comparing the characteristics of the vessel population, EPA assumed the
data submitted by each respondent were accurate, unless the data were found to be clearly
erroneous (e.g., a vessel noted to be over 650,000 feet in length). To account for error, the upper
range of quantitative values submitted for select characteristics (e.g., vessel  weight and length,
ballast water capacity, etc.) has been truncated to the 90  percentile value. For 6,468 out of the
43,431 uniquely identified vessels, the information provided by the respondent was incomplete
or insufficient (e.g., did not include a specific entry/value for tonnage or ballast water capacity)
and was not included in the overall analysis. Instead, EPA complemented the incomplete or
insufficient data with information from two databases: the U.S. Coast Guard's Marine
Information for Safety and Law Enforcement (MISLE) database (USCG, 2009) and National
Ballast Water Information Clearinghouse (NBIC). MISLE provides a wide range of information
regarding  vessel characteristics, hailing ports, and other pertinent information tracked by the U.S.
Coast Guard. EPA used the MISLE database to support vessel characterizations in their 2010
Report to  Congress.3 NBIC provides data on ballast water management practices of commercial
ships that  operate in the waters of the United States.

These two databases were used to develop estimates of the number of vessels eligible for
coverage under the VGP  (Abt Associates, 2008). To check the accuracy of EPA's original
estimates  and to evaluate whether vessels that should be seeking coverage actually were doing
so, EPA compared the number of NO Is submitted to the MISLE and NBIC estimates, as
summarized in section 2.3 of this document. Furthermore, Appendix A of this report provides a
comparison of the information contained in the NOI database with estimates developed as part of
the economic analysis for the 2008 VGP.
2 In this analysis, EPA defines uniquely identified vessels as those that are certified and have active permits. These
vessels all have a unique IMO registration or other vessel identifier number; vessel name; and/or call sign in the NOI
database, as well as a permit status labeled as either 'Active' or 'Certified'. EPA determined that 43,431 out of
53,567 total vessels currently meet these criteria. Vessels that are not considered in this analysis include 3,563
vessels with an archived status and 2,692 vessels with a terminated status. EPA notes that owner/operators of some
vessels with an archived status intended to seek active coverage, but did not take all necessary steps in the
electronic NOI system to finalize that coverage.
3U.S. EPA, 2010. Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial Fishing
Vessels and Other Non-Recreational Vessels Less than 79 Feet. Report EPA 833-R-10-005. August 2010.

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Summary of the VGP Vessel Universe                                         March 2013


2   NOI Vessel Universe

This section of this document provides a comprehensive summary of vessel information
submitted by vessel owner/operators in their NOIs. The EPA NOI database (dated August 5,
2010) includes data for 43,431 vessels with an active or certified NOI4 status that operate in U.S.
waters, including 6,468 vessels for which tonnage and/or ballast water capacity is missing
(Figure 2.1-1). Section 2.2 of this document presents results from 36,642  uniquely identified
vessels that submitted complete NOIs. Section 2.3 compares the insufficient NOI data with
MISLE and NBIC databases for the remaining 6,468 vessels.

2.1   Overview of Vessels by Vessel Type

Vessel owner/operators can classify their vessel under Question B.5 on the VGP NOI form as
one of eight listed vessel types (plus an "other" category). Of the 36,642 uniquely identified
vessels, 24,241 vessels were listed under one of these eight classifications (in order of number of
vessels identified):
   •   Barges of all types;
   •   Oil or Gas Tankers;
   •   Commercial Fishing Vessels with Ballast Water (hereinafter Commercial Fishing
       Vessels);
   •   Large Ferries (250+ passengers or more than 100 tons of cargo, e.g., cars, trucks,  trains,
       or other land-based transportation);
   •   Large Cruise Ships (500+ passengers);
   •   Research Vessels;
   •   Emergency Vessels;
   •   Medium Cruise Ships (100 to 499 passengers).

Of these 24,241 vessels, barges, followed by oil and gas tankers, represent the largest percentage
of vessels (Figure 2.1-1). Commercial fishing vessels with ballast water, large ferries, large and
medium  cruise ships, and research and emergency vessels, combined, represent about one
percent or so of the total.

The remaining 12,401 vessels were identified as "other," making this the second largest category
of vessels overall. Many vessel operators who checked "Other" also filled in  a secondary vessel
type (see additional details provided in section 2.2.1.1 of this document).
4 An active NOI refers to those for which the 30-day waiting period has been completed and no additional issues
have been identified, whereas a certified NOI is one that is in the 30-day waiting period prior to becoming active.
Note: not all NOIs in the current system are active (see footnote 2).
5 The values reported for vessel tonnage and/or ballast capacity for 321 vessels with active or certified NOI status
are less than 300 gross registered tons and 8 m3, respectively, and therefore, are also excluded from the more
detailed examination of vessel characteristics data summarized in this report.

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Summary of the VGP Vessel Universe
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Figure 2.1-1: NOI vessels by vessel type.
          D Commercial Fishing Vessel,
                146, 0.3%
    D Emergency Vessel
         56, 0.1%
                                          Number of Vessels
D Other, 12,401, 28.6%
                                                                           D Lacking Info,
                                                                            6,468, 14.9%
    D Barge, 20,410, 47.0%
                         D Not Applicable, 321, 0.7%

                   • Research Vessel, 82, 0.2%

   D Oil or Gas Tanker, 3,280, 7.6%

   D Medium Cruise Ship, 22, 0.1%
   I Large Cruise Ship, 127, 0.3%
2.2   Comprehensive Summary and Analysis of NOI Vessel Universe

Section 2.2 of this document presents vessel characteristic data reported in the NOI for the
36,642 uniquely identified vessels for the following four types of information:

Vessel General Characteristics and Voyage Related Information - vessel subtypes; tonnage,
length, and age; date of last dry dock; home/most frequented port; and crew size/passenger
capacity.

Ballast Water and Ballast Water Treatment - ballast water capacity; ballast water
management plan, tank cleaning and sediment disposal; and experimental ballast water treatment
systems and associated discharge of residual biocides.
  Source: EPA NOI database, August, 5, 2010. Note: Percentages are based on the total number of vessels within a
given type out of the total 43,431 uniquely identified vessels in the NOI. The subset of 6,468 vessels within the
"Uncertain" group and identified as "Lacking Information" consists of those vessels for which the information
reported in the NOI regarding tonnage or ballast water capacity was missing. These vessels are discussed further in
Section 2.3 of this document, and have been excluded from the more detailed data summary and analysis included in
section 2.2 of this document. Again, EPA did not analyze the 321 vessels identified as "Not Applicable" because the
tonnage and ballast water capacity reported in the NOI for these particular vessels are less than 300 gross tons and/or
8 m3, respectively. However, EPA notes that these vessels may have chosen to submit an NOI despite being smaller
than these thresholds, or if the vessel is below 79 feet, may be seeking coverage for the ballast water discharges only
as authorized in Part 1.2.1 of the VGP.

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Summary of the VGP Vessel Universe
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Vessel Discharge and Treatment System - applicable discharges and onboard treatment
systems and the waste-streams they are designed to treat.

Anti-fouling Hull Coatings - type of coating; interval since last application; and hull husbandry
practices, including the frequency with which the practices are implemented.

2.2.1   Vessel General Characteristics and Voyage Related Information

2.2.1.1 Vessel Subtypes
Respondents who selected one of the eight listed vessel types also had an opportunity to further
classify their vessel. Table 2.1 shows the number of owners/operators who either selected
"other" or specified a subtype in addition to  one of the eight vessel types. The percentage of
vessels that were further specified as a subtype was highest for emergency vessels (79 percent)
and commercial fishing vessels (57 percent). Notably, of the  12,401 respondents who classified
their vessel type exclusively as "Other" only 21 percent actually wrote in a  specific subtype as
requested by the NOT form.

Table 2.1. Number of respondents who further classified their vessel by writing in  a
subtype on their NOI.
Subtype
Specification
Yes
No
Total
Subtype Specified (%)
Barges
106
20,304
20,410
<1%
Oil and
Gas
Tankers
82
3,198
3,280
2.5%
Comm.
Fishing
84
62
146
57%
Large
Ferries
7
111
118
5.9%
Large
Cruise
Ship
1
126
127
<1%
Med.
Cruise
Ship
1
21
22
<1%
Research
2
80
82
2.4%
Emerg.
44
12
56
79%
Other
2,562
9,839
12,401
21%
Barges
Of the 20,410 barges, less than one percent (106 barges) were sub-classified by respondents. The
largest number were designated dredge attendant plants (50 barges), followed by dredgers (15),
deck barges for construction materials (13), oil and gas or other tank barges (10), and cranes of
various types (10).

Oil and Gas Tankers
Of the 3,280 oil and gas tankers, only 2.5 percent were specifically sub-classified, with the
largest number identified as either chemical tankers (51) or barge or tank barges (20).

Commercial Fishing Vessels
Roughly 58 percent of commercial fishing vessels (84 out of 146 vessels) were sub-classified as
bulk carriers, cargo or container vessels (56), with a much smaller number sub-classified as
tug/towboats (6), barges (5), or off-shore supply vessels (5).

Large Ferries, Large and Medium Cruise Ships, and Research Vessels
Very few ferries and large and medium cruise ships were sub-classified. Of the 118 large ferries,
four are sub-categorized as large cruise ships and three as medium cruise ships. Of the 127 large
cruise ships, one was sub-classified as a barge. Of the 22 medium cruise ships, one was sub-
                                           10

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Summary of the VGP Vessel Universe
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classified as a large ferry. Likewise, only two of the 56 research vessels were sub-classified, with
both identified as workboats.

Emergency Vessels
In contrast, 44 of 56 emergency vessels were sub-classified; 43 as oil recovery vessels and one as
a research vessel.

"Other" Vessels
Respondents were also given the choice to exclusively select "Other" and write in a specific
vessel type. Of the  12,401 "Other" vessels, only 2,562 respondents (21 percent) wrote in a
subtype as requested by EPA, while 9,839 respondents (79 percent) did not. Furthermore, out of
the 2,562 respondents who wrote in a specific vessel type, 67 respondents provided an entry that
matched one of the eight vessel types listed in the NOT form.

Cargo carriers (See Table 2.2 below) comprised the vast majority of the "Other" vessels (2,044
vessels), followed by tugs/tow boats (143), crew/supply/support vessels (115), chemical/oil
tankers (83), barges (34), and passenger vessels (18).

