EPA CONSIDERATION OF ISSUES UPON REMAND IN AMERICAN
WATERWAYS OPERATORS v. WHEELER, No. 18-CV-2933 (D.D.C.)
(February 26, 2021)
EPA prepared this document in response to a judicial remand of the administrative record
in litigation challenging EPA's determination, in February 2017, that adequate facilities for the
safe and sanitary removal and treatment of vessel sewage (pumpout facilities) are reasonably
available in Puget Sound. American Waterways Operators v. Wheeler, No. 18-cv-2933 (D.D.C.)
(Nov. 30, 2020). Such an EPA determination is necessary for the State of Washington's
prohibition on the discharge of vessel sewage in Puget Sound - a "no-discharge zone" (NDZ) —
to apply.
Summary
The Court's Order directed EPA to further consider the following issues, including any
additional fact-gathering the Agency deems necessary:
(1) the costs to vessels attributable to EPA's determination whether adequate
pumpout facilities are reasonably available;
(2) the bases to determine whether adequate sewage treatment facilities are
reasonably available for commercial vessels; and
(3) an explanation of the ratio of commercial vessels to pumpout facilities and why it
helped EPA's determination that adequate treatment and removal facilities are reasonably
available.
In response to the Court's Order, this document describes the Agency's consideration and
conclusion of the aforementioned issues:
(1) EPA determines that the expected costs to affected vessels, both recreational and
commercial, to access and use pumpout facilities do not materially alter EPA's
determination that adequate facilities are reasonably available in the Puget Sound NDZ.
(2) EPA determines that Puget Sound sewage facilities are regulated at the federal,
state, and local levels and in Indian Country and that there are adequate treatment
facilities reasonably available in Puget Sound. Existing WWTPs can accommodate the
extra sewage that is estimated to be generated under a Puget Sound NDZ.
(3) The 11:1 commercial vessel to pumpout ratio is a surrogate for pumpout capacity.
Upon remand, EPA has again analyzed volume demand and capacity; the screening
analysis detailed in this document now more quantitatively demonstrates that there is
1
-------
widespread availability and sufficient capacity to treat the volume of sewage from the
NDZ.
After consideration of the issues remanded by the Court - assessment of cost due to
pump out of vessel sewage, assessment of whether adequate sewage treatment facilities are
reasonably available, and addressing EPA's use of a ratio of commercial vessels to pumpout
facilities to determine whether adequate treatment and removal facilities are reasonably available
- EPA reaffirms its determination that adequate facilities for the safe and sanitary removal and
treatment of vessel sewage (pumpout facilities) are reasonably available in Puget Sound.
Background
On July 21, 2016, the Washington State Department of Ecology (Ecology) petitioned
EPA, pursuant to Clean Water Act (CWA) section 312(f)(3), 33 U.S.C. § 1322(f)(3), for a
determination that adequate pumpout facilities are reasonably available for the waters subject to
Washington's proposed NDZ. Ecology's application included a certification that the protection
and enhancement of waters described in the petition require greater environmental protection.
See 40 CFR 140.4. On October 14, 2016, Ecology supplemented its application with information
concerning commercial vessel pumpout availability in Puget Sound.
On February 21, 2017, following public notice in the Federal Register and consideration
of comments, EPA determined that adequate pumpout facilities are reasonably available in the
waters subject to Washington's proposed NDZ. 82 FR 11218. EPA's determination assessed
reasonable availability for all vessels but separately described the availability of sewage pumpout
facilities for recreational vessels and for commercial vessels, respectively, in recognition of the
different needs associated with each. EPA's administrative record, including the State's
application materials, contained limited cost information applicable to vessel operations and to
the treatment of sewage from vessels in Puget Sound. In its determination, EPA explained its
then-current position that the CWA did not require EPA to consider costs in determining
reasonable availability of facilities.
Following EPA's 2017 determination, Ecology proceeded with a State rulemaking to
establish the vessel sewage discharge prohibition for the waters identified in its petition. WAC
173-228-030 (hereinafter "Puget Sound NDZ"). As part of this process, Ecology instituted a
five-year delayed implementation schedule of the rule's effectiveness for certain commercial
vessels. For vessels not identified for delayed implementation, such as recreational vessels, the
NDZ took effect in May 2018. WAC 173-228-050.
In December 2018, American Waterways Operators (AWO) filed a lawsuit alleging that
EPA's determination was arbitrary and capricious under the Administrative Procedure Act
(APA), 5 U.S.C. § 706, and that EPA was not authorized to issue a determination on Ecology's
purportedly defective petition. On November 30, 2020, the Court issued a Memorandum and
Order holding that EPA was required to consider costs in determining whether adequate
pumpout facilities were reasonably available. The Court reviewed Supreme Court and D.C.
Circuit cases explaining that a statute's "textual hook" directs the scope of an agency's
consideration of factors in regulatory determinations. The Court determined that the term
2
-------
"reasonably available" in CWA section 312(f)(3) constitutes the type of language that "naturally
and traditionally includes consideration of all the relevant factors" and that"[1 ]ogic likewise
dictates that the agency was required to consider costs." As such, the Court held that EPA acted
arbitrarily and capriciously in violation of the APA by not considering costs, and that the Agency
must do so on remand. The Court further concluded that the record did not sufficiently document
EPA's finding that adequate facilities for the treatment of vessel sewage were reasonably
available in Puget Sound, or EPA's use of a ratio of commercial vessels to pumpout facilities in
determining that facilities are available for these vessels. American Waterways Operators v.
Wheeler, No. 18-cv-2933, atDkt. 66.
On December 10, 2020, EPA invited the parties in the American Waterways Operators v.
Wheeler litigation to provide updated data and information relevant to EPA's consideration of
the issues on remand with a request that any such information be provided to EPA no later than
Friday, January 8, 2021, in order for EPA to review and consider the information within the time
provided by the Court. Each of the parties provided responsive information. In preparing its
response to the remand, EPA also independently sought and compiled updated information from
third parties, such as fees charged by pumpout facilities. See Memorandum to File Re:
Documentation of Contacts with Pumpout Service Companies and NOAA (Memorandum to
File).
This document explains EPA's consideration of the issues remanded by the Court and
provides the basis for EPA's reaffirmation of its determination that pumpout facilities are
reasonably available in the Puget Sound NDZ. First, the document discusses EPA's
consideration of costs. Next, the document explains EPA's assessment of whether adequate
treatment facilities for sewage from all vessels, including commercial vessels, are reasonably
available in Puget Sound. Finally, the document addresses EPA's use of a ratio of commercial
vessels to pumpout facilities to determine whether adequate treatment and removal facilities are
reasonably available.
Cost Considerations
This section describes EPA's consideration of costs in the determination whether
adequate facilities are reasonably available for the removal and treatment of sewage from all
vessels in Puget Sound. Cost is one of many factors EPA now considers in making its
determination. EPA also considers the variety of other factors addressed in the information
submitted by a State in accordance with EPA's implementing regulations at 40 CFR140.4. Per
the regulations, a State's application must include: "(1) A certification that the protection and
enhancement of the waters described in the petition require greater environmental protection than
the applicable Federal standard; (2) A map showing the location of commercial and recreational
pump-out facilities; (3) A description of the location of pump-out facilities within waters
designated for no discharge; (4) The general schedule of operating hours of the pump-out
facilities; (5) The draught requirements on vessels that may be excluded because of insufficient
water depth adjacent to the facility; (6) Information indicating that treatment of wastes from such
pump-out facilities is in conformance with Federal law; and (7) Information on vessel population
and vessel usage of the subject waters."
3
-------
Overview of Cost Tool
Upon remand, EPA analyzed the costs associated with a Puget Sound NDZ by using a
cost analysis tool (hereinafter, "the Tool") it had developed for estimating compliance costs for
vessel sewage NDZs, that can be modified to reflect the unique characteristics of an individual
water body (the Tool is available as an Excel file, see Appendix A). The Tool calculates the
percent increase in baseline operating costs that affected vessels in Puget Sound may incur using
pumpout facilities to comply with the Puget Sound NDZ. EPA selected this metric for the cost
analysis because most costs incurred by affected vessels relate to operating costs, such as
increased fuel or crew-related expenditures.
To derive final outputs, the Tool generated a series of calculations based on a variety of
user inputs and default values described in detail below. A critical feature of the Tool is a
screening analysis that calculates how frequently the demand for pumpout facilities (i.e., the
volume of sewage produced by vessels that needs to be pumped out) is projected to exceed
pumpout facility capacity (i.e., the volume of sewage that can be pumped out by available
facilities). The frequency with which demand exceeds capacity influences the core of the cost
analysis due to its relationship with factors such as wait time (and resulting lost revenue). The
screening component primarily assesses the availability of facilities, though to some extent it
also considers the adequacy of facilities because it assesses the capacity to manage the volume of
vessel sewage generated.
EPA's cost analysis focuses on non-oceangoing commercial vessels operating in Puget
Sound, including tugboats (and other similar vessels, i.e., workboats, escort vessels, barges, etc.),
fishing vessels, excursion vessels, ferries, and research vessels. EPA assumed that oceangoing
vessels would choose the least costly option of discharging sewage outside of Puget Sound.
EPA assessed the costs for both recreational and commercial vessels in its analysis.
However, the Tool was designed to focus on the cost implications for commercial, not
recreational, vessels for two primary reasons. First, federal grant funding is available to states
through the Clean Vessel Act (CVA) for the construction and maintenance of pumpout facilities
servicing recreational vessels. In contrast to fees charged by pumpout facilities servicing
commercial vessels, fees to use these federally funded pumpout facilities are nominal (e.g., $5-
25 per pumpout) or, as is increasingly common, free of charge.
Second, recreational vessels with toilets installed onboard tend to be more uniform in
size, number of passengers, and volume of sewage produced than their commercial counterparts.
As such, recreational vessel needs (e.g., draft and berth requirements, volume to be pumped) for
access and use of pumpout facilities are generally consistent, which is not the case for
commercial vessels, where size, number of crew/passengers, volume of sewage produced, and
draft or height can vary widely (e.g., a four crew commercial fishing vessel versus a 100-
passenger excursion vessel). This variation in commercial vessels directly affects the type of
facility that commercial vessels can access. For this reason, the cost analysis sorted the
commercial vessel population to determine whether adequate pumpout facilities are reasonably
4
-------
available for the types of commercial vessels present in the proposed waterbody. An analogous
sorting is not needed for most recreational vessels. Despite these two distinguishing factors, EPA
did consider in this analysis whether the cost to recreational vessels is prohibitive, such that it
would negate the ability to partake in recreational boating in Puget Sound, and discusses those
considerations later in this document.