Table 2.2. Cargo carrier type specified within the "Other" vessel category.
CARGO CARRIER TYPE
General Cargo (Not Otherwise Specified)
Car/Truck Carrier
Refrigerated Cargo
Log/Lumber/Woodchip Carrier
Roll-on Roll-off Cargo
Cement Carrier
Grain/Ore Carrier
Irradiated Nuclear Fuel Carrier
Ore/Bulk/Oil Carrier
# Vessels
1,870
74
47
25
19
3
2
2
2
2.2.1.2 Vessel size and age
Tonnage
Table 2.3 provides a summary of the statistical distribution of tonnage7 of NOT vessels by vessel
type. Median tonnage ranges from 563 gross tons (GT) for emergency vessels to 53,526 GT for
large cruise ships. Barges, in general, are lighter than other vessel types with 90 percent of the
barges weighing less than 1,065 GT.
7 Vessel tonnage is reported in terms of gross tons (GT) here and throughout the remainder of this data summary
report. For purposes of this analysis, where data was entered as gross registered tons (GRT), values were converted
to GT using a multiplication factor of 0.592885 (or approximately 300 GT per 506 GRT) to standardize numbers.
This conversion factor was recommended by the U.S. Coast Guard (personal communication between Jordan
Gilliland, Environmental Scientist, EPA NOI Processing Center (staffed by the Avanti Corporation), and the U.S.
Coast Guard; December 2010). EPA recognizes that calculation of GRT is complex and does not necessarily result
in a linear relationship between GT and GRT. Thus values for vessel tonnage may be over- or under-estimated in
this report for certain vessels.
                                             11

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Summary of the VGP Vessel Universe
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Table 2.3. Statistical distribution of tonnage (GT) of NOI vessels by vessel type.
Statistic
Minimum
10th Percentile
25th Percentile
Median
75th Percentile
90th Percentile
N (sample size)
Barges
5
418
453
705
788
1,065
20,364
Oil and
Gas
Tankers
25
6,039
14,224
24,908
46,730
93,033
3,244
Comm.
Fishing
58
117
325
1,997
15,542
26,512
145
Large
Ferries
99
374
498
1,451
3,216
9,149
118
Large
Cruise
Ship
391
8,767
33,094
53,526
81,984
101,415
127
Med.
Cruise
Ship
99
395
1,147
4,584
17,951
27,993
22
Research
82
174
682
1,780
2,925
5,606
81
Emerg.
70
94
488
563
2,711
7,905
56
Other8
9
189
3,904
15,939
27,681
43,286
12,241
Length
A summary of the statistical distribution of vessel length among vessels in the NOI is provided in
Table 2.4. Median length ranges from 200 feet for emergency vessels and barges to over 857 feet
for large cruise ships. Cruise ships are the longest vessels overall followed by oil and gas tankers.

Table 2.4. Statistical distribution of length (feet) of NOI vessels by vessel type.
Statistic
Minimum
10th Percentile
25t Percentile
Median
75th Percentile
90th Percentile
N (sample size)
Barges
14
190
195
200
200
264
20,256
Oil and
Gas
Tankers
27
412
577
620
818
1,034
3,274
Comm.
Fishing
65
114
147
265
554
628
146
Large
Ferries
91
139
180
260
364
583
118
Large
Cruise
Ship
142
477
713
857
962
1,021
127
Med.
Cruise
Ship
95
119
292
420
594
613
22
Research
87
124
187
224
283
321
77
Emerg.
64
96
156
194
286
322
55
Other
30
122
371
600
738
915
12,151
Age
Table 2.5 provides the distribution of the age of vessels by vessel type. The median age of all
vessel types is approximately 18 years old, ranging from six years for oil and gas tankers to 26
years for large ferries and emergency vessels. Oil and gas  tankers and large cruise ships tend to
be newer with 90 percent of these vessels equal to or less than 18 and 20 years old, respectively.
In contrast, large ferries tend to be older.
8 As discussed previously, "other" vessels comprise a wide variety of vessel types; hence, the summary statistics for
the "other" vessels have a wide distribution.
                                             12

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Summary of the VGP Vessel Universe
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Table 2.5. Statistical distribution of agea (years) of NOI vessels by vessel type.
Statistic
Minimum
10th Percentile
25th Percentile
Median
75th Percentile
90th Percentile
N (sample size)
Barges
1
4
9
15
29
33
20,307
Oil and
Gas
Tankers
1
2
3
6
12
18
3,267
Comm.
Fishing
1
7
12
23
32
38
146
Large
Ferries
1
7
12
26
42
54
118
Large
Cruise
Ship
1
3
7
11
16
20
127
Med.
Cruise
Ship
2
10
11
20
26
37
22
Research
2
8
14
23
34
42
81
Emerg.
3
18
18
26
35
43
56
Other
1
2
5
11
22
33
12,262
a Age determined by subtracting year built from 2011.
2.2.1.3 Dates of Dry Docking
Table 2.6 summarizes the time interval since the last drying docking for vessels by vessel type.
Among vessels that have been dry docked, the median length of time (in years) that elapsed since
the last dry dock is from 2 to 4 years with 3 years being the most common. The longest time that
elapsed since the last dry dock for any vessel was 37 years. Overall, the time since the last dry
dock is longest for barges. With the exception of barges, at least 90 percent of all other vessels
have been dry docked within the past 5 years.

Table 2.6. Statistical distribution of the time interval since the last dry docking by vessel
type (by years).
Statistic
Minimum
10th Percentile
25th Percentile
Median
75th Percentile
90th Percentile
Maximum
N (sample size)
Barges
1
2
2
4
6
9
23
6,943
Oil and
Gas
Tankers
1
2
2
3
4
5
7
1,507
Comm.
Fishing
1
2
2
3
4
4
28
135
Large
Ferries
2
2
2
3
3
5
37
111
Large
Cruise
Ship
2
2
3
3
4
5
7
93
Med.
Cruise
Ship
1
2
2
2
3
3
4
18
Research
1
2
2
3
4
4
6
80
Emerg.
2
2
3
3
4
5
7
56
Other
1
2
2
3
4
5
32
7,113
2.2.1.4 Home/Most Frequented Port and Geographical Area of Operation
The information submitted regarding home/most frequented port city9 and/or general geographic
area of operation varies greatly both between and within vessel types, and is summarized by
vessel type below.
9 Note here that vessels may not always operate in their home/most frequented port, or remain at their home/most
frequented port for significant intervals of time. Many vessels might travel/work between numerous ports. Because
it is difficult for EPA to discern which city listed in the NOI is the primary home/most frequented port city, when
more than one city was entered, the first city in the list was assumed to be the primary home/most frequented port
city.
                                             13

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Summary of the VGP Vessel Universe
March 2013
Barges
Information on home/most frequented port was provided for 15,641 barges, 11,480 of which
actually listed a specific city (equivalent to a 56 percent response rate for the 26,410 uniquely
identified barges in the NOT database), and is summarized in Table 2.7. Of the approximately
240 cities cited as home/most frequented port, New Orleans, LA and Jeffersonville, IN were the
most frequently listed (at 24 and 22 percent of barges, respectively).

The top 15  home/most frequented port cities are host to approximately 85 percent of the barges
(9,787). Of the top 50 home/most frequented ports, port cities along the Ohio River Valley are
host to 42 percent of the barges, followed closely by Gulf Coast cities (33 percent) and more
distantly by cities along the Mississippi River (10 percent) and Atlantic Coast (6 percent),
respectively. The distribution of barges by geographic region is provided in Figure 2.2-1.
Assuming most owners/operators listing home/most frequent port cities in the Gulf Coast region
have done so because their barges only operate along the Mississippi and Ohio Rivers, this
means up to 85 percent of covered barges are likely operating within the larger Mississippi-Ohio
River system.

Only 2 percent of barges (361 of 19,558 reported) travel beyond the U.S. EEZ and more than 200
nm from any shore. Similarly, only 2 percent of barges (344 of 19,595 reported) engage in
Pacific nearshore voyages. These 344 barges represent approximately three quarters of the total
number of barges where home/most frequented port city was provided as being on the West
Coast or Hawaii.

Table 2.7.  Top fifteen home/most frequent port cities for barges.
Home/Most Frequented U.S. Port
New Orleans, LA
Jeffersonville, IN
Pittsburgh, PA
St Louis, MO
Metropolis, IL/ Davant, LA
New York, NY
Cincinnati, OH
Houston, TX
Tuscaloosa, AL
Houma, LA
Ashland, KY
Boston, MA
Seattle, WA
Baton Rouge, LA
Grand Rivers, KY
Total other (non-descript) home ports:
Inland Waterway Systems-
Seaboard and Gulf Coast (ports)-
(Ports in) Coastal Waters-
Grand Total
# Vessels
2,771
2,513
981
823
675
353
277
242
229
197
191
153
147
124
111
4,161
4,117
24
20
15,641
                                           14

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Summary of the VGP Vessel Universe
                              March 2013
Figure 2.2- 1: Distribution of barges by geographic region.
                                                          10
                Southern inland, 70,
                     0.6%     ^ Other, 446, 3.9%
Atlantic Coast, 704,
     6.1%
        Pacific Coast and
        Hawaii, 427, 3.7%
  Ohio River Valley,
    4854, 42.3%
                                                          Gulf Coast, 3792,
                                                             .33.0%
                                                   Mississippi River
                                                  Basin, 1187, 10.3%
Oil and Gas Tankers
Table 2.8 summarizes the home/most frequented port for 2,350 oil and gas tankers reporting this
information. The top ten most commonly cited home/most frequented port cities are in the
following states: Texas, New York, California, Louisiana, and Pennsylvania (in order of
prevalence). Houston, Texas was the most common city, representing approximately 40 percent
of the total oil and gas tankers. Of the top 10 home/most frequented port cities, approximately 46
percent are from the Gulf Coast, nine percent are from the East Coast, and five percent are from
the West Coast. The top ten cities identified represent more than half of the entries listed under
home/most frequented port for oil and gas tankers.
  Geographic region assigned by EPA based on home/most frequented port city.

                                             15

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Summary of the VGP Vessel Universe
March 2013
Table 2.8. Top ten home/most frequented port cities for oil and gas tankers.
Home/Most Frequented U.S. Port
Houston, TX
New York, NY
Texas City, TX
Galveston, TX
Los Angeles, CA
New Orleans, LA
Long Beach, CA
Louisiana Offshore Oil Port
Philadelphia, PA
Lake Charles, LA
Total # Vessels for which Home Port was provided
# Vessels
811
183
74
70
70
55
49
36
34
32
2,350
Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from
any shore was provided for 3,114 oil and gas tankers.  Of those, 95 percent (2,966 of 3,114) were
reported to travel outside the U.S. EEZ. Twenty-four percent (627 out of 2,617 tankers) were
reported as being engaged in Pacific nearshore voyages.

Commercial Fishing Vessels
Information on home/most frequented port was provided for 84 commercial fishing vessels. The
top three most commonly cited port cities were Dutch  Harbor, AK; Seattle, WA and New
Orleans, LA. Of the 24 home/most frequented port cities, 54 percent are from the West Coast, 33
percent from the Gulf Coast, and five percent from the East Coast.

Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from
any shore was provided for 146 commercial fishing vessels. Of those vessels, 75 percent (110
vessels) were reported to travel outside the U.S. EEZ.  Only 23 percent (33 vessels) were reported
to engage in Pacific nearshore voyages.

Large Ferries
Table 2.9 summarizes the home/most frequented port for large ferries. The home/most
frequented ports of operation for 51 of 116 ferries (44  percent) are located along the Northeast
Atlantic coast, concentrated in the cities of New York, NY; Burlington, VT; Woods Hole, MA;
and Cape May, NJ. The highest home/most frequented port city listed for large ferries is Seattle,
WA, where 23 large ferries (20 percent) are located.
                                          16

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Summary of the VGP Vessel Universe
March 2013
Table 2.9. Home/most frequented port for large ferries.
Home/Most Frequented U.S. Port City
Seattle, WA
New York, NY
Burlington, VT
Woods Hole, MA
Cape May, NJ
Galveston, TX
Larkspur, CA
Cedar Island, NC
Juneau, AK
Ketchikan, AK
Hatteras, NC
Mobile, AL
New London, CT
Pittsburgh, PA
Port Hueneme, CA
Total # Vessels for which Home Port was provided
# Vessels
23
8
6
6
5
5
5
4
4
4
3
3
3
3
3
116
Figure 2.2-2 shows the distribution of large ferries by general geographic region of operation.