The statutory text of CWA section 312(f)(3) guided which costs were included and
excluded from the cost analysis. Under CWA section 312(f)(3), EPA is directed, upon
application by a State, to determine whether "adequate facilities for the safe and sanitary removal
and treatment of sewage from all vessels are reasonably available." The term "reasonably
available" applies to the determination of "adequate pumpout facilities." As such, the costs
identified for inclusion by EPA are those that vary based on the adequacy of existing facilities, as
well as costs affecting the degree to which use of those facilities can be considered "reasonably
available." These costs include facility use costs, pumpout time costs, travel costs, and wait time
costs, all of which are described in more detail below.
EPA's cost analysis does not consider costs that are not influenced by the adequacy and
availability of pumpout facilities. For example, EPA did not incorporate costs to retrofit a vessel
to comply with the discharge prohibition (the NDZ itself), such as the costs associated with
replacing a flow-through (Type I or Type II) marine sanitation device (MSD) to a Type III MSD
(a holding tank designed to store vessel sewage until pumpout) or the costs for time lost out of
service for installation of such devices. EPA did not include in its assessment the costs associated
with replacing or supplementing an existing Type I or Type II MSD with a holding tank because
any such need for retrofit would be attributable to the per se existence of the NDZ and would not
be attributable to inadequacy or unavailability of pumpout facilities.
Under CWA section 312(f)(3), where the state takes primary responsibility for regulating,
EPA's determination is limited to the reasonable availability of adequate pumpout facilities
rather than the reasonableness of the State's establishment of the Puget Sound NDZ generally.
EPA does not question a state's determination that waters identified in the NDZ application
"require greater protection" when EPA determines whether adequate pumpout facilities are
reasonably available in response to the state's proposal to prohibit vessel sewage discharges. For
that reason, EPA constrains its consideration of costs to the costs that can be attributed to
pumpout facility availability and adequacy. Because complying with a vessel sewage discharge
prohibition (other than avoiding travel within the zone) would necessarily entail use of an
existing or newly installed holding tank, any costs to vessel owners associated with retrofitting
would be attributable to a state's prohibition on discharges itself and not to factors related to the
"availability" or "adequacy" of the pumpout facilities that serve vessels equipped with such
tanks.
This approach is based on a plain reading of CWA section 312(f)(3). A state NDZ does
not "apply" unless and until EPA concludes that adequate facilities are reasonably available.
Congress directs EPA to consider costs by using words (the adjective "reasonably available")
that modify only the EPA pumpout facility determination. The statutory consequence of an
5
-------
EPA's affirmative determination is that the vessel sewage prohibition "applies," but Congress
did not include similar text directing EPA to consider (much less authorize EPA to consider) the
reasonableness of application of the NDZ.
In addition, there is no indication that Congress meant the term "available" to have any
meaning other than its commonplace meaning of ready or accessible or usable; whether pumpout
facilities have any of these attributes is unrelated to whether use or installation of new or
expanded holding tanks is required, let alone how much such retrofits may cost. In keeping with
the CWA's policy emphasizing the primary role of states in water quality protection and the
sensitivity to federal preemption demonstrated in the 1970 and 1972 legislative history of vessel
sewage control provisions, the statutory text vests the state with the role of determining which
waters require greater protection and ultimately whether the vessel sewage discharge prohibition
should apply. EPA's task is limited to determining whether the pumpout facilities that become
critical to avoiding disruptions to interstate commerce when a state establishes a NDZ are
reasonably available. For EPA to determine that costs other than those attributable to the
availability of adequate pumpout facilities preclude a sewage discharge prohibition would
overstep EPA's statutory role and undermine the role that CWA section 312(f)(3) largely vests in
states to take the actions they find necessary to protect their waters.
Moreover, retrofit costs are one-time "fixed costs" that are not influenced by and do not
vary based on whether pumpout facilities are adequate and available. Such vessel costs are not
relevant to any attribute (e.g., number, size, distribution, accessibility) of pumpout facilities.
Costs that EPA input into the Tool were determined annually by vessel class using a
"uniform demand" scenario. The concept of uniform demand assumes that an equal number of
vessels within a class will pump out every day. For example, if a particular vessel class is
expected to pump out every four days, then under a uniform demand scenario one in four vessels
within that class will pump out each day during the months that the class is expected to operate.
This assumption is consistent with cost-minimizing behavior, as vessel operators will minimize
costs by spreading out demand, reducing the wait time to access a pumpout facility. This
assumption is also reasonable because vessel operators can schedule a pumpout ahead of time at
a facility. In this way, EPA's Tool models daily demand on the available pumpout facilities
across the year. Using the operating schedule of pumpout facilities, EPA estimated the volume of
sewage each facility can receive daily and was therefore able to determine the percent of days
per year that demand for pumpout service is expected to exceed capacity.
In addition to providing insight into the adequacy of pumpout facilities as compared to
the needs of the vessel population, EPA used this value (percent of days per year when demand
would exceed capacity) to estimate how often vessels may be expected to wait to access a
pumpout facility, and subsequently the cost of such a wait. EPA assumed that individual
pumpout facilities would be equally in demand for services. While EPA recognizes that some
pumpout facilities may be in higher demand such that they experience wait times when others do
not, EPA was not able to model unequal demand, however, and assumed that all facilities serve
6
-------
pumpout needs for Puget Sound based on equal demand. For that reason, EPA approached the
issue of wait times at the waterbody level rather than the facility level, such that when periods of
demand exceeded capacity across Puget Sound, wait times could be expected. The cost
associated with this wait time would be a function of lost revenue for the time spent waiting.
These are conservative, worst-case scenario assumptions designed to estimate the high-end
ranges of expected costs.
EPA's cost analysis used three categories of inputs for each vessel class - vessel inputs,
pumpout facility inputs, and cost inputs - as described in the bullets below (definitions and
source information are available in Appendix B).
• Vessel inputs: the number of vessels operating in the proposed NDZ, which months these
vessels are operating, average number of crew/passengers onboard, sewage generation
rate, number of days between pumping out, average distance traveled to access a facility,
percent of vessels with holding tanks already installed, and a buffer time for pumping out.
• Pumpout facility inputs: pumpout facility name, type, operating schedule (hours, days,
and months of operation), connectivity to sewer, holding tank capacity, total working
flow of the pumpout facility, and the fee.
• Cost inputs: annual vessel baseline operating costs, vessel speed, fuel consumption,
hourly revenue, and fuel price.
The analysis used these input values to generate the estimates of the different kinds of costs.
• Pumpout facility use costs: The estimated fees paid to use a pumpout facility. To
generate an estimate, the Tool identifies which of the available pumpout facilities have
capacity to service each vessel class and uses an average of those facility fees. For
example, if the average tugboat is expected to pumpout 1,000 gallons of sewage per
pumpout, only available facilities with capacities over 1,000 gallons will be used in
determining the average cost to pumpout a tugboat.
• Pumpout time costs: The lost revenue to the vessel operator resulting from the time
required to use the pumpout facility (i.e., to complete pumpout of onboard sewage). This
value is a combination of the actual time to pumpout (based on the volume being pumped
and the working flow of the facility), as well as a "buffer time" that accounts for
additional time not actively pumping.
• Travel costs: The lost revenue and fuel cost to the vessel resulting from the time and
distance to travel to a pumpout facility, should accessing a facility require substantial
deviation from typical operations.
• Wait time costs: The lost revenue from waiting to access a pumpout facility. Wait time
costs would be expected when the preliminary screening analysis in the Tool indicates
that demand for pumpout facilities may exceed the collective facility capacity to receive
sewage. On these days, EPA assumes that each vessel would have to wait for other
vessels ahead of it to pump out, which includes the "buffer time" explained earlier. In the
"Vessel Inputs" described above, one of the inputs is the percent of vessels of each class
with holding tanks already installed. These vessels would not incur new costs associated
with pumpout fees, pumpout time, or travel, since the vessels are already pumping out
7
-------
prior to the NDZ designation. However, State establishment of an NDZ would create
increased demand for pumpout facilities which may create new wait times associated
with pumping out. As such, the additional wait times these vessels with holding tanks in
the baseline may face are appropriately considered in EPA's determination. EPA notes,
however, there is a sufficiently large pumpout capacity in Puget Sound such that EPA
does not consider wait times to be a significant issue for commercial vessels (see
screening analysis below).
To conduct the analysis with the formulae in the Tool, when EPA lacked values specific
to Puget Sound, EPA relied on some "default values" for several inputs, which are explained
below along with the sources of those default values. Many of the Puget Sound-specific values
were taken from reports written directly by Ecology or by consultants working on behalf of
Ecology, namely Herrera Environmental Consultants, Inc. (hereinafter, "Herrera").
Populating the cost analysis tool with the required values generated output results for
EPA's review. The first section of the output pertains to the screening analysis and provides the
minimum and maximum demand and capacity (in gallons per day) from the uniform demand
scenario modeling. This section of the output also provides an estimate for the percent of days
when minimum and maximum demand, respectively, exceeds capacity. The second section of
the output is a table containing the full breakdown of the various costs by vessel class, including
the total compliance cost per year in dollars, as well as the percent increase in baseline operating
costs for vessels with and without holding tanks installed in the baseline.
Application of Cost Tool to Puget Sound
Vessel Population Profiles
This section explains the inputs that EPA used to characterize each Puget Sound vessel
class in the analysis, including assumptions made and the sources for each input.
Tugboats
The sources reviewed by EPA indicate that approximately 174 tugboats, including ocean
tugboats, harbor tugboats, workboats, and assist and escort boats operate within Puget Sound. Of
these, Ecology (2016b) estimated that 150 tugboats would require pumpout facilities. EPA used
150 in its calculations and assumed year-round operation (and therefore sewage generation) by
these vessels (i.e., non-oceangoing, sewage generating tugboats). This is a conservative approach
to tugboat operating months because vessels would likely be taken out of service for a few weeks
per year for maintenance. As reported by Herrera (2015), "[cjurrently about 25 percent of the
tugboat fleet based out of Puget Sound utilizes holding tanks; the rest have Type II MSDs that
treat and discharge waste (Charlie Costanzo, Vice President-Pacific Region, AWO, personal
communication, November 2013)." As such, EPA assumed that 25% of the tugboat population
used in the analysis have holding tanks installed in the baseline.
The default value used in the Tool for the average number of crew onboard a tugboat is
six individuals. EPA reliance on this value was based on previous research conducted on EPA's
behalf by Eastern Research Group, through conversation with AEP River, a barge company.
Herrera and Veda Environmental (2013) estimated an average crew of four to six, with the
8
-------
potential for as many as ten. In its most recent information submission, AWO reported that
towing vessel operators typically carry five crew. Because the default value used in the Tool is in
line with the estimates provided by both Ecology and AWO, EPA used an average crew of six.
In "Puget Sound NDZ Commercial Vessel Economic Evaluation," Herrera (2015)
reported information conveyed by AWO regarding tugboat operations in Puget Sound, including
information pertaining to sewage generation rates, trip duration, and the number of tugboats
operating holding tanks in the baseline. For sewage generation, AWO provided an estimate of 16
gallons per person per day, noting that it was "based upon current vessel plumbing and
configurations." The Herrera (2015) report explains that high efficiency heads are available on
the market that would reduce the sewage generation rate to between two and six gallons per
person per day. As such, EPA's use of 16 gallons as the generation rate may be overly
conservative.
A Herrera (2015) report explains that AWO reported a typical trip length to be 14 to 21
days. In AWO's January 2021 submission, a footnote indicates that members reported pumpouts
would need to occur between every 5-15 days. In the same document, as part of calculations for
an appropriately sized holding tank, AWO used 30 days for the interval. In light of the varied
information provided, EPA used 21 days as a midpoint of the values provided for the expected
interval between uses of a pumpout facility by tugboats.
Because tugboats in Puget Sound are likely to rely on the use of mobile pumpout trucks
instead of stationary facilities, EPA assumed a buffer time of one hour in addition to the
calculated time for active pumping of the tank. This buffer time assumption accounts for the
miscellaneous time, such as connecting the hoses to the vessel and travel time of the mobile
facility, that the vessel operator must pay for in pumpout facilities fees. The Tool also calculates
the estimated cost in lost revenue due to this time because the vessel cannot perform jobs during
the time it is pumping out sewage. EPA selected an hour for the buffer time based on information
available from several different pumpout truck companies, which suggests a rough
approximation of one hour of billable time for every 1,250 or so gallons of sewage pumped.1
EPA believes this is an appropriately conservative estimate given that the volume of sewage to
be pumped by an average tugboat will vary based on days between accessing pumpout facilities,
such that the volume pumped may be more or less than 1,250 gallons. For example, certain
harbor tugs may access facilities more frequently, requiring a smaller volume to be pumped out
and therefore experiencing shorter pumpout times. Additionally, vessel operators can choose to
hire truck companies located nearest to preferred pumpout locations, limiting the buffer time
needed to account for trucks traveling to the pumpout location.
1 Arrow Marine Services provided information to AWO (reported in the January 2021 submission) that 6,000
gallons would take approximately 6-7 hours to pump out, suggesting a rough estimate of one hour of billed time per
1,000 gallons. Sound Marine & Industrial Services (see Memorandum to File) informed EPA that a recent pumpout
of 5,000 gallons was billed for 2.5 hours, equating to about 2,000 gallons per hour. Lastly, Emerald (CleanHarbors)
provided information to AWO (reported in the January 2021 submission) that a "standard" pumpout (assumed to be
3,000 gallons) would take a half day (assumed to be four hours), equating to approximately 750 gallons per hour.
EPA recognizes that this is a rough approximation based on available information, as billable time will depend on
where the vessel is located, where the pumpout truck is coming from, and other relevant factors.
9
-------
For the average distance traveled to access a pumpout facility, EPA used in the Tool a
value of five nautical miles. According to Ecology (2016b), "[t]he tug industry provided a list of
preferred additional stationary pumpout locations and discussed their vessel logistics. Most tug
vessels refuel at Harbor Island, and sometimes in other locations such as Anacortes or Tacoma.
Other possible locations, although not refueling there now, are the east waterway in Everett, and
Fisherman's Terminal." The locations identified here - where tug refueling operations typically
occur - are well-distributed across the NDZ and are in areas where it is expected that vessels
would require minimal travel to access a dock where pumpout operations could occur. In many
cases, it is likely that a pumpout truck could access the vessel at the same location where
refueling is to occur, such that additional travel would not be required at all. For context, in the
northern portion of Puget Sound, the Port of Bellingham and Anacortes are approximately 15
nautical miles apart. In the southern portion of Puget Sound, on the other hand, Harbor Island
and Elliott Bay Marina (south of Fisherman's Terminal) are just over four nautical miles apart.
Assuming some vessels would not require travel, while some may require more, EPA identified
five nautical miles as a reasonable estimate for the distance to travel to pumpout facilities.
Commercial Fishing Vessels
According to the reports generated by Herrera (e.g., Herrera, 2013), 350 commercial
fishing vessels spend some portion of the year in Puget Sound. Per one such report (Herrera,
2015), "[ajbout 70 of these vessels are salmon seiners that fish in Puget Sound for part of the
year. The remaining majority of the fleet berths in Puget Sound ports (e.g., Anacortes and
Fisherman's Terminal in Seattle), and fishes outside of Puget Sound, typically in Alaska, for
most of the year." According to Washington Department of Fish and Wildlife staff, the 70 purse
seiners primarily operate during the fall, while approximately 250 gillnetters fish in late summer
and late fall for sockeye and chum salmon, respectively (Herrera, 2013). The 2013 Herrera report
further explained that most purse seiners fish in Alaska, such that they only pass through Puget
Sound at the beginning and end of their season. Charter fishing vessels also operate in Puget
Sound. However, as described by Herrera (2013),
The certified charter boat captains that were contacted indicated that holding waste and
using pumpout stations/services is compulsory to maintaining status as a certified charter
boat. Therefore, certified charter vessels are already in compliance with a NDZ. The
charter boat captains of non-certified boats that were interviewed also indicated that NDZ
compliance should not be difficult. The captains interviewed indicated that their vessels
either have Type III MSDs or porta-potties and that they already use pumpout or dump
stations.
For purposes of the cost analysis, EPA used a value of 350 commercial fishing vessels in
lieu of attempting to parse whether portions of the fleet may or may not place demand on
pumpout services at any given time. Based on information gathered by Herrera (2015),
approximately half of commercial fishing vessels in Puget Sound already had holding tanks
installed within the time-period reported by Herrera at least six years ago.
In a conversation with Sound Marine & Industrial Services (see Memorandum to File), a
sewage pumpout provider in Puget Sound, the company representative explained to EPA that the
10
-------
commercial fishing fleet is typically serviced between October and mid-January, followed by a
brief break, with services resuming between mid-February and May. The representative
indicated that June through September sees little demand for pumpout services from the fleet.
Because the information provided by Sound Marine covered a more expansive period than that
described by the Washington Department of Fish and Wildlife, EPA used those time periods in
the Tool.
EPA recognizes that the information provided by Sound Marine & Industrial Services
may not be representative of the commercial fishing fleet's demand on pumpout facilities
considering the myriad fisheries in the Puget Sound region. However, even if some of the fleet is
pumping out in the four months between June and September, EPA estimates the volume of
sewage produced to still be low because vessels in this class have small crews that produce an
estimated 64 gallons of sewage per day. Herrera (2013; 2015) reports that commercial fishing
vessel crews range from 2 individuals (gillnetters) to 5 individuals (purse seiners) and the vessels
do not typically remain out of port for multiple days. As such, EPA assumed an average crew of
four with a pumpout interval of one day. EPA used the sewage generation rate for tugboats of 16
gallons per person per day as a proxy for the rate on commercial fishing vessels because both
vessel classes have small crews and may have marine heads of similar efficiency. This is a
conservative assumption because it assumes that the gillnetters and purse seiners do not leave
Puget Sound and discharge in the ocean during these months (or that the vessels return daily to
pump out).
Because commercial fishing vessels typically return to port daily and produce small
volumes of sewage, EPA assumed that these vessels can be serviced by pumpout facilities
without the need to travel. Mobile pumpout facilities are not expected to have difficulty
accessing fishing vessels where they are offloading their catch. Importantly, while this analysis
only considers pumpout facilities identified as available for commercial vessels, some of the
fishing fleet may access the facilities that typically service recreational vessels. The volume of
sewage produced by the fishing vessels is low, and many fishing vessels likely do not have draft
or berth restrictions that prevent access to these facilities. Indeed, marina operators would find it
more profitable to service both recreational and commercial vessels, when able. EPA notes,
however, that CVA-funded facilities are typically restricted to recreational vessel use. Because of
this increased flexibility, EPA did not include a buffer time assumption for the average
commercial fishing vessel.
Excursion Vessels
In Washington's Final Regulatory Analysis (Ecology, 2018), the State explains that the
60 excursion vessels identified as operating within Puget Sound were already compliant with the
NDZ. Washington also identified three "small commercial passenger ships," defined as having
249 overnight passengers or fewer, that would need to retrofit and use pumpout facilities. These
vessels include small cruise ships and whale watching vessels. EPA bundled these two sets of
vessels together as "excursion vessels," using a total vessel population of 63 in the Tool
calculations. Of these, all but three had holding tanks installed before establishing the NDZ and
therefore are part of the baseline.
11
-------
According to Herrera (2013), these small commercial passenger ships "carry from about
15 to 600 passengers, although the majority are at the lower end of this range and carry 60 or
fewer passengers." As such, EPA conservatively entered into the Tool a default value of 187
passengers. This value was taken from work conducted by Eastern Research Group on EPA's
behalf to estimate vessel sewage generation rates, and was an average based on information
provided by 23 medium/small cruise ships.2 This is likely an overestimate because Ecology
indicates that most of the vessels are at the lower end of the provided range. EPA further
assumed that these vessels would operate between April and September. This operating month
range is based on the number of days per year this vessel type is expected to operate in U.S.
waters - 174 - centralized to the middle of the year as EPA expects excursion vessels to
typically operate during the spring and summer months (U.S. EPA, 2006).