Figure 2.2- 2: Distribution of large ferries by geographic region.
          Area of Operation for Large Ferries
                                Geographic Area
Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from
any shore was provided for 118 large ferries. Of those, 10 were reported to travel outside the
U.S. EEZ, while 17 were identified as being engaged in Pacific nearshore voyages.
                                        17

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Summary of the VGP Vessel Universe
March 2013
Large Cruise Ships
Home/most frequented port cities for 67 of the 112 large cruise ships are located on the East
Coast of the United States. Fifteen of these vessels operate in and out of New York, NY and
three operate out of Boston, MA. Forty-seven of the large cruise ships have home/most
frequented ports listed along the Atlantic coast of Florida, primarily in Miami (17), Port
Everglades (11), Port Canaveral (9), and Fort Lauderdale (8). There are 17 large cruise ships
with port cities located along the West Coast, while eight ships have home ports along the Gulf
Coast. Thirteen large cruise ships have home ports located outside of the U.S. Home/most
frequented port was not listed by 15 respondents.  Figure 2.2-3 shows the distribution of large
cruise ships by primary area of operation.

Figure 2.2- 3: Primary area of operation reported for large cruise ships.
           Area of Operation for Large Cruise Ships
                                 Geographic Area
Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from
any shore was provided for 114 large cruise ships. Of those, 84 (74 percent) were reported to
travel outside the U.S. EEZ while 34 were engaged in Pacific nearshore voyages.

Medium Cruise Ships
The home/most frequented ports listed for six of the 22 medium cruise ships were located along
the Florida coast. Four ships operate along the Northeast Atlantic Coast in New York City, NY,
Boston, MA and Newport, RI. Four medium cruise ships operate  along the Alaskan and
Hawaiian coasts and two operate in the Caribbean. Figure 2.2-4 shows the distribution of
medium cruise ships by primary area of operation.
                                          18

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Summary of the VGP Vessel Universe
March 2013
Figure 2.2- 4: Primary area of operation for medium cruise ships.
        Area of Operation for Medium Cruise
                             Ships
                               Geographic Area
Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from
any shore was provided for 19 medium cruise ships. Thirteen of the 19 medium cruise ships (68
percent) travel outside the U.S. EEZ and only four are reported to engage in Pacific nearshore
voyages.

Research Vessels
Table 2.10 provides information on the home/most frequented port information, for which 70 of
the 82 research vessels (85 percent) provided information. Eleven vessels listed Seattle, WA as
their home/most frequented port city, followed by Galveston, TX (8) and Honolulu, HI (6). A
total of 33 U.S. cities were listed, of which 20 were listed as home/most frequented port for only
a single vessel. The seven cities listed in Table 2.10 account for 41 of the 70 (59 percent)
research vessels.

Table 2.10. Top seven home/most frequented port cities for research vessels.
Home/Most Frequent U.S. Port
Seattle, WA
Galveston, TX
Honolulu, HI
Guam
Houston, TX
Pascagoula, MS
Tampa, FL
Total # Vessels for which Home Port was provided
# Vessels
11
8
6
5
5
3
3
70
Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from
any shore was provided for 79 research vessels: 67 of these (85 percent) traveled outside the U.S.
EEZ and 33 engaged in Pacific nearshore voyages.
                                         19

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Summary of the VGP Vessel Universe
March 2013
Emergency Vessels
Information on home/most frequented port city was provided for 55 of the 56 emergency vessels,
which included a total of 34 different U.S. cities/ports. Only three cities (Galveston, TX, Long
Beach, CA, and Port Angeles, WA) were reported to have four or more covered emergency
vessels.

A total of 50 of the 56 emergency vessels (89 percent) reported travelling beyond the U.S. EEZ,
and 42 (75 percent) reported engaging in Pacific near shore voyages.

Other Vessels
Information on home/most frequented port was provided for a total of 8,323 "Other" vessels,
6,356 of which provided a specific  city. While a number of responses contained multiple
home/most frequented cities, a total of 212 unique cities were identified. New Orleans, LA was
the highest ranking home/most frequented port (22 percent), followed by Houston, TX (10
percent) and Los Angeles, CA (6 percent). The top 10 home/most frequented port cities account
for over 61 percent of the "Other" vessels (Table 2.11). On a regional basis, the Gulf Coast
accounts for 49 percent of the home/most frequented ports, followed by the Northeast coast (16
percent) and Southwest coast (12 percent). Inland ports accounted for seven percent of
home/most frequented ports, while  Alaskan and Hawaiian cities each accounted for less than one
percent.

Table 2.11. Top 10 Home/most frequented port cities for "Other" vessels.
Home/ Most Frequent US Port
New Orleans, LA
Houston, TX
Los Angeles, CA
New York, NY
Port Fourchon, LA
Long Beach, CA
Baltimore, MD
Seattle, WA
Norfolk, VA
Houma, LA
# Vessels
1,405
669
400
347
225
214
176
176
163
152
Information about whether the vessel travels beyond the U.S. EEZ and more than 200 nm from
any shore was provided for 11,627 "Other" vessels: 9,105 (over 78 percent) were reported to
travel outside the U.S. EEZ. Permittees reported 2,272 "Other" vessels (out of 9,659 responses)
were engaged in Pacific nearshore voyages.
                                          20

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Summary of the VGP Vessel Universe
March 2013
2.2.1.5 Crew and Passengers

Table 2.12 provides a summary of the maximum crew and passenger capacity for vessels having
submitted an NOT. As shown, the large/medium cruise ships and large ferries have a greater
capacity for persons (includes crew and passengers) onboard than other vessel types. The
maximum number of people (crew and passengers) aboard large cruise ships and ferries is at
least an order of magnitude greater than for any other vessel type. Barges, on the other hand, tend
to operate with fewer persons on board, and are assumed to be unmanned in many cases. The
majority of barge operators (approximately 6,900) did not list any information for maximum
capacity. EPA assumes that these barges are unmanned and/or unpowered, and that a blank
response likely meant "zero persons." The distribution of maximum persons aboard any given
type of vessel is graphically displayed in Figures 2.2-2 and 2.2-6.

Table 2.12. Summary statistics of maximum crew and passenger capacity for vessels having
submitted an NOI.
Statistic
Minimum
25th percentile
Median
75th percentile
Maximum
# Non-zero
Responses
Barge11
1
2
4
20
336
284
Comm.
Fishing
4
11
22
35
192
78
Oil and
Gas
Tankers
2
25
29
32
70
2,530
Large
Ferries
8
307
559
1,042
6,012
115
Large
Cruise
Ships
560
1,900
3,455
4,200
8,460
113
Med.
Cruise
Ships
95
208
315
557
800
19
Research
5
33
41
60
150
81
Emerg.
6
16
16
50
56
53
Other
2
20
25
30
6,014
9,129
11 EPA notes that more than 6,900 owners/operators of barges did not submit any information on the maximum
number of persons. As discussed above, since the vast majority of barges are unmanned, EPA assumes that barges
that did not respond are unmanned.
                                           21

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Summary of the VGP Vessel Universe
                             March 2013
Figure 2.2- 5: Distribution of maximum persons (crew and passengers) aboard vessels of a
given type.
      Maximum Passengers and Crew aboard
                    Barges
                  Maximum # of Persons
      Maximum Passengers and Crew aboard
           Commercial Fishing Vessels
                 6-10

                  Maximum # of Persons
      Maximum Passengers and Crew aboard
               Large Cruise Ships
               600-1,000   1,001-1,500  1,501-2,500 2,501 o

                   Maximum # Persons
Maximum Passengers and Crew aboard
         Oil and Gas Tankers
                                                                       Maximum # of Persons
Maximum Passengers and Crew aboard
           Large Ferries
         600-1,000  1,001-1,500  1,501-2,500 2,501 o

             Maximum # Persons
Maximum Passengers and Crew aboard
        Medium Cruise Ships
   0-50     51-100    101-150    151-250

            Maximum # of Persons
                                                 22

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Summary of the VGP Vessel Universe
                           March 2013
Figure 2.2- 6: Distribution of maximum persons (crew and passengers) aboard vessels of a given
type (continued).
      Maximum Passengers and Crew aboard
               Research Vessels
                6-10
                       11-15    16-25

                 Maximum # of Persons
                                     26 or more
Maximum Passengersand Crew aboard
         Emergency Vessels
          6-10     11-15    16-25    26 or more

           Maximum # of Persons
      Maximum Passengers and Crew aboard
                 Other Vessels
                 6-10
                        11-15
                               16-25
                  Maximum # of Persons
                                               23

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Summary of the VGP Vessel Universe
March 2013
2.2.2  Ballast Water and Related Information

2.2.2.1 Ballast Water Capacity
Table 2.13 provides a summary of ballast water capacity12 for vessels within the NOT database.
Oil and gas tankers possess substantially greater ballast water capacity (median capacity of
23,893 m3) compared to other vessel types. Vessels designated as "Other" in the NOT database
tend to have a much larger ballast capacity (median ballast capacity is 10,198 m3) than for
vessels specifically identified by type, reflecting the large number of cargo carriers sub-classified
under "Other" by respondents (see section 2.2.1.1 of this document).

Table 2.13. Statistical summary of ballast capacity for vessels in the NOI.
Statistic
Minimum
10th Percentile
25th Percentile
Median
75th Percentile
90th Percentile
N (sample size)
Barges
0.76
143
166
206
1,030
1,665
4,849
Oil and
Gas
Tankers
34
4,279
17,049
23,893
42,350
68,306
2,650
Comm.
Fishing
0.09
41
168
1,388
6,775
25,756
129
Large
Ferries
17
32
97
404
1,631
9,141
43
Large
Cruise
Ship
19.4
752
2,151
3,136
4,334
6,563
105
Med.
Cruise
Ship
9
33
204
364
742
2,043
17
Research
14
79
206
425
814
2,278
72
Emerg.
12
36
200
332
552
14,775
37
Other
1
83
1,710
10,198
23,497
34,405
9,587
The relationship between vessel tonnage and ballast water capacity is compared to the
relationship between vessel length and ballast water capacity in Figure 2.2-3 through Figure
2.2-4. Overall, vessel tonnage is a slightly better predictor of ballast water capacity than length
except for emergency vessels. Note: the distribution of ballast water capacity displayed in the
figures has been truncated as appropriate to eliminate the influence of obvious outliers (as
discussed in section 1.3 of this document).
12 All values for ballast water capacity here and throughout this document have been converted to cubic meters (m3)
assuming 1 m3 equals 264.17 gallons.
                                            24

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Summary of the VGP Vessel Universe
March 2013
Figure 2.2- 7: Relationship between vessel tonnage (GT) and ballast water capacity for
vessels identified in the NOI database.
100,0
sr 10,0
o" 1,0
s.
CO
u 1
"co
m
Barge Tonnage vs BallastCapacity
*• * *
JU -djnpTy^Tjp*^
^VJEtaEt^J*^
- f?fiPv^r *
»« t»» •*

100 1,000 10,000 100,000
Vessel Tonnage (GT)

Commercial Fishing Vessel Tonnagevs Ballast Capacity

—
<»v-A
rv**^***
« ^rV^?*
^<*^» \u

10 100 1,000 10,000 100,000
Vessel Weight (GT)

Large Cruise Ship Tonnagevs Ballast Capacity


CO '
Q_
CO
u 10o

m 10 -

tj&lf*
^^^^^
•

100 1 ,000 10,000 100,000 1 ,000,000
Vessel Tonnage (GT)