For excursion vessels, EPA used a default sewage generation rate of 8.4 gallons of
sewage generated per person per day, taken from EPA's (2008) "Cruise Ship Discharge
Assessment Report." Herrera (2013) reported that small cruise ships typically hold their sewage
for one to two days, while Ecology (2018) estimated the pumpout interval to be two to three
days. As such, EPA selected the midpoint value of two days for the estimate of the excursion
vessels' pumpout interval.
Lastly, EPA assumed that excursion vessels would likely not require additional travel to
access pumpout facilities. Due to excursion vessels' typically large size, EPA expects that
pumpout trucks can access the docks or other facilities where excursion vessels would typically
frequent. Similarly, EPA did not calculate a buffer time for excursion vessels because pumping
out may occur concurrently with other activities, such as boarding and offloading passengers.
Ferries
Of the 45 ferries operating in Puget Sound, Herrera (2013) reports that 22 of these ferries
are Washington Department of Transportation ferries with dedicated pumpout facilities.
Similarly, Ecology (2018) reports that the remaining 23 ferries are Alaska Marine Highway
System vessels that also use dedicated pumpout facilities. Because these ferries already have
holding tanks (installed prior to the establishment of the NDZ) and are serviced by dedicated
pumpout facilities (meaning that they will not generate demand for the facilities used by other
vessels), EPA concluded that none of the ferries will experience an increase in annual operating
costs. As such, EPA does not provide any further profiling or analysis for ferries because the
dedicated pumpout facilities mean that ferries do not compete with other vessels in the demand
for pumpout capacity.
NOAA Research Ships ("Public Unclassified")
The National Oceanic and Atmospheric Administration (NOAA) Marine Operations
Center - Pacific reported to Ecology that some of their research vessels may be impacted by the
NDZ, specifically identifying four vessels (two hydrographic survey ships and two research
ships) that would require pumpout facilities (Herrera, 2013). The frequency with which these
2 A full accounting of the data used to generate these estimates is provided in the "Sewage Gen & Pumpout Int" tab
of the Tool, as well as in the References section of this document.
12
-------
vessels would operate in Puget Sound was not well-defined. Per Herrera (2013), the
hydrographic survey vessels are "typically in Seattle for a few days to a week prior to going up
to Alaska, although at times they may be in Puget Sound for longer periods (weeks or months)
doing research." Similarly, the research vessels are "typically in Seattle for a couple of weeks
twice a year prior to going up to Alaska, or they may be in Puget Sound for longer periods of
time doing research." In conversation with EPA on January 29, 2021, NOAA staff indicated that
the typical operating season ranges between April and October, with the majority of activity
occurring in Puget Sound from April to mid-May and September to October, which is when
vessels will be transiting to and from Alaska. As such, EPA used two operating seasons in the
Tool for this type of vessel: April 1 through May 15 and September 1 through October 31.
NOAA also confirmed that most trips last for a few days to approximately six weeks.
The two types of NOAA research vessels have as many as 55 and 40 persons onboard,
respectively, so an average of 48 crew was used in EPA's analysis. In the absence of specific
data regarding sewage generation rates, EPA used an estimate of sewage generation on board
cargo/container/tanker ships as a proxy. This estimate - 11 gallons per person per day - was a
median value derived from information provided to EPA by the Chamber of Shipping of
America (2010).
EPA estimates that these vessels would pump out approximately every three days while
operating in Puget Sound. The source of this value is "The NOAA Fleet Plan: Building NOAA's
21st Century Fleet" (NOAA, 2016). In discussing the effect of environmental regulations and
policies on fleet operations, the report states that because of vessel discharge requirements under
the Clean Water Act, "ships operating in coastal or protected areas must break operations every
two to four days to transit from the working ground to perform these necessary services." This
was confirmed in conversation with NOAA staff on January 29, 2021, who estimated that
pumpouts would be needed every three to five days. EPA further assumed that these vessels
would not need to travel additional distances to use pumpout facilities, as mobile facilities could
be called to service the vessels where they are receiving other services.
As reported by Ecology, all four of the ships were equipped with holding tanks with
capacity ranging from 8 to 10 hours for the hydrographic survey vessels, to three days for the
research vessels. However, these NOAA vessels have since upgraded holding capacity to comply
with the NDZ (see Memorandum to File). As such, the cost assessment assumes that 100% of
"public unclassified" vessels have holding tanks (installed in anticipation of the establishment of
the NDZ). While these vessels have sufficient holding capacity, they are still included in EPA's
screening analysis because they do not have dedicated pumpout facilities and, therefore, require
continued access to available public facilities.
Pumpout Facility Information
This section describes the available pumpout facilities identified by EPA for use in the
analysis. Information regarding the facility characteristics was gleaned from the various reports
produced for and by Ecology, as well as additional information provided by AWO. In some
cases, information was obtained from the pumpout facilities themselves, either via company
websites or from conversations with company representatives (see Memorandum to File). This
13
-------
section also explains EPA's reliance on default values in the absence of Puget Sound-specific
data or information.
Because the stationary facilities identified by Ecology in its application may not be
suitable or accessible to certain larger commercial vessels, EPA limited its costs analysis for
available and adequate pumpout facilities to include only mobile facilities identified by Ecology
in the January 2021 submission and the stationary facilities at the Port of Bellingham. Fifteen
mobile pumpout companies operate 69 individual facilities (i.e., a truck, boat, or barge). EPA
gathered information about service hours per day, days per week, and months per year of
operation for each facility primarily from company websites when available, and in some cases,
conversations with certain operators.3 If this information was not readily available, EPA assumed
pumpout service to be available 16 hours per day, five days per week with year-round operation.
While some recreational vessel pumpout facilities may close during the off-season, such closures
are not expected to affect commercial vessel pumpout operations, particularly those able to
service other sectors or pumpout needs (e.g., septic tanks). EPA supported this assumption by
contacting some of the companies, each indicating that services are available 365 days per year
(see Memorandum to File). To determine the maximum volume of sewage that each facility can
pump per day while in operation, the Tool has fields for whether the facility is connected to a
sewer and, if not, the size of the holding tank at the facility. EPA used information provided by
Ecology and AWO in their January 2021 submissions and, in some cases, the companies
themselves, regarding the size of holding tanks for the individual facilities.
An explanation of the fees used in the analysis is provided in the table below.
Company Name
Fee Information
Rose Head Service
According to Ecology's January 2021 submission, the fee is $18 and
up. Rose Head Service website provides pricing between $15 for
weekly service up to $25 for on-call service. However, for large
tanks (>50 gal), the website indicates that a quote is required. As
such, EPA did not populate the fee inputs.
SS Head
Per company website, "larger tanks" are serviced at a rate of $20 per
pump plus $0.20/gallon.
Arrow Marine
Services
Default value used. Per AWO's recent information submission,
Arrow was unable to provide a rate sheet.
Port of Bellingham
Pumpout services are free of charge.
Pump Me Out
Per Ecology's January 2021 submission, the fee is $35-45.
Pelican Pump
Per Ecology's January 2021 submission, the fee is $20 and up.
Seattle Sanitation
Services/SaniTug
Per Ecology's January 2021 submission, the fee is $20-25.
Elliott Bay Marina
Per Ecology's January 2021 submission, the fee is $25 and up.
Marine Vacuum
Services
Default value used.
Washington Marine
Cleaning
Per AWO's January 2021 submission, "Each time that a vessel
undergoes service for pumpout from the company would cost
3 See Memorandum to File.
14
-------
between $5,000 and $7,000." A company representative provided
EPA with a rough estimate of approximately $175/hour plus $0.57
per gallon (including disposal fees). These are the values used by
EPA in the analysis; however, the representative did note that
additional variable fees may apply (e.g., tolls, PPE) (see
Memorandum to File).
NRC
Per AWO's January 2021 submission, "Pumpout service from NRC
costs $135/hour for the truck and an additional $0.50 - $0.85 per
gallon of effluent removed." NRC also charges "additional disposal
costs." As such, EPA used the high end of the range, $0.85/gallon.
Emerald/ CleanHarbors
Per Ecology's January 2021 submission, "Pumping costs estimated
at $1,700 for about 6 hours of work and 1,500 gallons of sewage
($0.25/gallon King County rate)." Using these values, EPA estimated
a rate of $220/hour, in addition to the $0.25/gallon charge.
Sound Marine &
Industrial Services
According to a company representative, a recent pumpout service
had a rate of $154/hour and $0.25/gallon, plus a small fuel surcharge
(see Memorandum to File).
Sanitation Offloading
Solutions
Per Ecology's January 2021 submission, the fee is $35 and up.
Pumpout Seattle
Per Ecology's January 2021 submission, the fee is $25 and up.
NW Mobile Pump Out
and Marine
Environmental
Services
Per Ecology's January 2021 submission, the fee is $20-30 and up.
Lastly, EPA assumed that commercial facilities would use a vacuum system with a
working flow rate ranging between 75 and 100 gallons per minute (gpm), with an average of 88
gpm (Alaska Clean Harbors, no date; Keco Pump and Equipment, no date). EPA uses this default
pump rate value throughout the analysis.
Cost Information
There are five cost inputs in the Tool, provided as default values, that are used to
calculate a variety of the cost outputs. These include annual baseline operating costs for
commercial vessels, vessel speed, fuel consumption, hourly revenue, and fuel price. For the
Puget Sound cost analysis, EPA used the default values for all the inputs for tugboats,
commercial fishing vessels, and excursion vessels, as explained below. Default values were not
available for NOAA research ships.
Annual Baseline Operating Costs
For tugboats, EPA initially anticipated using a baseline operating cost estimate of
$853,260 per year based on a U.S. Army Corps of Engineers Department of Civil Works
memorandum (2004) that estimates the daily operating costs for the Mississippi River towboats.
Because the estimates are in 2004 dollars, the Tool converted the amounts to 2018 dollars.
Because the information available to EPA pertained to towboats in the Mississippi River and
may not be perfectly representative of coastal tugboats in Puget Sound, EPA reviewed
15
-------
information on annual operating costs for Puget Sound tugboats available in a report by Herrera
(2015) to decide whether to adjust the initial estimate. The report provided a range of operating
costs between $510,000 and $1.9 million. EPA also solicited information directly from AWO on
operating costs for tugboats in Puget Sound, which AWO provided in its January 2021
submission, quoted below.