1000
— 100
E
O
500
500
£. 10000
S
g- 1000
o
CA
™
TO
m
00
10
1
1
il and Gas TankerTonnagevs Ballast Capacity
+* **&**
^BB^^»»

^pPl *
+~-^~^ »*
» »





50 1,000 10,000 100,000 1,000,000
Vessel Tonnage (GT)

100,0
_ 10,0
«
1 1'°
1 1
CO
u
1
CO
m
Large Ferry Tonnagevs. BallastCapacity


nn -


+ J^"
»* H^**^* *
	 <^ 	 < 	



1 10 100 1,000 10,000 100,000
Vessel Tonnage (GT)




co 1UU
Q.
CO
H 10
=
TO
m ^
Medium Cruise Ship Tonnage vs. Ballast Capacity
J>
** ^^-^>
J^*^^ *
	 + 	


10 100 1,000 10,000 100,000
Vessel Tonnage (GT)
                                         25

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Summary of the VGP Vessel Universe
March 2013
Figure 2.2- 8: Relationship between vessel tonnage (GT) and ballast water capacity for
vessels identified in the NOI database (continued).
          Research Vessel Tonnage vs Ballast Water Capacity
                   100         1,000

                     Vessel Tonnage (GT)
            Other Vessel Tonnage vs. BallastCapacity
                    100   1,000   10,000  100,000 1,000,000
                      Vessel Tonnage (GT)
Emergency Vessels Tonnage vs. Ballast Capacity

&
a.
u 1U
"«
_ro
"ro
» * * * » » <
•» » » I
*•


10 100 1,000 10,000 100,000
Vessel Tonnage (GT)
                                                26

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Summary of the VGP Vessel Universe
March 2013
Figure 2.2- 9: Relationship between vessel length and ballast water capacity for vessels
identified in the NOI database.
Ballast Capacity (m3)
^ 3 8
-> o o o
-^ o o o o
Barge Length vs Ballast Capacity

' lilt^fir^
I *-«^!| Up! *
* «•***•! *
« *

10 100 1,000
Vessel Length (feet)

Com
1,000,000
f 100,000
8 10,000
1
J2 1 ,000
JS
m 100
10
mercial Fishing Vessel Length vs Ballast Capacity
x
* 2^
• X^
^^

0 100 1,000 10,000
Vessel Length (feet)

Large Cruise Ship Length vs Ballast Capacity


Q.
TO
o 100 _
m 10 -


'
,,
/ »

10 100 1,000 10,000
Vessel Length (feet)

10,000,00
_ 1,000,00
~ 100,00
1 10,00
Q.
o 1,00
ffi
^ 10
TO
1
Oil and Gas Tanker Length vs Ballast Capacity



*• 4r*
° /t +



10 100 1,000 10,000
Vessel Length (feet)

Ballast Capacity (m3)
-, 3 8
->• O O O
-*• O O O O
-=•00000
Large Ferry Length vs. Ballast Capacity

* +^<>
*<£&
^^ A


0 100 1,000
Vessel Length (feet)

Medium Cruise Ship Length vs. Ballast Capacity

'o
CO
U
« 10
CO
m
*
^^^ ^



10 100 1,000
Vessel Length (feet)
                                         27

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Summary of the VGP Vessel Universe
March 2013
Figure 2.2-10: Relationship between vessel length and ballast water capacity of for vessels
identified in the NOI database (continued).
           Research Vessel Length vs Ballast Capacity
                       1,000      10,000      100,000
                    Vessel Length (feet)
         OtherVessel Length vs. Ballast Capacity
                     100    1,000
                    Vessel Length (feet)
                                10,000
                                      100,000
Emergency Vessel Length vs. Ballast Capacity
J

u
"w
m
• #•«$


4


10 100 1,000 10,000
Vessel Length (feet)
2.2.2.2 Ballast water management, tank cleaning, and sediment disposal
Ballast Water Management
Responses on the NOI regarding whether a vessel has a ballast water management plan (BWMP)
is summarized by vessel type in Table 2.14. Nearly all oil and gas tankers, most large cruise
ships, and vessels designated as "Other" indicated having a BWMP.  Most large ferries indicated
in their NOI that they did not have a BWMP. Approximately half (50 percent) of barges did not
identify whether they had a BWMP.

Table 2.14. Percentage of vessels within a given type where use/non-use of a ballast water
management plan (BWMP) has been indicated.
Existing BWMP?
Yes
No
Not Indicated
Barges
23%
27%
50%
Oil and
Gas
Tankers
98%
1%
1%
Comm.
Fishing
82%
13%
5%
Large
Ferries
15%
78%
7%
Large
Cruise
Ship
91%
8%
1%
Med.
Cruise
Ship
73%
27%
0%
Research
78%
6%
16%
Emerg.
88%
12%
0%
Other
91%
7%
2%
Tank Cleaning Frequency
Responses on NOIs regarding the frequency of ballast tank cleaning vary widely as summarized
in Table 2.15. The frequency of ballast tank cleaning for most vessels occurs every 1 to 5 years
and coincides with dry docking. Notable exceptions include large cruise ships, where ballast
tanks are cleaned more frequently (less than one year), and barges, where ballast tanks are rarely
cleaned. The frequency of ballast tank cleaning varies most within oil and gas tankers.
                                            28

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Summary of the VGP Vessel Universe
March 2013
Table 2.15. Summary of the frequency of ballast tank cleaning for vessel types (Values
reflect percentage of vessels for which a response was provided).
Frequency
Every 5 years or more
(i.e., rarely)
Other (periodical,
mostly at dry dock)
Every 1 to 5 years
Less than 1 year
Every voyage
Not applicable/
No Ballast
Total # Respondents
Barges
47%
30%
1%
1%
0%
21%
7,427
Oil and
Gas
Tankers
2%
42%
29%
23%
2%
2%
2,554
Comm.
Fishing
14%
19%
45%
9%
0%
13%
127
Large
Ferries
0%
27%
25%
0%
0%
48%
69
Large
Cruise
Ship
14%
14%
26%
41%
0%
5%
105
Med.
Cruise
Ship
6%
38%
12%
19%
0%
25%
16
Research
16%
19%
23%
31%
0%
11%
74
Emerg.
9%
10%
77%
2%
0%
2%
56
Other
11%
54%
21%
10%
0%
4%
8,724
Sediment Disposal
Ballast water sediment disposal methods by vessel type are summarized in Table 2.16. Ballast
water sediment disposal for most vessels occurs onshore at shipyards via a third party during dry
docking. Large and medium cruise ships, oil and gas tankers, and "Other" vessels also identified
offshore/overboard  ballast sediment disposal as a commonly used method (Figures 2.2-11 and
2.2-12).

Table 2.16. Summary of ballast water sediment disposal methods for vessel types (Values
reflect percentage  of vessels for which a response was provided).
Methods
Onshore at shipyards
via third party
Onshore/Landfill
Onshore or Offshore
Offshore/overboard
Not applicable/
No Ballast
Total # Respondents
Barges
78%
0.2%
0%
0.8%
21%
6,950
Oil and
Gas
Tankers
37%
4%
19%
37%
3%
2,521
Comm.
Fishing
81%
0%
0%
6%
13%
123
Large
Ferries
50%
2%
0%
6%
42%
62
Large
Cruise
Ship
72%
0%
10%
18%
0%
97
Med.
Cruise
Ship
49%
0%
13%
19%
19%
16
Research
55%
2%
7%
8%
28%
74
Emerg.
84%
4%
4%
5%
3%
56
Other
70%
0%
7%
16%
7%
8,529
                                          29

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Summary of the VGP Vessel Universe
                               March 2013
Figure 2.2-11: Sediment disposal methods based on NOI submittals.
              Barge Sediment Disposal Methods
Oil and Gas Tanker Sediment Disposal Methods
                                                                   1   Not
                                                                    applicable/bkl
                                                                    Ballast, 3, 3%
                                                                                                     Onshore/Landfill,
         Commercial Fishing Vessel Sediment Disposal
                        Methods
  :  Onshore
   Offshore, 0,0%
   Large Ferry Sediment Disposal Methods
                                                                             ]  Onshore o
                                                                              Offshore, 0,0%
                             Onshore/Landfill,
                                 2,2%
         Large Cruise Ship Sediment Disposal Methods
  I Onshore/Landfill,
      0,0%
Medium Cruise Ship Sediment Disposal Methods
                                                                 1     Not
                                                                   applicable/No
                                                                  Ballast, 19, 1
                                                                                                      Onshore/Landfill,
                                                                                                         0,0%
                                                        30

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Summary of the VGP Vessel Universe
                                   March 2013
Figure 2.2-12: Sediment disposal methods based on NOI submittal (continued).
         Research Vessel Sediment Disposal Methods
  :  Offshore/
  overboard,8,
         I Onshore/Landfill,
             0,0%
         "Other" Vessel Sediment Disposal Methods
  1 Onshore/Landfill,
      0,0%
       Emergency Vessel Sediment Disposal Methods
         •   Not
           applicable/No
D  Offshore/   Ballast, 3,:
 overboard, 5,5
                                                   31

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Summary of the VGP Vessel Universe                                        March 2013


2.2.2.3 Experimental ballast water treatment systems and discharge of residual biocides
The use of an experimental ballast water treatment system that results in the discharge of residual
biocides was indicated by 26 vessels (two oil and gas tankers, one medium cruise ship, and 23
"Other" vessels). One oil and gas tanker reported a residual discharge of bi-sulfite (the other oil
and gas tanker did not provide information on discharge type), and the medium cruise ship
reported a residual discharge of sodium hypochlorite.

Of the 23 "Other" vessels, five of them were cargo carriers and 18 were an unspecified subtype.
Information on the type of residual biocide present in the discharge was provided for only one of
the 23 vessels. The residual biocide discharged was total residual chlorine.

2.2.3   Applicable Discharges and Related Information

2.2.3.1 Applicable discharges
The 2008 VGP NOT identified 26 types of vessels discharges. Table 2.17 provides a rank of the
vessel discharges reported by vessel type (from high to low). The five most prevalent discharges
for each type of vessel are indicated by light gray shading and bold type font. Deck  washdown
and runoff is reported as a top five discharge in all nine vessel types/categories.  Anti-fouling
hull coatings is a top five discharge in seven vessel types/categories, followed by cathodic
protection and ballast water (6 vessel types/categories each), firemain systems (5), seawater
cooling overboard discharge (4), bilgewater/oily water separator effluent (3), and graywater (2).
Aqueous film forming foams (AFFF) is a top five discharge in emergency vessels, while
underwater ship husbandry and welldeck discharges are top five discharges in barges (Table
2.17). The top  10 discharges of the "Other" vessel type/category largely reflect those reported for
cargo carriers.
                                           32