Six AWO companies were surveyed for operating costs in December 2020. The low
range of estimates for annual operating costs ran between $1 million - $1.5 million. The
highest annual operating cost estimate ranged between $8 million - $10 million. Most
harbor-assist towing vessels range between $3 million - $7 million in annual operating
costs. Averaged out over the entire diverse fleet of AWO member vessels, the average
approximate operating cost of crewing, vessel maintenance, insurance, regulatory
compliance, and regulatorily required drydocking for a towing vessel operating in Puget
Sound in 2020 is approximately $4 million...
AWO's estimates are substantially higher than EPA's initial default value and the information
provided by the Herrera report. For this reason, EPA explains the different outcomes when
applying baseline operating cost assumptions of both $853,260 and $4 million to account for this
wide range.
For commercial fishing vessels, the default annual baseline operating cost of $377,893
was taken from the Valdez Harbor Expansion Feasibility Study (U.S. Army Corps of Engineers,
2010). The default values for excursion vessels in the Tool are the same as those used for ferries.
The annual baseline operating cost of $1,884,944 is an average of the operating costs found
across 11 different sources.4 See the "Bsln Cost Assumptions" tab in the Tool for more details.
Vessel Speed
The default vessel speeds in nautical miles per hour used for each vessel class are 11.75
for tugboats (based on vessel speeds reported by Weeks Marine (2019)), 13 for commercial
fishing vessels (based on the cruising speed of a tuna purse seiner from (Mauric Sea Novators,
no date)), and 30.5 for excursion vessels (based on the average speed of two whale watching
vessels from Boston Harbor Cruises). See the "Compliance Cost Assumptions" tab in the Tool
for more details.
Fuel Consumption
Average fuel usage in gallons per hour for each vessel class was estimated by dividing
horsepower by 10 (Lee, 2013). Average horsepower for each vessel class was based on a review
of California commercial harbor craft (South Coast Air Quality Management District, 2015).
Average fuel consumption (gallons per hour) was estimated as 98.2 for tugboats, 30.1 for
commercial fishing vessels, and 82.7 for ferries and excursion vessels. In EPA's analysis,
tugboats were the only class expected to travel to access pumpout facilities, therefore incurring
4 (State of Washington Joint Transportation Committee, 2006); (U.S. Department of Transportation, 2011a; 2011b);
(Skagit County, WA, 2019); (Whitman, Requardt, & Associates, 2015); (U.S. DOI, 2010); (Economic & Planning
Systems, 2015; 2019), (Cambridge Systematics, 2011); (Whatcom County Public Works, 2018); (NelsonNygaard
Consulting Associates, 2006).
16
-------
costs associated with these fuel consumption values. Another source of information consulted by
EPA indicates that "modern tugs, with power ratings of 3,000 to 5,000 hp, burn large amounts of
fuel when operating at full rpm — anywhere from 100 to 200 gallons per hour for a harbor tug
pushing against a ship" (Walsh, 2008). Because tugboats would not actively be working while
transiting to a pumpout location, EPA retained the lower default value of about 98 gallons per
hour. See the "Compliance Cost Assumptions" tab in the Tool for more details.
Hourly Revenue
The tugboat hourly revenue default value of approximately $1,300 used in the Tool is
based on the estimate provided by Herrera (2015) for Puget Sound. For commercial fishing
vessels, EPA calculated a default value using commercial fishing revenue and catch volume data
for the Pacific (Pacific Fisheries Information Network, 2019) and Atlantic (ACCSP, 2019)
coasts. EPA determined an average dollar of revenue per megaton of catch and multiplied by the
average capacity of a fishing vessel to generate an average hourly revenue estimate of $1,676.
For excursion vessels, EPA used an hourly revenue estimate of $1,300, rounding up from the
value developed for ferries based on the Washington State ferry fleet (San Juan County).
Fuel Price
Lastly, for all vessel classes, EPA used an average fuel price of $2,256 per gallon. This
was the national 2018 average price per gallon for No. 2 diesel fuel from the Energy Information
Administration (2019). EPA acknowledges that there is likely regional variability with state and
local fuel taxes. However, EPA anticipates that, due to minimal expected travel, these changes
would have an insignificant impact on the Tool calculations.
Values used for NOAA Research Ships
Default values were not available for the NOAA research ships. As such, EPA obtained a
rough estimate of the annual baseline operating costs from NOAA's (March 2018) "NOAA Fleet
Societal Benefit" final report, which provided total annual operating costs for 16 vessels in the
fleet, totaling $108,568,526. EPA used the average value of $6,785,533 in the Tool. Average
vessel speed for these ships was determined to be 12 nautical miles per hour using an average of
the reported speeds of five ships based in NOAA's Pacific Marine Operations Center (Rainier,
Bell M. Shimada, Fairweather, Oscar Dyson, and Reuben Lasker) from the Center's website. In
the absence of more specific information, the fuel consumption value for ferries and excursion
vessels was used. The default value for fuel price was also used. Because NOAA research ships
are federally owned vessels, EPA did not attempt to establish a value for hourly revenue.
Output
After running the cost Tool - with the aforementioned inputs - it is projected that
available pumpout capacity will always exceed the demand for pumpout services in Puget
Sound. Before applying the uniform demand scenario, the Tool calculates ranges for demand and
capacity. As shown in the Table and Figure below, minimum demand (which equates to the
demand from vessels that pumpout every day) is approximately 22,400 gallons. In the case of
Puget Sound, only commercial fishing vessels are expected to pump out every day. As such,
minimum demand represents the total daily volume produced by the 350 fishing vessels that
would need to be pumped out. Maximum demand (which reflects the total daily demand from all
17
-------
vessel classes) is approximately 529,000 gallons. Capacity, on the other hand, reflects the day
and month in which the smallest/fewest facilities are operating (total minimum capacity) and the
day and month in which the largest/most facilities are operating (total maximum capacity).
Total - minimum
Total - maximum
Demand (gallons/day)
22,400
529,057
Capacity (gallons/day)
3,168,000
3,943,632
Figure 1: Screening Analysis
3,943,632
a nm nm
3,500,000
3,000,000
2,500,000
2,000,000
1,500,000
1,000,000
529,057
3,168,000
22,400
u
Demand (gallons per day)
Capacity (gallons per day)
Applying the uniform demand scenario, EPA can more precisely model the frequency with
which demand may exceed capacity. The results are shown in the table below.
Minimum daily demand (gallons per day)
14,400
Maximum daily demand (gallons per day)
137,872
% of days where min. capacity meets demand
100%
% of days where max. capacity meets demand
100%,
This means that on days in the year when the least volume of sewage is pumped out, demand for
pumpout facilities is approximately 14,400 gallons. On days when the greatest volume of sewage
is pumped out, demand is approximately 137,000 gallons. Based on these estimates, both
minimum and maximum facility capacity meets demand every day of the model year. In other
words, pumpout capacity far exceeds projected demandfrom establishing an NDZ in Paget
Sound.
Because there are no days where maximum demand is expected to exceed minimum
capacity, the analysis estimates that vessels will generally not incur wait times (nor the
associated cost due to not being able to immediately access a facility) based on uniform demand.
EPA recognizes that some of the companies operating pumpout trucks may be involved in other
18
-------
services, such as pumping out septic tanks. However, over 80% of the available capacity could
be otherwise engaged while still meeting maximum demand even before applying the uniform
demand approach (see the Figure shown above). EPA also recognizes that some of the available
facilities have tank capacities that are not suitable for some vessel classes. For example, Rose
Head Service has a tank of 300 gallons, and so could not typically service vessel classes other
than commercial fishing vessels. As described earlier, EPA accounted for this when determining
the average cost for a pumpout for any given vessel class but cannot automatically do so for
calculating minimum and maximum capacity and demand. As such, EPA ran a parallel screening
analysis removing the facilities with more limited holding capacities. Facilities excluded from
the screening analysis were Rose Head Service, SS Head, Pump Me Out, Pelican Pump, Seattle
Sanitation Services/SaniTug, Elliott Bay Marina, Sanitation Offloading Solutions, Pumpout
Seattle, and NW Mobile Pump Out and Marine Environmental Services. The facilities that
remained in the parallel analysis have capacities of roughly 3,000 gallons or more. This results in
available facility capacity between 3,104,640 (minimum) to 3,400,320 (maximum) gallons per
day. Even when removing the smaller capacity facilities altogether, minimum capacity still
exceeds maximum demand throughout the year.
A breakdown of cost by vessel class for tugboats, commercial fishing vessels, and
excursion vessels is provided in the table below. Ferries and NOAA vessels were not included in
the summary table below, since ferries have dedicated pumpout facilities and the NOAA vessels
all have holding tanks in the baseline, such that no increased baseline costs are anticipated as
there are no wait time costs.
Commercial Fishing
Vessel Class
Tugboats
Vessels
Excursion
Total number of vessels
150
350
63
Number of vessels w/ holding tanks
38
175
60
Number of vessels w/o holding tanks
113
175
3
Annual baseline operating costs ($/year)
$853,260
$377,893
$1,884,944
Annual facility use costs ($/year)
$15,562
$5,171
$91,710
Annual travel costs - fuel ($/year)
$1,639
$0
$0
Annual travel costs - lost revenue ($/year)
$9,615
$0
$0
Annual pumpout time costs - lost revenue ($/year)
$31,223
$4,327
$67,681
Annual wait time costs - lost revenue ($/year)
$0
$0
$0
Total annualized compliance costs ($/year)
$58,038
$9,498
$159,391
Expenditure test - vessels w1 holding tank
0.0%
0.0%
0.0%
Expenditure test - vessels w/o holding tank
6.8%
2.5%
8.5%
EPA estimates that none of the vessel classes with holding tanks already installed prior to
establishment of the NDZ will experience new/incremental costs. Most of the costs associated
with using pumpout facilities were already part of these vessels' baseline operating costs. No
wait time costs are expected for these commercial vessel classes in Puget Sound according to the
uniform demand model.