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Summary of the VGP Vessel Universe                                      March 2013
Table 2.17. Percentage of vessels where the applicable discharge listed is reported.
(Note: the 26 applicable discharges listed represent the possible discharges listed on the 2008 VGP NOI. The top five applicable discharges
for each NOI vessel type are shaded.)
Applicable discharge Type
Ballast Water
Seawater Cooling Overboard Discharge
Deck Washdown and Runoff
Graywater
Firemain Systems
Chain Locker Effluent
Bilgewater/Oily Water Separator Effluent
Boiler/ Economizer Slowdown
Cathodic Protection
Anti-fouling Hull Coatings
Refrigeration and Air Condensate Discharge
Distillation or Reverse Osmosis Brine
Non-oily Machinery Wastewater
Aqueous Film Forming Foams
Small Boat Engine Wet Exhaust
Underwater Ship Husbandry
Controllable Pitch Propeller Hydraulic Fluid
Seawater Piping Biofouling Prevention
Exhaust Gas Scrubber Washwater Discharge
Graywater Mixed with Sewage
Freshwater Layup
Gas Turbine Wash Water
Welldeck Discharges
Motor Gasoline and Compensating Discharge
Elevator Pit Effluent
Sonar Dome Discharge
Percentage of owners/operators responding
Barges
29%
<1%
99%
<1%
<1%
<1%
25%
<1%
9.4%
5.3%
<1%
<1%
2.6%
<1%
<1%
26%
<1%
<1%
<1%
1 .4%
<1%
<1%
22%
<1%
<1%
<1%
96%
Oil and
Gas
Tankers
99%
97%
97%
97%
95%
90%
89%
89%
88%
87%
82%
72%
71%
68%
67%
64%
64%
60%
56%
53%
35%
22%
17%
13%
11%
3.3%
82%
Comm.
Fishing
87%
53%
67%
59%
59%
51%
23%
7.2%
54%
55%
54%
5.8%
16%
9.4%
9.4%
10%
12%
3.6%
2.2%
48%
8.7%
2.2%
2.9%
2.2%
<1%
<1%
95%
Large
Ferries
28%
73%
98%
28%
91%
25%
38%
24%
82%
82%
48%
3.4%
38%
50%
42%
12%
42%
10%
3.4%
29%
15%
4.3%
7.8%
4.3%
19%
4.3%
98%
Large
Cruise
Ship
90%
96%
99%
65%
96%
62%
58%
58%
95%
90%
85%
85%
55%
51%
76%
76%
82%
73%
30%
54%
32%
27%
28%
27%
42%
27%
89%
Med.
Cruise
Ship
74%
100%
95%
79%
95%
68%
68%
63%
100%
95%
79%
58%
68%
37%
63%
58%
79%
16%
11%
53%
26%
0%
16%
5.3%
37%
0%
86%
Research
82%
15%
90%
29%
24%
73%
87%
29%
80%
88%
16%
13%
5%
54%
9%
1%
73%
0%
0%
4%
5%
0%
4%
0%
1%
4%
100%
Emerg.
96%
2%
96%
48%
11%
57%
57%
9%
95%
91%
4%
0%
5%
82%
4%
34%
54%
2%
0%
2%
2%
2%
0%
2%
0%
0%
100%
Other
94%
14%
96%
35%
41%
72%
85%
61%
82%
78%
19%
12%
13%
43%
3.5%
2.5%
55%
1.1%
<1%
4.5%
9%
1 .6%
1 .4%
1 .3%
1 .3%
0%
80%
                                                                33

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Summary of the VGP Vessel Universe
March 2013
2.2.3.2 Onboard treatment systems for generated waste streams
Indication of onboard treatment systems and the corresponding treated waste stream is summarized in Table
2.18. The majority of oil and gas tankers and large cruise ships (approximately 80 percent) have onboard
treatment systems of some type. Many of these vessels have multiple treatment systems for a variety of waste
streams. The most common generated waste streams were oily water, bilgewater and sewage/sanitary water.
Very few barges reported having onboard treatment systems for generated waste streams.
                      13
Within the large subset of "Other" vessels sub-classified as cargo carriers, approximately 88 percent (1,774 of
2,044) reported an onboard treatment system. The type of waste stream treated was identified by 1,607 cargo
carriers (79 percent). The most prevalent waste stream treated aboard bulk cargo carriers was oily water (82
percent), followed by sewage/sanitary water (54 percent). Bilgewater was reported at 28 percent (see footnote
"a" in Table 2.18 below).

Table 2.18. Presence of onboard treatment systems per vessel type and a summary of the types of
generated waste streams that were treated
(Note: values reflect the number of vessels responding with the percentage for that class of vessels in
parentheses).
Onboard Treatment
Systems?
No
Yes
Total # Respondents
(Percent)
Barges
18,970
(93)
114
(D
19,084
(94)
Oil and
Gas
Tankers
156
(5)
2,551
(78)
2,707
(83)
Comm.
Fishing
82
(56)
60
(41)
142
(97)
Large
Ferries
65
(55)
53
(45)
118
(100)
Large
Cruise
Ship
14
(11)
100
(79)
114
(90)
Med.
Cruise
Ship
8
(36)
11
(50)
18
(82)
Research
16
(20)
64
(78)
80
(98)
Emerg.
32
(57)
24
(43)
56
(100)
Other
2,377
(19)
7,586
(61)
9,963
(80)
Type of Generated Waste Stream and the Corresponding Number (#) of Vessels that Treated it.
Unspecified/Response
Not provided
Wastewater (AWS)
Graywater
Sewage/Sanitary
Oily water3
Bilgewater3
Sludge
Lube oil separator
Incinerator
Seafood processing
waste
65
17
11
10
13
3
0
0
0
0
1,361
79
44
629
1,413
500
0
0
0
0
19
0
2
4
31
8
0
0
0
2
42
0
7
8
0
1
0
0
0
0
13
18
17
18
36
53
1
1
0
0
3
0
2
3
3
6
0
0
0
0
50
0
2
14
26
11
2
0
2
0
21
0
1
1
0
3
0
0
0
0
2,370
0
351
2,433
3,926
1,588
0
0
218
0
AWS = Advanced Wastewater System.
3 Though oily water and bilgewater are generally considered the same waste stream generated/treated aboard vessels, these waste streams are listed
separately in this table to reflect the actual description provided by NOI respondents.
13 As discussed in Part 1.2.3.2 of the VGP, discharges of sewage are regulated under section 312 of the CWA and do not require an
NPDES permit.
                                                   34

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Summary of the VGP Vessel Universe
March 2013
2.2.4  Anti-fouling Hull Coatings and Related Information

2.2.4.1 Type of coating
Table 2.19 provides a summary of anti-fouling hull coatings used on vessels.  With the exception of barges, the
use of an anti-fouling hull coating was reported for 80 percent or more of vessels. Most were organotin-free,
copper-based anti-fouling paints that are compliant with current EVIO regulations (e.g., International
Interclene™ 245 or International Intersmooth™ 640, Ameron™ ABC #3, Hempel Olympic™ 7660). In a
limited number of instances, the hull coating reported was "anti-foulant free"  epoxy coating.

Of the 12,401 vessels categorized as "Other" in the NOI database, 42 percent (5,155) reported the application of
a tributyltin (TBT)-free anti-fouling hull coating, while 24 percent indicated a copper-based anti-fouling paint
used to coat the hull of their vessel.

Table 2.19. Summary of anti-fouling hull coatings used on vessels as reported on the vessels' NOIs. (Note:
values reflect the total number of vessels for which a response was provided, with the corresponding
percentage within a class of vessels in parentheses).
Anti-fouling Hull
Coating?
No
Yes
Uncertain
Total # Respondents
(Percent of total)
Barges
8,542
(42)
838
(4)
149
(<1)
9,529
(47)
Oil and
Gas
Tankers
8
(0.2)
2,630
(80)
21
(0.6)
2,659
(81)
Comm.
Fishing
10
(7)
124
(85)
0
135
(92)
Large
Ferries
13
(11)
102
(86)
1
(0.8)
116
(98)
Large
Cruise
Ship
0
107
(84)
3
(2)
109
(86)
Med.
Cruise
Ship
0
18
(82)
1
(5)
19
(83)
Research
2
(3)
78
(95)
0
80
(98)
Emerg.
2
(4)
54
(96)
0
56
(100)
Other
912
(8)
8,072
(65)
539
(4)
9,523
(77)
2.2.4.2 Anti-fouling hull coating application and hull husbandry practices
Hull Coating Applications
Table 2.20 provides a summary of the number of years since the last anti-fouling hull coating was applied.
With the exception of barges, most vessels (90 percent) received an anti-fouling hull coating within the last
three to five years. The shortest median time interval between hull coatings was two years for medium cruise
ships, and the longest was 5 years for barges.  The longest overall time interval between hull coatings was 81
years for a barge built in 1930.

The date of last application of anti-fouling coating and last dry dock coincide for a large portion of vessels (e.g..
approximately 43 percent of oil and gas tankers and bulk cargo carriers and 70 percent of barges).
                                                  35

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Summary of the VGP Vessel Universe
March 2013
Table 2.20. Summary statistics de
Statistic
Minimum
10th Percentile
25th Percentile
Median
75th Percentile
90th Percentile
Maximum
N (sample size)
Barges
1
2
3
5
8
11
81
2,011
Oil and
Gas
Tankers
1
2
2
3
4
5
19
2,606
picting number of years since last anti-fouling hull coating was applied
Comm.
Fishing
1
2
2
3
4
4
12
127
Large
Ferries
1
2
2
3
4
5
37
117
Large
Cruise
Ship
1
2
3
3
4
5
7
109
Med.
Cruise
Ship
1
2
2
2
3
3
4
18
Research
1
2
2
3
4
5
6
80
Emerg.
2
2
3
4
4
6
7
23
Other
1
2
2
3
4
5
68
8,805

Table 2.20, depicting the number of years since last anti-fouling hull coating at the time of NOT coverage, is
consistent with Table 2.21 showing the frequency with which hull husbandry practices were employed. Most
vessels for which NOT data are available are cleaned at either a dry dock, every 2 to 5 years, or as needed. EPA
categorized the information received into hull husbandry practices done in association with dry docking and
hull husbandry practices not done in association with dry docking.

Table 2.21. Summary of the frequency with which hull husbandry practices are utilized for vessels.
(Values represent actual number of responses)
Frequency
Barges
Oil and
Gas
Tankers
Comm.
Fishing
Large
Ferries
Large
Cruise
Ship
Med.
Cruise
Ship
Research
Emerg.
Other
Frequency of hull husbandry practice employed not associated with dry dock
Annual (or less)
Every 2 to 5 years
Less than once per 5
years
As needed
12
183
82
233
75
201
33
256
0
64
0
0
6
7
0
4
25
23
0
3
3
0
0
4
10
7
0
1
2
6
0
1
294
901
0
1,530
Frequency of dry docks when hull husbandry practices employed
At dry dock
unspecified
Annual (or less)
Every 2 to 5 years
Less than once per 5
years
As needed
378
0
84
15
5
960
75
414
109
49
22
1
25
1
2
25
0
20
0
0
11
0
18
0
10
5
0
7
0
0
24
0
27
0
3
2
0
42
1
1
3,361
6
1,154
0
290
Hull Husbandry Practices
Table 2.22 highlights some of the more common hull husbandry practices for NOT vessels and the number of
respondents who listed them. The most common practices include the use of power washing or a
scraping/power washing/sand blasting combination, after which the anti-fouling coating is re-applied, as
needed.
                                                 36

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Summary of the VGP Vessel Universe
                          March 2013
Table 2.22. Summary of hull husbandry cleaning practices for NOI vessels
(Note: values represent actual number of responses).
14
Practice
Power washing only
Power washing +
sand blasting
Sand blasting only
Scraping + power
washing
Scraping only
Scraping + sand
blasting
Scraping, power
washing and/or sand
blasting
Hosed off with water
only
Light scraping/
Scrubbing with or w/o
Detergent
Underwater Divers
Other
Contingent on
Shipyard practice
Barges
523
141
137
55
21
19
13
6
3
0
0
0
Oil and
Gas
Tankers
992
0
294
0
381
0
0
0
0
0
225
170
Comm.
Fishing
31
0
4
0
4
0
14
0
0
0
1
0
Large
Ferries
21
15
7
0
0
0
0
1
3
1
0
0
Large
Cruise
Ship
12
2
4
0
0
0
0
6
33
24
0
0
Med.
Cruise
Ship
3
3
0
0
0
0
0
1
4
1
0
0
Research
14
6
6
4
5
5
1
2
0
0
0
0
Emerg.
45
3
0
0
0
0
0
0
0
0
0
0
Other
1,723
1,630
771
106
64
81
112
79
126
566
380
0
2.3   Characterization of Vessels with Missing Information
The NOI database includes data for 43,431 vessels with an active or certified NOI status, 6,468 of which have
missing tonnage and/or ballast water capacity information. This section of the document characterizes the 6,468
vessels with incomplete NOIs using information from other data sources.

2.3.1   Data Sources
A primary data source on vessel population characteristics is the U.S. Coast Guard's MISLE database (USCG,
2009) which contains a wide range of information on vessel characteristics, accidents, marine pollution
incidents, and other pertinent information tracked by the U.S. Coast Guard. The database has a broad scope and
encompasses information on vessels covered in other public data sources such as the U.S. Coast Guard's
Merchant Vessels of the United States (VESDOC) data file for documented vessels and the U.S. Army Corps of
Engineers' Waterborne Transportation Lines of the US (WTLUS) data.

Nearly one million vessels that operate in U.S. waters are included in the MISLE database with vessel data
including:
•  Identification number(s)
•  Vessel category (e.g., class, type, subtype, service)
•  Size (e.g., weight, length, breadth,  depth)
•  Area of operation (e.g., hailing port, route type)
•  Passenger and crew capacity
•  Propulsion (i.e., method, engine type, and horsepower)
•  Construction material and design (e.g.,  hull material, design type, hull configuration/shape)
•  Year built or age
14 The number of hull husbandry practices used may be underrepresented. When respondents listed multiple practices on their NOI,
only the first listed practice was used for this data set.
                                                  37

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Summary of the VGP Vessel Universe                                         March 2013
In compiling MISLE data, the U.S. Coast Guard largely relies on documents submitted by vessel owners or
operators in accordance with vessel documentation requirements (e.g., certificate of documentation) or on
information gathered by U.S. Coast Guard staff directly (e.g., during inspections, vessel boardings, or accident
investigations). The scope of the data included in MISLE is driven in part by the regulatory requirements to
which different types of vessels are subject and by activities conducted by U.S. Coast Guard offices. Therefore,
MISLE is generally most comprehensive for those vessels that are documented, state registered, and/or subject
to inspection requirements. Thus, the vessels in the MISLE  database are often times the same vessels that are
required to submit a completed NOI for coverage under the  VGP. This overlap helped EPA bolster NOI forms
that were submitted with missing or incomplete information.

The U.S. Coast Guard maintains a separate database, the NBIC, with information from ballast water reports
submitted by all ballast tank-equipped vessels entering U.S. waters. The information provided in NBIC
includes:
•  Vessel name
•  Vessel category (e.g. class, type, subtype, service)
•  Area of operation (hailing port, or state)
•  Route information (arrival date and last port at which the vessel was called)
•  Information on ballast water management practices (e.g., ballast capacity, volume discharged).

EPA obtained NBIC data on foreign and domestic flag arrivals to U.S. ports during calendar year 2005. These
data were used to estimate the economic benefits of the final VGP (Abt Associates, 2008). When the MISLE
data failed to fully complete the missing information on a vessel's NOI, NBIC data were used to fill in data
gaps where possible.

2.3.2   Methodology
EPA used the Call Sign, Primary VIN, and IMO Number fields to match NOI data to entries in the MISLE
database.15 Entries listed as blank, "N/A,"  "None," "na,"  or "Unknown" in the NOI form were not compared to
the database.

For the vessels in the NOI database where information is  incomplete, EPA used the information from MISLE
only if the MISLE record was deemed sufficiently reliable based on the matched information.16 In general, data
compared between the NOI and MISLE databases matched  reasonably well. Of the 32,19917 vessels that were
found to match between the NOI and MISLE databases (based on their Call sign, Primary VIN, or IMO
number), 54 percent have names that match exactly. In other instances, the names are only slightly different
(e.g., "IB935" vs. "IB 935" or "M/V Mendocino" vs. "Mendocino"). Over three quarters of the matched vessels
(79 percent) have values reported for vessel tonnage that are exactly the same in the two databases, while about
86 percent have values that are within 10 percent of each  other (difference often seemingly due to rounding).18
15 Note that while the call sign, VIN, and IMO number should be unique to each vessel, both the NOI and MISLE databases contain
multiple entries for the same identifier (not necessarily corresponding to each other). For example, in cases where a matching
algorithm identified multiple vessels with the same identifier, the matched information did not always correspond to the same vessel.
16 EPA deemed the MISLE data sufficiently reliable if at least one of the following MISLE entries corresponded to the NOI data:
vessel name matched, the vessel tonnage was within 10%, or the vessel lengths were within 10%.
17 Out of the 43,431 uniquely identified vessels with active NOIs.
18 Note that MISLE does not specify if the vessel tonnage, which is recorded in the field "gross tons", is reported as gross tons (GT) or
gross registered tons (GRT). For the purpose of this analysis, EPA compared the exact values in MISLE to the values reported in the
NOIs and did not adjust for potentially different units. EPA noticed when reviewing data for vessels for which the identifying
                                                   38

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Summary of the VGP Vessel Universe
                                                                     March 2013
Over half of the vessels (56 percent) have the exact same length, while 84 percent have lengths that are within
10 percent of each other.

This high matching rate suggests that MISLE may be a reasonable source of data from which to draw additional
information when the NOT contains insufficient information.
2.3.3   Summary and Analysis ofNOI Vessels with Incomplete Information
Of the 6,468 vessels for which NOT information was missing or insufficient, vessel tonnage recorded in MISLE
(or ballast capacity recorded in NBIC) was available to supplement the NOT for slightly more than a quarter
(1,801) of these vessels. As shown in Figure 2.3-1, over half of the barges, roughly a third of the "Other"
vessels, and just under 10 percent of the oil or gas tankers with incomplete NOT forms were able to be
supplemented by data from either the MISLE or the NBIC. Information on vessel tonnage and/or ballast
capacity remains missing or insufficient for 4,667 of the 43,431 uniquely-identified vessels in the NOI.

Figure 2.3-1: MISLE and NBIC compatible vessels.
  Commercial
fishing vessel,
     0%
                                        Medium cruise
                                          ship, 1, 0%
    Other, 635, 35%
      Research
    vessels, 8, 1
              Oil and ga:
             tankers, 125,
                 7%
                                                    Barges, 1029,
                                                        57%
See Appendix B for more details regarding the summary of 6,468 vessels with incomplete information.
Generally, EPA found that characteristics of these vessels were similar to those discussed in section 2.2 of this
document for which NOI data were sufficient.
information matched in both databases, that values in the NOI database reported as GRT often matched values in the MISLE GT field,
suggesting that units may not be defined consistently in the MISLE database as GT.
                                                  39

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Summary of the VGP Vessel Universe                                        March 2013
3   Summary

This document summarizes vessel information in EPA's NOT database and was prepared to provide useful
information about VGP regulated vessels and the characteristics and conditions of their discharges.

The NOT data summarized in this document includes 36,642 uniquely identified vessels that submitted a
complete NOT and 1,801 vessels where vessel tonnage and/or ballast water capacity was initially missing. For
this latter group of vessels, EPA used the MISLE and NBIC databases to help fill in critical missing information
to better characterize these 1,801 vessels.

Table 3.1 below summarizes key characteristics according to vessel type based on the information provided for
the 36,642 vessels that submitted complete NOIs. In general, the following can be concluded:

General Characteristics and Voyage Related Information
   •   Oil and gas tankers and large cruise ships are the largest of the NOI vessels and also generally the
       newest in terms of vessel age.
   •   The maximum passenger and crew capacity for passenger transport and leisure vessels (large  cruise
       ships, medium cruise ships, and large ferries) greatly exceeds that of any of the other NOI vessel types.
   •   A relatively large proportion of commercial fishing and emergency vessels are used for other  purposes,
       as noted by the high degree of sub-classification.
   •   The Gulf Coast is the primary geographic region of operation for working boats (i.e., barges, oil and gas
       tankers,  commercial fishing vessels) while the Pacific (Northwest especially), Northeast, and Florida
       Atlantic coasts appear to be the primary regions for passenger transport and leisure vessels (large cruise
       ships, medium cruise ships, and large ferries).
   •   A significant proportion of NOI vessels, except for barges and large ferries, travel beyond the US EEZ.

Ballast Water and Treatment Related Information
   •   The ballast water capacity of oil and gas tankers greatly exceeds  that of other NOI vessels.
   •   Ballast sediment is disposed of predominantly onshore, with the  exception of a relatively large portion
       (37 percent)  of oil and gas tankers, which discharge sediment outside of waters covered by the VGP.
   •   Except for barges, which tend to have comparatively low ballast  water capacity, the majority of ballast
       water tanks aboard vessels are cleaned at least once every 1 to 5 years.
   •   Few experimental ballast water treatment systems  currently exist aboard NOI vessels.

Discharges and  Discharge Related Information
   •   Deck washdown and runoff is the predominant discharge reported for all NOI vessels, followed by anti-
       fouling hull coatings, cathodic protection, ballast water, and firemain systems.
   •   More than half of the oil and gas tankers, large cruise ships, and research vessels reported having
       onboard treatment systems for generated waste streams. As would be expected, barges had the fewest
       onboard treatment systems for their generated waste streams.
   •   Oily/bilgewater,  sewage/sanitary, and graywater are the predominant waste streams treated aboard NOI
       vessels.
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Summary of the VGP Vessel Universe                                        March 2013
Anti-fouling Hull Coatings and Related Information
   •   Except for barges, the hulls of greater than 80 percent of all NOT vessels are protected with an anti-
       fouling hull coating.
   •   Anti-fouling hull coatings are generally applied at least every 3 years for most vessels.
   •   The hulls of all NOT vessel types are cleaned predominantly via power/pressure washing, with some
       vessels also using underwater divers and scrubbing.