For vessels without holding tanks in the baseline, the percent increase in baseline
operating costs ranges from 2.5% to 8.5% across the vessel classes. The excursion vessels
experience the greatest increase, at 8.5%. However, only three of the 63 excursion vessels
included in the analysis do not have holding tanks; EPA expects only those three vessels to incur
the increased costs. EPA used a conservatively high value of 187 passengers for excursion
vessels, whereas Herrera (2013) reported that most of these vessels carry 60 passengers or fewer.
If the analysis is conducted using the more realistic 60-passenger value, the percent increase in
operating costs for these vessels drops to 2.9%. EPA also notes that, to the extent possible, some
19
-------
or all of these costs may be passed on to customers, and that pumpouts may be able to occur
concurrently with other necessary activities (such as boarding and offloading passengers), such
that the lost revenue due to annual pumpout time costs may be overestimated. Lastly, it is
important to note that the percent increase in baseline operating costs for excursion vessels
would not substantially change if more pumpout capacity was available unless the price for
pumpout services was driven down as a result. These vessels' high costs are the result of the
large volumes of sewage produced onboard, due to the comparatively high number of
passengers. For these reasons, EPA does not consider the 2.9% to 8.5% increase in operating
costs for these three vessels to be unreasonable. Even if such an increase was untenable for these
three of the 63 excursion vessels in Puget Sound, EPA's statutory role is to determine the
reasonable availability of pumpout facilities for all vessels. If 60 of 63 vessels within the vessel
class can operate viably based on current pumpout capacity, adequate facilities are reasonably
available. Given that numerous excursion vessels operating in Puget Sound are already equipped
with holding tanks, EPA did not find these added costs to be unreasonable.
Tugboats are expected to experience a 6.8% increase in baseline operating costs, resulting
from facility use costs, travel costs, and pumpout time costs, based on the lower default value for
baseline operating costs. According to AWO in the January 2021 submission, . .NDZ operating
costs add approximately roughly 5% to 10% to the average vessel's annual operating costs.
These costs do not include retrofits or modifications, or the cost to replace a vessel that cannot be
physically altered to comply with NDZ requirements." EPA's estimate of 6.8% falls within
AWO's predicted range; however, AWO provided to EPA a much higher baseline operating cost
(average of $4 million). Using AWO's figure of $4 million, the resulting percent increase in
baseline operating cost drops from 6.8% to 1.5%.
Because the default used by EPA results in a higher percent increase, EPA conservatively
continued to use the original value of $853,260. Using an estimate of annual baseline operating
cost of $853,260, a 6.8% increase equates to about $58,038 per vessel per year. As described by
Herrera (2015),
The size of tugboat companies that operate in Puget Sound range from small to very
large. An example of a small company would be Campbell Maritime, which operates four
tugboats, almost exclusively within Puget Sound. At the opposite end of the spectrum,
Foss Maritime, operates more than 200 tugboats worldwide and has homeports on every
continent (Saltchuk 2015). In the middle are companies such as Western Towboat, which
operates 21 tugboats in Puget Sound and in Alaska. Foss' gross annual revenue was
reported to be more than $430 million (Saltchuk 2015), which would equate to an annual
revenue of about $2 million per boat. Calculated differently, assuming a tugboat does
paid work for 12 hours a day, 365 days a year at a rate of $600 to $2,000 per hour, annual
revenue would be $2.6 million to $8.7 million per boat.
Using Herrera's high-end and low-end estimates of annual revenue, $2.6 million and $8.7
million per vessel, an increase of $58,038 in operating cost equates to between 0.61% and 2.2%
of annual revenue per vessel. Importantly, about $31,000 of that increase is attributable to lost
revenue due to the time it takes to pump out. However, these costs would only be incurred when
the vessel operator has turned down billable work to pump out. In other words, if the vessel can
schedule pumpouts in between jobs, then revenue is not being lost. This is similarly
acknowledged in Ecology's final cost-benefit analysis for the proposed NDZ (Ecology, 2018).
20
-------
As such, the true cost is likely lower than the estimate because vessel operators may be able to
pump out between scheduled work. Additionally, had EPA used the $4 million value for baseline
operating cost for tugboats, the percent of annual revenue per vessel would also be lower.
Commercial fishing vessels are expected to experience a 2.5% increase in baseline
operating costs, resulting from facility use costs and pumpout time costs. Based on a baseline
operating cost of $377,893 (as explained in the Cost Information section above), this increase
amounts to a dollar value of about $9,498 per vessel per year. As described by Herrera (2015),
Washington statewide revenue for commercial finfish was approximately $160 million in
2013. Statewide revenue for shellfish, which includes crabs and clams, was about $44
million (WDOR 2015). Based on this revenue estimate and dividing by the 347 fishing
vessels in Puget Sound (Herrera 2013), a gross estimate of the approximate revenue
generated per vessel per year would be $575,000. A substantial number of Washington-
based fishing vessels participate in fishing activities within and outside of Washington
State and may therefore generate additional revenue that would not be included in this
estimate... Since many vessels sell their fish outside of Washington State, the actual
revenue per vessel may be substantially higher for at least some portion of the
commercial fishing fleet based out of Puget Sound.
Using the $575,000 estimate for annual revenue, an increase of $9,498 in operating cost
equates to 1.6% of annual revenue per vessel. Unlike local tugboats and excursion vessels,
commercial fishing vessels have less flexibility in pricing their goods since they typically enter a
global seafood market. However, as noted in the quote above, it is possible that certain vessels
have higher annual revenues than used here, so 1.6% may be an overestimate of the increase.
Finally, as noted earlier, because NOAA's hydrographic survey ships and research ships
already have been retrofitted and no wait time costs are expected, EPA does not anticipate that
these ships will incur any increases to baseline operating costs.
Recreational Vessels
In addition to considering the cost implications of the NDZ on non-oceangoing
commercial vessels, EPA considered costs to recreational vessels. Of the recreational vessels
expected to have installed toilet facilities, Ecology (2018) reported that approximately 91% were
already equipped with holding tanks, leaving about 2,013 vessels that would need to retrofit and
therefore incur increased costs from using pumpout facilities. As explained by Ecology in the
State's initial application, "on-going costs for recreational vessels to pumpout is minimal, with
most pumpouts being free or $5 per pumpout" (Ecology, 2016a).
EPA has determined that this nominal fee is reasonable. Additionally, EPA does not
expect substantial costs associated with traveling to access a pumpout facility because marinas
with free or low cost pumpout facilities are distributed throughout Puget Sound (see Table 1 in
Appendix C for an updated list of pumpouts available for recreational vessels). While
commercial vessels have hourly revenue that can be impacted by lost time due to pumping out,
as well as wait times, recreational vessel operators do not face monetary costs, although waiting
for pumpout would take time away from other leisure pursuits. Although they do not face
monetary losses from wait times, recreational vessel operators do still have an incentive (the
value of their leisure time) to spread out their pumpout demands. As such, EPA did not calculate
21
-------
a cost associated with the time waiting to access a pumpout facility or the time to pump out the
holding tank of a recreational vessel. After considering cost of compliance to recreational
boaters, as well as the other factors mentioned above and information in the administrative
record, EPA has determined that there is reasonable availability of pumpout facilities for
recreational boaters to comply with the NDZ.
Summary of Ecology's Cost Benefit Analysis
As part of the Washington State rulemaking process to designate the NDZ, Ecology
(2018) developed a "Final Regulatory Analysis" report that included a final cost-benefit analysis.
While EPA independently assessed the costs associated with its determination whether adequate
pumpout facilities are reasonably available, as noted in the Court's order, EPA "is not starting
from scratch." American Waterways Operators v. Wheeler, No. 18-cv-2933, atDkt. 66, p. 42.
Though EPA does not consider retrofit costs to be attributable to its pumpout facilities
determination, Ecology did consider that such costs would be attributable to its establishment of
the NDZ and it considered the benefits of doing so. Though EPA considered the costs as
described above, EPA did not conduct a "cost-benefit" analysis because CWA section 312(f)(3)
assigns the determination of benefits to the State rather than to EPA.
As explained in Ecology's report, "Ecology concludes, based on reasonable
understanding of the quantified and qualitative costs and benefits likely to arise from the rule,
that the benefits of the rule are likely greater than the costs." In the analysis, EPA did not
consider retrofit costs, whereas Ecology did. Ecology estimated that the total 20-year present
value for retrofit costs are approximately $511 million to $551 million, of which between $113
million to $153 million is the estimated cost to business and government. The bulk of anticipated
retrofit costs fall to recreational vessels, for which the NDZ is already in effect. For the second
category - pumpout costs - Ecology determined that the total 20-year present value costs are
estimated to be between $191 million and $212 million, the majority of which (about $148
million) are expected to be incurred by tugboats and similar vessels.
In its analysis, Ecology assumed that pumpouts for tugboats and commercial fishing
vessels would cost "approximately $1 thousand per pumpout via truck, every two weeks, for
each vessel." Additionally, Ecology estimates that lost revenue for tugboats would amount to
approximately $2,500 to $3,000 per pumpout, but only in such cases where billable work was
forgone to pumpout. EPA's estimates were roughly in line with Ecology's, as EPA estimated that
an individual pumpout for a tugboat would cost about $900 in fees, plus roughly $1,800 in lost
revenue. As noted above, Ecology assumed the same cost to each commercial fishing vessel of
$1,000 per pumpout every two weeks. EPA's estimate for commercial fishing vessel pumpout
fees was substantially lower, since these vessels can access less expensive pumpout facility
options and are expected to pump out a small volume of sewage daily (rather than every two
weeks). Installing a smaller holding tank that is pumped out more frequently would allow for less
displacement of fish hold space for the vessel, so EPA does not expect that these vessels would
only pump out every two weeks.
For small commercial passenger vessels, Ecology estimated that each vessel would incur
annual pumpout costs of $25,000. EPA's analysis determined an annual pumpout facility use
22
-------
cost of nearly $92,000 per vessel. This discrepancy is likely due to EPA's overestimation of the
number of passengers and crew onboard these vessels. As noted earlier, Ecology reported that
most vessels carry 60 or fewer passengers, whereas EPA conservatively assumed a value of 187
(over triple Ecology's estimate). Using 60 as the input for average crew/passengers, EPA's
facility use cost estimate drops to about $33,000, which is comparable to Ecology's estimate.
Lastly, Ecology acknowledged that recreational vessel operators will incur costs related
to pumping out, including facility use fees, fuel costs, and the value of time to pump out.
However, Ecology was not able to quantify these costs.
Ecology's cost benefit analysis considered environmental and public health benefits and
benefits to the shellfish industry (and avoided costs due to preventing illness), as well as costs to
retrofit vessels. EPA notes that even though the scope of the State's analysis was broader than
EPA's, Washington State still determined the benefits of establishing the NDZ outweigh the
costs.
Conclusion on Cost
EPA determines that the expected costs to affected vessels, both recreational and
commercial, to access and use pumpout facilities do not materially alter EPA's determination
that adequate facilities are reasonably available in the Puget Sound NDZ.
Recreational vessel operators in Puget Sound can access a substantial number of free
and/or low-cost pumpout facilities distributed throughout the NDZ and have been doing so since
the NDZ took effect for these vessels in May 2018.
For commercial vessels, EPA determines that the costs attributable to using pumpout
facilities would not result in an unreasonable financial burden nor affect the reasonable
availability of such facilities. Commercial vessels with holding tanks installed prior to the
designation of the NDZ already access pumpout facilities or discharge offshore, including an
estimated 25% of tugboats, 50% of commercial vessels, and 95% of excursion vessels. For
tugboats and commercial fishing vessels that do not already have holding tanks installed, the
anticipated percent increase in baseline operating costs for each vessel represents a small fraction
of the vessel's annual revenue. While excursion vessels experience the highest cost increase
based on conservative estimates of the average volume of per passenger sewage generated daily
and the numbers of passengers per vessel, only three of the 63 excursion vessels would be
expected to even incur these new costs after application of EPA's conservative assumptions in
the cost analysis.
Additionally, the NDZ applies to all vessels, and therefore does not provide a competitive
advantage or disadvantage to any particular entity. Instead, such costs will be folded into the
existing "cost of doing business" in Puget Sound, which Washington State has already
determined to be reasonable and warranted in exchange for the benefits of the vessel sewage
discharge prohibition. While EPA does not consider the above costs to be prohibitive to the
continued operations of these vessel classes in Puget Sound, it is possible that some individual
vessels may bear more significant adverse effects due to issues such as vessel design
configuration. However, the exclusion of a small number of vessels resulting from an NDZ
23
-------
designation does not preclude a determination that adequate pumpout facilities are reasonably
available in Puget Sound as a whole. Further, cost to pump out would not be significantly
different if there were increased pumpout capacity because available capacity is not a limiting
factor based on EPA's screening analysis demonstrating that pumpout capacity already exceeds
the volume of sewage generated that would need to be pumped out.
Reasonableness of Available and Adequate Sewage Treatment Facilities
in Puget Sound
This section explains EPA's assessment of the extent to which adequate sewage treatment
facilities are available in Puget Sound to support the NDZ.
EPA's final determination in February 2017 assessed the availability of adequate
treatment facilities. However, the Court remanded the issue after concluding that the
administrative record was insufficient in explaining EPA's assessment with respect to treatment
of sewage from commercial vessels. Upon remand, EPA reviewed and re-considered information
in the existing administrative record, invited the parties in the litigation to provide updated data
and information, and conducted additional fact-finding to inform its further consideration of the
issue.
EPA invited updated data and information related to the locations where pumped out
vessel sewage is treated, a description of how sewage treatment facilities are regulated by the
State, how the State ensures compliance with State and federal requirements, and any
information related to pumped out vessel sewage that is not treated at a regulated treatment
facility. EPA also invited updated data and information on the capacity of sewage treatment
facilities to accommodate the incremental increases in vessel sewage that could reasonably be
attributed to the establishment of the Puget Sound NDZ. In the December 10, 2020 invitation,
EPA explained its expectation that information from Ecology would be particularly relevant
since it is the primary regulatory authority for sewage and the protection of water quality under
the Washington Revised Code. See RCW 90.48.
On January 8, 2021, the parties in the litigation provided updated data and information.
Among other things, Ecology explained that, on average, Puget Sound treatment plant actual
flows are about 47% of design capacity, thereby demonstrating that sufficient capacity exists at
regulated treatment facilities to accommodate vessel sewage from a Puget Sound NDZ. In
addition, Ecology provided information identifying the various treatment facilities where
pumped out sewage is sent and how such facilities are appropriately regulated under State and
federal law to provide safe and sanitary treatment of vessel sewage from all vessels, commercial
and recreational, in Puget Sound and even in the summer, when vessel sewage volumes are
highest. Ecology's 2016 NDZ petition and January 2021 supplement included multiple tables
(see Appendix C) summarizing data collected on available pumpout options for recreational and
commercial vessels. The January 2021 supplement is particularly relevant as it contains
information that captures the time period since May 10, 2018, when the Puget Sound NDZ came
into effect (with the exception of certain commercial vessels which were exempted for five years
before needing to comply with the NDZ requirements).
24
-------
Analysis of Adequate Sewage Treatment in Puget Sound
Based on review and consideration of the expanded administrative record, EPA
concludes that there is adequate - safe and sanitary — treatment capacity to accommodate sewage
generated from all commercial and recreational vessels operating in Puget Sound. Land-based
sewage treatment operations along the shores of Puget Sound waters are operating well below
design treatment capacity (actual flow average per month is only 47% of WWTP design
capacity). These treatment facilities are subject to a regulatory infrastructure to assure that
sewage is adequately treated prior to discharge. Adequate treatment facilities are located
throughout Puget Sound that provide more than sufficient capacity for the treatment of vessel
sewage generated all year round. The adequacy of the treatment capacity and infrastructure is
described primarily in materials provided by Ecology. The tables provided in Ecology's January
2021 submission and referenced in the ensuing analysis can be found in Appendix C.5
Table 3 of Ecology's January 2021 submission provides information on the commercial
vessel stationary pumpouts in Puget Sound, including the location of the pumpout facilities, the
vessels serviced, and the disposition of sewage - all of which is disposed at National Pollutant
Discharge Elimination System (NPDES) permitted WWTPs.
Table 4 provides information related to mobile vessel pumpout (removal) services in
Puget Sound, including the areas serviced by each company, the vessels serviced, the capacity of
each facility, and where each company disposes of pumped out sewage. All of these pumpout
companies transfer removed vessel sewage to NPDES-permitted WWTPs for treatment, except
for the pumpout boat located at Point Roberts Marina, which transfers its collected vessel sewage
to a Large Onsite Septic System regulated by the Washington Department of Health.
Table 5 lists the number of pumpout truck companies by county and identifies the typical
disposal location for each county (mainly NPDES-permitted WWTPs). As Ecology noted in its
2021 submission, because pumpout trucks travel to a variety of docks and commercial vessel
sites, they can transfer sewage removed from vessels to various terrestrial NPDES-permitted
WWTPs throughout Puget Sound. Some pumpout trucks may also discharge to "biorecycling"
facilities, which are regulated by an Ecology-issued Biosolids Permit per the Washington
Administrative Code 173-308.
State and Federal Wastewater Regulatory Structure
This section contains a description of the State and federal regulatory structure that helps
to ensure the adequate treatment of sewage at the following three categories of treatment
5 Table 1 of Ecology's January 2021 submission provides updated information on pumpout and treatment facilities
for recreational vessels. In its 2017 NDZ determination, EPA previously concluded that adequate treatment facilities
for recreational vessels were reasonably available. The Court's remand directed EPA to assess whether adequate
treatment facilities for commercial vessels were reasonably available. Notwithstanding the scope of the Court's
remand, EPA agrees with Ecology's analysis which concluded that all sewage from recreational vessels is treated at
facilities that are adequately regulated to ensure safe and sanitary treatment.
25
-------
facilities in Washington State: NPDES permitted wastewater treatment plants, septic systems and
biorecycling/biosolid facilities.
NPDES Permitted Wastewater Treatment Plants
In Washington State, EPA authorized the Washington Department of Ecology to
administer through provisions of State law, the NPDES permitting, compliance and enforcement
programs under the CWA.6 Ecology's January 2021 submission describes the State's
comprehensive regulatory program that addresses facility planning, performance standards,
permitting, operations and maintenance, and compliance. Notwithstanding Ecology's NPDES
permit authorization, EPA provides ongoing oversight of Ecology's NPDES permitting program
and retains independent authority to enforce NPDES permits and to object to permits issued by
Ecology. 40 CFR 123.44(c).
Ecology's January 2021 submission provides a thorough explanation of how the State
regulates WWTPs via NPDES permits consistent with the requirements of 40 CFR Part 123 and
WAC 173-220 and 221. Ecology must comply with State and federal laws and regulations when
administering Washington's NPDES permits program. This includes issuing permits with
technology-based effluent limitations and, when necessary, water-quality based effluent
limitations to assure compliance with applicable water quality standards. NPDES permits also
impose requirements including, but not limited to, discharge monitoring requirements to
demonstrate compliance with effluent limits, reporting of effluent data and immediate reporting
of non-compliance events, requiring planning or source controls when flows and pollutant
loadings reach 85% of plant capacity, requiring licensed operators as well as operations and
maintenance of wastewater treatment plants, and many other permit requirements to insure that
WWTPs treat wastewater in a safe and sanitary way.
Combined Sewer Overflows
Washington has established requirements for the control of combined sewer overflows
(CSOs) at WAC 173-245. CSOs occur during or after heavy precipitation events that exceed
older sewer collection systems' capacity, designed to receive both domestic sewage and storm
water, to deliver collected flows for treatment. The State law requirements, however, ensure that
all CSOs comply with technology-based effluent limitations and Washington's applicable water
quality standards at WAC 173-201 A. Washington's requirements are consistent with EPA's CSO
control policy. 33 U.S.C. § 1342(q); 59 FR 18688 (Apr. 11, 1994). As Ecology explained in its
January 2021 submission to EPA, all NPDES permits for communities with CSOs require the
community to implement the CSO control policy's "Nine Minimum Controls" as basic
technology-based standards for each CSO outfall. NPDES permits additionally require
communities to "achieve and maintain" compliance with the State's performance standard for
CSO discharges, per WAC 173-245.
Ecology's January 2021 submission identified three jurisdictions (the Cities of Seattle
and Everett and King County) in Puget Sound that are not in current compliance with the water
6 Ecology is authorized to issue NPDES permits for discharges into the waters of Washington State except that EPA
retains NPDES permitting authority for Indian Country and federal facilities within the State.