The use of the U.S. Coast Guard's MISLE and NBIC databases was a means of completing critical information
(e.g., vessel tonnage and ballast water capacity) for NOT vessels where such information was lacking. Of the
6,468 vessels for which NOT information was missing or insufficient, vessel tonnage recorded in MISLE or
ballast capacity ecorded in NBIC is available for slightly more than a quarter (1,801) of those vessels. The
characteristics of these vessels (predominantly barges, oil and gas tankers, and "Other" vessels) are similar to
those of vessels for which more complete information is available in the NOI database.
                                                  41

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Summary of the VGP Vessel Universe
March 2013
Table 3.1. Summary of key vessel characteristics reported in the NOI database by vessel type.
Subcategory
Vessel Type
Barge
Oil and Gas
Comm. Fishing
Large Ferry Large Cruise
Medium Cruise
Research
Emergency
General Characteristics and Voyage Related Information
Median Tonnage (GT)
Median Length (ft)
Median Age (yrs)
Median Dry Dock Interval (yrs)
Top Home/Most Frequented
Ports
Primary Geo Regions
Travel Beyond EEZ (%)
Pacific NS Voyage (%)
Max Crew/Passenger (Median)
705
200
15
4
New Orleans, LA
Jeffersonville, IN
Pittsburgh, PA
St. Louis, MO
Metropolis, IL
Inland - Ohio R.
Gulf Coast
2
2
4
24,908
620
6
3
Houston, TX
New York, NY
Texas City, TX
Galveston, TX
Los Angeles, CA
Gulf Coast
95
24
22
1,997
265
23
3
Dutch Harbor, AK
Seattle, WA
New Orleans, LA
West Coast
Gulf Coast
76
23
29
1,451
260
26
3
Seattle, WA
New York, NY
Burlington, VT
Woods Hole, MA
NE Atlantic
Pacific NW
8.5
14
559
53.526
857
11
3
Miami, FL
Pt Everglades, FL
Pt Canaveral, FL
San Diego, CA
Florida Coast
West Coast
74
29
3,455
4,584
420
20
2
New York, NY
Boston, MA
Newport, Rl
NE Atlantic
68
21
315
1,780
224
23
3
Seattle, WA
Galveston, TX
Honolulu, HI
Pacific NW/Hawaii
Gulf Coast
85
41
41
563
194
26
3
Galveston, TX
Long Beach, CA
Port Angeles, WA
Pacific NW
Gulf Coast
89
75
16
Ballast Water and Related Information
Median Capacity (m3)
Existing BWMP (%)
Cleaning Frequency
206
23
47% 5 yrs +
23,893
98
42% periodical
(1 -5 yrs or less)
1,388
82
45% 1 to 5 yrs
404
15
52% periodical
(1-5 yrs)
3,136
91
41 % 1 yr or less
364
73
38% periodical
(1 yr or less)
425
78
31 % 1 yr or less
332
88
54% periodical
(1 to 5 yrs)
Discharges and Discharge Related Information
Top Discharges
Treatment Systems (%)
Waste Streams Treated with
Systems
Deck wash/runoff
Ballast water
Underwater Hus
Bilge/Oily water
Welldeck
<1
Wastewater
Graywater
Sewage/Sanitary
Ballast water
Seawater cooling
Deck wash/runoff
Graywater
Firemain
78
Oily/Bilgewater
Sewage/Sanitary
Ballast water
Deck wash/runoff
Graywater
Firemain
Anti-fouling hull
42
Oily/Bilgewater
Deck wash/runoff
Firemain
Cathodic Protect
Anti-fouling Hull
Seawater cooling
45
Sewage/Sanitary
Graywater
Deck wash/runoff
Seawater cooling
Firemain
Cathodic Protect
Anti-fouling hull
79
Oily/Bilgewater
Sewage/Sanitary
Graywater
Seawater cooling
Cathodic Protect
Deck wash/runoff
Firemain
Anti-fouling hull
50
Oily/Bilgewater
Sewage/Sanitary
Graywater
Deck wash/runoff
Anti-fouling hull
Bilge/Oily water
Ballast water
Cathodic Protect
78
Oily/Bilgewater
Sewage/Sanitary
Deck wash/runoff
Ballast water
Cathodic Protect
Anti-fouling hull
Aq. Film Foams
43
Oily/Bilgewater
Anti-fouling Hull Coatings and Related Information
Antifouling Coating (%)
Yrs Since Last Application
(Median)
Most Common Husbandry
Practice
4
4
Pressure wash
80
3
Pressure wash
85
3
Pressure wash
86
3
Pressure wash
84
3
Scrubbing/Divers
82
2
Pressure wash
95
3
Pressure wash
96
4
Pressure wash
                                                              42

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VGP NOI Vessel Universe Summary Report                                March 2013


4   References

Abt Associates, 2008. The Economic and Benefit Analysis of the Final Vessel General Permit. Abt Associates,
Inc., Cambridge, MA.

US Coast Guard (USCG), 2009. Marine Information for Safety and Law Enforcement (MISLE) Database. U.S.
Coast Guard, Washington, D.C.

USEPA, 2008a. Vessel General Permit (VGP). U.S. Environmental Protection
Agency.(http://www.epa.gov/npdes/pubs/vessel jygpjermit.pdf).

USEPA, 2008b. Final Issuance of National Pollutant Discharge Elimination System (NPDES) Vessel General
Permit (VGP) for Discharges Incidental to the Normal Operation of Vessels: Fact Sheet. U.S. Environmental
Protection Agency.

USEPA, 2010. Report to Congress: Study of Discharges Incidental to Normal Operation of Commercial
Fishing Vessels and Other Non-Recreational Vessels Less than 79 Feet. Report EPA 833-R-10-005. August
2010.
                                               43

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VGP NOI Vessel Universe Summary Report                               March 2013
                                         Appendix A
                         Comparison of the NOI Universe of Vessels versus
              the Universe of Vessels in the Final 2008 VGP Economic and Benefit Analysis
                                             A-l

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VGP NOI Vessel Universe Summary Report
                                               March 2013
This appendix summarizes findings from EPA's comparison of data submitted on NOIs (from June 1, 2009
through August 5, 2010) with prior EPA estimates of the universe of vessels subject to NOI requirements, as
determined during the development of the VGP. The purpose of the comparison is to identify, and where
possible, explain differences between the expected and actual vessel universe.

The Economic and Benefit Analysis of the Final Vessel General Permit (Abt Associates, 2008) provides
estimates of the number of vessels that would be subject to the VGP in the first five years of the permit period,
including estimates of the number of vessels that would need to submit a completed NOI to EPA. These
estimates were derived mostly from public data sources, namely: (1) the WTLUS data file compiled by the
Waterborne Commerce Statistics Center of the U.S. Army Corps of Engineers  (USAGE) Navigation Data
Center, (2) the VESDOC data file compiled by the U.S. Coast Guard, and (3) information submitted by the
International Association of Drilling Contractors on mobile offshore drilling units. Using these data, the number
of vessels required to submit an NOI was estimated at 49,736, including 41,906 domestic vessels and  7,830
foreign vessels. Table A-l summarizes the distribution of vessels required to submit an NOI, by vessel
provenance and class.

Table A-l. Estimates of number of vessels required to submit NOI (reproduced from Abt Associates,
2008; Table 3-1 and Table 3-2).
19
Vessel Classes
Commercial Fishing
Freight Barge
Freight Ship
Passenger Vessel
Tank Barge
Tank Ship
Utility Vessel
Total
Domestic Vessels
Count
26
30,961
469
1,270
4,808
117
4,255
41,906
% of Total
<1
74
1
3
11
<1
10
100
Foreign Vessels
Count
-
125
5,577
146
30
1,891
61
7,830
% of Total
-
2
71
2
<1
24
1
100
TOTAL
Count
26
31 ,086
6,046
1,416
4,838
2,008
4,313
49,736
% of Total
<1
63
12
3
10
4
9
100
Information in EPA's current NOI database indicates that 43,110 vessels have active coverage under the VGP
as of August 5, 2010,20 or about 15 percent less than EPA's estimate of 49,736 vessels (see Figure A-l and
Table A-2 below). Based on these data, EPA overestimated the number of vessels that would have to submit an
NOI when compared to those that did (41,906 vessels estimated and 29,278 vessels with active VGP coverage),
while EPA underestimated the number of foreign vessels that would be required to submit an NOI (7,830
vessels estimated and 13,832 vessels with active VGP coverage).21 Much of the difference between the pre-
permit issuance estimates and number of vessels with active VGP coverage in the NOI is accounted for by
freight barges: over 9,000 fewer freight barges than expected submitted an NOI to EPA.  The numbers of freight
  Due to gaps in the publicly available data on domestic vessel tonnage, the estimates developed for the VGP conservatively assumed
that, when tonnage information was missing, vessels greater than 78 feet in length were likely to be 300 GT, and therefore, would be
required to submit an NOI.
20 This total includes vessels for which NOI applicability is still uncertain due to incomplete NOI information (see section 2.3 of this
document), but excludes the very small subset of 321 vessels identified as "Not Applicable" in section 2.1 which are identified as such
because the tonnage and ballast water capacity reported in the NOI for these particular vessels are less than 300 GT and/or 8 m3,
respectively.
21 To determine domestic versus foreign vessels, EPA used the Country and State fields. Then, where those fields were blank, EPA
manually checked the address and company name to determine the country of origin.
                                                  A-2

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VGP NOI Vessel Universe Summary Report
March 2013
ships, tank ships, and other vessels that submitted NOIs partly offset this discrepancy, with the actual number of
vessels covered under the VGP exceeding pre-permit issuance estimates by about 2,000 vessels in each of the
categories.
Figure A-l: Comparison of number of vessels subject to NOI requirements - Actual number versus the
number based on earlier VGP estimates.
    50,000
    45,000
    5,000
                                                                     Utility Vessel
                                                                     Tank Ship
                                                                     Tank Barge
                                                                     Public Vessel, Unclassified
                                                                     I Passenger Vessel
                                                                     Other
                                                                     I NA
                                                                     • Freight Ship
                                                                     Freight Barge
                                                                     I Commercial Fishing Vessel
                      eNOI
                                              Rulemaking Estimate
Table A-2. Comparison of actual NOI vessels and earlier VGP estimates.
Vessel Class
Commercial Fishing
Vessel
Freight Barge
Freight Ship
NA
Other
Passenger Vessel
Public Vessel,
Unclassified
Tank Barge
Tank Ship
Utility Vessel
Grand Total
NOI Applies
Domestic
102
21 ,684
417
1
574
450
11
3,362
167
2,510
29,278
Foreign
81
123
7,530
-
1,724
61
.
8
4,145
160
13,832
Total
183
21 ,807
7,947
1
2,298
511
11
3,370
4,312
2,670
43,110
Earlier VGP Estimates
Domestic
26
30,961
469
-
-
1,270
.
4,808
117
4,255
41,906
Foreign

125
5,577
-
-
146
.
30
1,891
61
7,830
Total
26
31,086
6,046
-
-
1,416
.
4,838
2,008
4,316
49,736
Difference
(157)
9,279
(1,901)
(1)
(2,298)
905
(11)
1,468
(2,304)
1,646
6,626
                                                   A-3

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VGP NOI Vessel Universe Summary Report                                  March 2013

Several factors may explain differences between the vessel population estimate and NOI vessels with active
VGP coverage. Main reasons include:
   •  Missing or incorrect data in vessel databases. While EPA found that public data sources generally
       provide reasonably accurate information for vessels that submitted an NOI, it is possible - and even
       likely - that outdated or incomplete data in the public databases used to derive pre-permit issuance
       estimates resulted in an overestimation of vessels subject to NOI requirements. For example, retired
       vessels are not necessarily removed from the database even as new vessels are added, and duplicate
       entries may be present in the database for the same vessel if the vessel information changed.22
       Furthermore, in cases when information was incomplete, EPA used conservative assumptions when
       estimating the number of vessels that would need to submit an NOI (e.g., in cases where data on vessel
       weight was missing, all vessels above 78 feet were assumed to meet the tonnage threshold and to be
       required to submit an NOI). This is not necessarily the case of actual vessels. In general, errors or
       incomplete data in the public database tended to bias pre-permit issuance estimates upward.
   •  Failure to Submit an NOI or Failure to Correctly Certify an NOI. It is possible that some vessels
       currently operating in U.S.  waters have not submitted an NOI even though they are required to do so.
       Furthermore, some vessel operators may have thought they submitted an NOI successfully; however,
       they may have failed to certify the NOI, and therefore, did not receive active coverage. Approximately
       3,600 vessels remain in archived status in the NOI database. To the extent that vessels otherwise
       required to submit a completed NOI have not yet done so, the actual NOI counts may under-represent
       the universe of vessels subject to NOI requirements.
22 For example, EPA noticed that some vessels with different names or operators share the same identification numbers (e.g., IMO
number), even though this identifier should be unique.
                                                 A-4

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VGP NOI Vessel Universe Summary Report                                March 2013
                                          Appendix B
                Summary of vessel characteristics where NOI information was incomplete
                                             B-l

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VGP NOI Vessel Universe Summary Report                                 March 2013
This section summarizes the vessel characteristic data for the 6,468 vessels that lacked complete NOIs. Using
incomplete NOI data and supplementary data from MISLE or NBIC, as available, vessel characteristics for each
vessel class are summarized below. A "response" or "information provided" as the terms are used below,
indicate information provided on an incomplete NOI for which the MISLE and NBIC data were used to better
characterize these vessels.

Barges

Vessel General Characteristics and Voyage Related Information
EPA used MISLE or NBIC to supplement incomplete NOI information for 1,029 barges. Only 13 of the 1,029
barges (1 percent) were further sub-classified, with those identified as either dredge attendant plants (11 barges)
or oil and gas tankers (2).

Consistent with the information provided for the barges with complete NOIs, the median vessel tonnage, length,
and age of these barges is 764 GT,23 200 feet, and 9  years old, respectively. (See  Table 2.3 through Table 2.5)

Information on home/most frequented port was provided for 326 of these barges (32 percent). Of the 12 cities
indicated as home/most frequented port, St. Louis, MO (75 percent) and New York, NY (21 percent) were listed
most frequently.

Owners/operators of all but two of the approximately 330 barges for which a response was provided indicated
that their vessel is unmanned (zero maximum passengers and crew). EPA inferred from this result that the
majority of barges lacking a response for the maximum passengers or crew on their NOI form also were
unmanned.

Ballast Water and Related Information
The NBIC database did not contain any  additional ballast water capacity information that could be used to fill in
the gap for the 1,029 barges with incomplete NOIs. Nevertheless, seven owner/operators out of the 342 who did
respond to this question on an incomplete NOI indicated having an existing BWMP, and 11  owners/operators
provided information regarding ballast sediment disposal (onshore at shipyards via third party) and ballast tank
cleaning frequency (periodically; mostly at dry dock).

No owners/operators indicated having an experimental ballast treatment system aboard their vessels.

Applicable Discharges and Related Information
Of the 26  listed applicable discharges that vessels may generate (Table 2.17), the 1,029 barges identified only
nine discharge types. The nine discharge types are: deck washdown and runoff (886  out of 1,029 barges),
cathodic protection (79), bilgewater/oily water separator effluent (69), underwater ship husbandry (18), anti-
fouling hull coatings(13), ballast water (5), small boat engine wet exhaust (1), exhaust gas scrubber washwater
discharge (1), and welldeck discharges (1). This list  roughly coincides with the discharge types for barges listed
on complete NOIs (Table 2.17).
23 This number assumes that MISLE information is reported as GT since the database does not specify GT or GRT; also see footnote
15.
                                                 B-2

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VGP NOI Vessel Universe Summary Report                                  March 2013

No information about onboard treatment systems and corresponding waste streams generated/treated were listed
for any of the barges (i.e., 873 of the 1,029 responded in their NOIs that no systems were on board; the
remainder did not respond).

Anti-fouling Hull Coatings and Related Information
Owners/operators of only seven of the 271 barges for which a response was provided in the incomplete NOI
indicated application of an anti-fouling hull coating. All seven respondents indicated coating their vessels
within the last eight years. Hull husbandry practices, according to the eighteen responders, generally are
employed every 2 to 5 years or as needed using a power washer while the vessel is at dry dock.

"Other" Vessels

Vessel General Characteristics and Voyage Related Information
Missing information was confirmed using MISLE or NBIC for the 635 "Other" vessels in the NOI database,
only 3  of which were further sub-classified by the respondents as oil or gas tankers

For these "Other" vessels, the median vessel tonnage is 27,581,24 the median length is 623 feet, and the median
age is 18 years old.  This compares closely with "Other" vessels with complete NOIs which have a median
length  of 600 feet and a median age of 11 years old, respectively (See Table 2.4 and Table 2.5).

Respondents provided information on home/most frequented port for only 32 of the 635 "Other" vessels with
incomplete NOIs (5 percent). Of the cities indicated as home/most frequented port (note:  a total of only 13
different port cities were listed), 70% of vessels listed cities in Louisiana (Fourchon, New Orleans, Houma),
Alabama (Tuscaloosa, Mobile),  or Texas (Houston, Texas City).

Where a response was provided regarding maximum passenger size, 74 out of 77 "Other" vessels responded
that their vessel was unmanned (zero maximum passengers). Of the three remaining respondents, the maximum
passenger size was 2, 4, and 10. Where a response was provided regarding maximum crew size, 115 "Other"
vessels indicated a median of 30 maximum crew members. The combination of data for maximum passenger
size and maximum crew sizes results in a median similar to the median for "Other" vessels with complete NOIs
(see Table 2.12).

Ballast Water and Related Information
Information regarding ballast water capacity for 273 of 635 "Other" vessels with incomplete NOI data was
available via matching vessels to the NBIC database. The median ballast water capacity for these vessels is
18,707 m3, which is nearly twice as high as the median value of the "Other" vessels with  complete NOIs (Table
2.13). However, these results are similar to the 90*  percentile ballast water capacity (approximately 34,000 m3).

Affirmative responses on NOIs from 476 owner/operators of "Other" vessels (94  percent) were provided
regarding the existence of a BWMP. Only  12 owners/operators provided information on their NOI regarding
ballast sediment disposal (11 of them indicating disposal onshore at shipyards via third party), and 13 provided
information on ballast tank cleaning frequency (11 indicating that their vessel's ballast tank is cleaned
periodically; mostly at dry dock).
24 This value assumes that this tonnage reflects GT since tonnage units are not specified in MISLE; this value could be over-estimated
by a factor of approximately 1.7 since 76 respondents indicated that the reported vessel tonnage in the NOI is based on GRT.
Assuming instead that MISLE vessel tonnage values reflect GRT, the median value would be approximately 16,300 GT, which
coincides with the value described previously for the larger subset of "Other" vessels in the NOI (i.e., 15,939 GT, see Table 2.3).
                                                 B-3

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VGP NOI Vessel Universe Summary Report                                 March 2013


No owners/operators indicated having an experimental ballast treatment system aboard their vessels.

Applicable Discharges and Related Information
Only 116 of the 635 "Other" vessels specified their generated discharge type on their NOI. Of the 26 listed
possible applicable discharges, respondents indicated generating 25 different types (the single exception being
sonar dome discharge). Deck washdown and runoff and graywater were reported as being discharged from 115
"Other" vessels; cathodic protection, ballast water, and anti-fouling hull coatings were reported as discharged
from over 90 vessels; and refrigeration and air condensate discharge, bilgewater/oily water separator effluent,
seawater cooling overboard discharge, and non-oily machinery wastewater were reported as discharged from
over 80 vessels. The list of top five applicable discharges corresponds closely with that of the "Other" vessels
with completed NOIs (Table 2.17).

Onboard treatment systems and corresponding waste  streams generated/treated were listed for only 78 of the
635 "Other" vessels. Bilgewater was listed as a waste stream treated by 37 of these vessels, oily water by 10
vessels, and raw sewage/sanitary by seven.

Anti-fouling Hull Coatings and Related Information
Owners/operators of 71 of the 98 "Other" vessels for which a response was provided indicated application of an
anti-fouling hull coating, 90 percent of which have coated their vessels within the last six years. Hull husbandry
practices, according to the very few owners/operators who responded (approximately 10), are employed as
needed or every 2 to 5 years, largely while the vessel  is at dry dock. Power washing is the hull husbandry
method most commonly employed for nine "Other" vessels,25 and scraping and underwater diving for one
vessel  each.

Oil or  Gas Tankers

Vessel General Characteristics and Voyage Related Information
Missing information in the NOI was confirmed using MISLE or NBIC for 125 oil or gas tankers. The median
vessel  tonnage for this particular subset of oil or gas tankers is 57,162 (assumed GT), which is more than twice
the median vessel tonnage for oil or gas tankers with  a complete NOI (i.e., 24,908 GT, see Table 2.3).
However,  the 90*  percentile vessel tonnages are relatively similar: approximately 83,700 and 93,000 GT,
respectively.

The median length of these vessels with incomplete NOIs is slightly higher (750 feet), and their age (7 years) is
slightly older compared with the information provided for the 3,280 oil or gas tankers with complete NOIs (i.e.,
620 feet and 6 years old, respectively; see Table 2.4 and Table 2.5). Again, the 90th percentile values are
relatively similar (i.e., 1,034 feet and 18 years old, respectively).

Home/most frequented port was not indicated for any of the 125 oil or gas tankers with incomplete NOI forms,
and no information was provided regarding maximum passenger size. Owners/operators  of 12 of these oil or gas
tankers did provide maximum crew size, which ranged from 25 to 35 maximum crew members, coinciding with
the value described for oil and gas tankers with a complete NOI (Table 2.12).
 1 See footnote "a" in Table 2.18.
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VGP NOI Vessel Universe Summary Report                                  March 2013

Ballast Water and Related Information

Information regarding ballast water capacity for 42 of the 125 oil or gas tankers with incomplete NO Is was
available via the NBIC database. The median ballast water capacity for these vessels is 37,866 m3, which is 1.6
times higher than the median capacity for oil or gas tankers with complete NOIs (23,893 m3) (Table 2.13). The
90* percentile ballast water capacity for these vessels, however, is 1.2 times lower than those oil or gas tankers
with complete NOIs (approximately 57,300 versus 67,300 m3, respectively).

All owner/operators of the 125 oil or gas tankers have an existing BWMP in place for their vessel, which is
consistent with 98 percent of oil and gas tankers indicated as having a BWMP that submitted a complete NOI
(see Table 2.14). Only one owner/operator provided information regarding ballast tank cleaning frequency
(every 1 to 5 years), and no respondents provided information in the NOI regarding ballast sediment disposal
for their oil or gas tanker.

No owners/operators indicated having an experimental ballast treatment system aboard their oil or gas tanker.

Applicable Discharges and Related Information
Only 12 owner/operators of the 125 oil or gas tankers with incomplete NOIs specified the applicable discharges
their vessels generated.  Of these twelve owner/operators, nearly all indicated discharging 25 discharge types. A
few discharge types not listed as generated  for each vessel includes: controllable pitch propeller hydraulic fluid
(only two vessels discharge), graywater mixed with sewage (only a single vessel discharges), welldeck
discharges (only a single vessel discharges), and no vessel reported discharging gas turbine wash water or sonar
dome discharge. This information is consistent with that of the oil or gas tankers with complete NOIs described
previously in section 2.2.3 of this document.

Responses affirming the use of an onboard  treatment system were provided for only 12 of the 125  oil  or gas
tankers; however none of the responses included the corresponding waste streams treated.

Anti-fouling Hull Coatings and Related Information
Owners/operators of 13 of the 125 oil or gas tankers for which a response was provided indicated application of
an anti-fouling hull coating; all of which have coated their vessels within the last four years. No additional
information was provided regarding the hull husbandry practices employed aboard these vessels, or the
frequency with which they may be implemented.


Miscellaneous Vessel Types

Missing information was confirmed using MISLE or NBIC for an additional eight research vessels, three
commercial  fishing vessels, and one medium cruise ship with an active or certified NOI. The vessel
characteristic data provided in the NOI for these uniquely-identified vessels is similar to the information
previously described for vessels with complete NOIs.
                                                 B-5

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