26
-------
quality-based federal and State requirements for CSO control. EPA is a party to the enforcement
consent decrees with King County and with the City of Seattle that established the judicially
enforceable requirements to bring the jurisdictions into compliance. U.S. v. King County, No.
2:13-cv-677 (W.D. Wash.), Dkt#6; U.S. v. City of Seattle, No. 2:13-cv-678 (W.D. Wash.), Dkt
#6. This important work, which will be completed over the next few years, will reduce the
number of CSO events by an expected 95% to 99%. See
https://www.epa.eov/enforcement/seattle-washineton-and-kine-coimtY-washineton-settlement.
In its January 2021 submission, Ecology noted that while CSO events are undesirable,
they are still preferable to discharges from marine sanitation devices. CSO discharges occur at
known locations and the municipal dischargers are required to provide prompt notification for
which the State can and does take public health measures to prevent exposure via warnings
against swimming, fishing, and shellfish harvesting in the CSO discharge area. By contrast,
absent a NDZ, discharges of vessel sewage may occur anywhere in Puget Sound and at any time,
and are not subject to notification requirements, even if discharging adjacent to a swimming or
shellfish harvest area.
Importantly, CSOs occur during wet weather events when there are large quantities of
stormwater in combined sewer systems (i.e., during the rainy season, which generally occurs
November-April in the Puget Sound region). By contrast, the peak vessel sewage capacity needs
in Puget Sound, which are associated with recreational boating season run May-September,
during the summer dry season. Because higher WWTP flows due to rain and wet weather events
occur primarily during the winter months, CSO events do not affect the treatment capacity
available during the summer when more vessels require pumpout and treatment services for
vessel sewage.
EPA concurs with Ecology's assessment that there is adequate capacity for sewage
treatment to accommodate a Puget Sound NDZ and that it is unlikely that pumped vessel sewage
will be sent to a WWTP during a CSO event. Although possible, this does not alter the fact that
facilities are reasonably available for the safe and sanitary treatment of vessel sewage to support
a Puget Sound NDZ, CSOs notwithstanding.
NPDES Compliance and Enforcement
Both EPA and Ecology have authority to enforce compliance with permitting
requirements for WWTPs. See 33 U.S.C. § 1319, RCW 90.48 and WAC 173-220-230. NPDES
permits contain terms and conditions related to compliance monitoring, including requirements
to sample effluent and report sampling results to Ecology. As the authorized regulatory authority,
Ecology reports that domestic WWTPs generally achieve a high rate of compliance with their
NPDES permits (98-99%> compliance rates). Ecology takes enforcement action against
permittees when needed to ensure compliance and has agency-wide and program-specific
compliance assurance protocols and procedures, including on-site inspections.
Septic Systems
Septic systems, also called onsite sewage systems, convey, store, and provide subsurface
soil treatment of sewage. In Washington State, onsite sewage systems are regulated based on the
27
-------
design flow of the system. According to Table 4 of Ecology's January 2021 submission, one of
the mobile pumpout companies transfers collected vessel sewage to a Large Onsite Sewage
Systems (LOSS).
LOSS convey, store, and provide subsurface sewage treatment with a design flow of
3,500-100,000 gallons per day. In Washington State, all LOSS systems must obtain and renew
annual operating permits from the Washington State Department of Health (DOH). The LOSS
rule (WAC 246-272B, developed under RCW 70.118B) requires LOSS owners and anyone
proposing to construct a LOSS to comply with applicable sections of the State's Water Pollution
Control Act (RCW 90.48), including surface and groundwater standards in accordance with
RCW 90.48.035. The State's LOSS rule includes the following: design, review and approval
requirements for construction; permit process requirements; engineering requirements; technical
standards; and operations, maintenance monitoring, and reporting requirements to meet
wastewater treatment standards.
Washington DOH has inspection and enforcement authority for LOSS, including the
assessment of civil penalties and issuance of orders, to ensure compliance with the applicable
laws and regulations. In addition, pursuant to RCW 90.48, Ecology has authority to take
enforcement action if there is a discharge from a LOSS to State waters. LOSS operators need
either a wastewater certification from Ecology (WAC 173-230), an approval by a local health
jurisdiction, or be qualified to operate a LOSS using proprietary technology, depending on the
type of LOSS (WAC 246-272B-07200).
Onsite Sewage Systems (OSS) have flows of less than 3,500 gallons per day and usually
treat wastewater from private homes and restaurants. See WAC 246-272A. Pursuant to RCW
43.20.050, the Washington State Board of Health establishes minimum requirements for the
DOH and local health jurisdictions, integrating public health and environmental protection.
Per the Washington OSS rule, local health jurisdictions are responsible for permitting all
OSS and must develop written onsite management plans. Particularly relevant to the NDZ, the
counties that border Puget Sound must include a strategy to protect shellfish growing areas,
aquifers, and water quality standards for groundwater; identify operations, maintenance, and
monitoring requirements for OSS in Marine Recovery Areas; enforce OSS permit application,
operation and maintenance, and repair requirements; in addition to other OSS owner
responsibilities. The OSS rule includes other requirements such as system design, sizing,
installation, plus soil and site evaluation. OSS installers and pumpers must be approved by local
health officers prior to providing services within a local health jurisdiction. Local health
jurisdictions must enforce the requirements of WAC 246-272A or refer to a local prosecutor's
office of the attorney general. DOH may take enforcement action if a local health jurisdiction is
unable to or fails to enforce an OSS rule. OSS must be inspected every one to three years,
depending on the type of treatment system.
28
-------
Biorecycling/Biosolids
According to Table 5, some commercial vessel pumpout trucks discharge to biorecycling
facilities, which are regulated under a biosolids permit issued by Ecology pursuant to WAC 173-
308, in accordance with CWA section 405 and 40 CFR Part 503.
The Ecology biosolids permit requires treatment, standards, monitoring, management,
recordkeeping, and reporting for all sewage discharges. The biorecycling facility uses pathogen
reduction measures and vector attraction for land application as a beneficial use and, according
to the Ecology January 2021 submission, the discharges do not drain to surface waters and
lagoon filtrate is applied at agronomic rates.
EPA concurs with Ecology's assessment that facilities are reasonably available for the
safe and sanitary treatment of vessel sewage to support a Puget Sound NDZ, including in
situations where sewage is treated by septic systems and biorecycling facilities.
Analysis of Treatment Capacity
EPA considered capacity to pump out and treat sewage from Puget Sound recreational
and commercial vessels and determined that adequate capacity exists to accommodate the
incremental increase of sewage generated from vessels in the Puget Sound NDZ.
Pumpout Trucks
Table 5 provides updated information for commercial vessel pumpout truck companies
by county. The information includes the number of pumpout truck companies in each county,
websites for each county, as well as the typical disposal location for truck companies operating
in each county. Ecology contacted local health departments with shorelines in Puget Sound
regarding how pumpout trucks operate in their areas and where their sewage is offloaded (mainly
to NPDES-permitted wastewater treatment plants). Irrespective of whether pumpout trucks
deliver sewage to a WWTP or a biorecycling facility, all pumpout trucks take pumped out vessel
sewage to a regulated treatment facility.
Sewage pumpers and trucks are certified by county health departments per WAC 246-
272A and applicable county code. Regulations provide requirements for licensure, pumping
operations, and reporting. Pumpout trucks are certified or licensed with each county annually,
typically involving an annual application, fee payment, proof of insurance and bonding, and a
truck inspection. Most counties also require pumpout truck drivers/pumpers to complete an
educational requirement such as passing an exam on sewage handling. Reporting requirements
regarding sewage disposal location vary by county.
Recreational Vessels
According to Ecology's January 2021 submission, an individual recreational vessel
produces an estimated 1,092 gallons of sewage per year. Using a conservatively high estimate of
43,677 recreational vessels in Puget Sound, Ecology estimated recreational vessels produce
roughly 47.7 million gallons of sewage per year, with greater volumes generated during the May-
September boating season. Washington State Parks estimated roughly 11 million gallons of
vessel sewage were pumped out through CVA Grant Program pumpouts in 2019. Ecology's
submission acknowledged that this figure is imprecise but likely biased high because of
29
-------
inconsistent flow monitoring equipment. The estimate by Washington State Parks does not
include sewage from pumpout boats or from pumpouts not included in the CVA Grant Program.
Commercial Vessels
Certain commercial vessels are not yet subject to the Puget Sound NDZ due to a five-year
delayed implementation to allow sufficient time for planning and compliance. Ecology's 2016
NDZ petition identified approximately 676 commercial vessels likely to regularly need pumpout
services over time. Washington State Ferries, U.S. military vessels, and certain other vessels,
which already have holding tanks and use large-scale pumpout facilities when moored, were
excluded from EPA's calculations because dedicated pumpout facilities exist for these vessels.
EPA estimated Puget Sound commercial vessel sewage volumes using the Tool to assess
costs described earlier in this document. The cost assessment methodology in the Tool provides
default estimates of sewage generation rates (gallon/person/day) by vessel class. See infra pp. 7-
12. The difference in rates is largely attributable to the efficiency of marine heads installed
onboard different vessel classes but is also dependent on the sources of information available to
EPA. In applying the methodology to Puget Sound, EPA assumed a sewage generation rate of 16
gallons per person per day for tugboats and commercial fishing vessels. For the remaining vessel
classes, EPA assumed sewage generation rates between 7 and 11 gallons. Applying the Tool
described above generated an estimated annual generation of 24.94 million gallons of sewage by
commercial vessels that would need to be pumped out (removed and treated) because of the
Puget Sound NDZ. This estimate does not include sewage generated by vessels with dedicated
pumpout facilities, such as Washington State Department of Transportation ferries and U.S.
military vessels. EPA notes that this is likely an overly high estimate based on the conservative
values selected for the Tool. For more details on tool functionality and assumptions made by
EPA to calculate this estimate, see the cost discussion, above.
Commercial vessels operate year-round, generally nearest to the urbanized areas on the
shores of Puget Sound that are serviced by large wastewater treatment plants with high design
capacity.
Total Capacity
Taken together, EPA estimates Puget Sound recreational vessels produce between 11 and
48 million gallons of sewage per year7, plus roughly 25 million gallons per year from
commercial vessels, for a (conservatively high) total of 36-73 million gallons of sewage per year
needing pumpout facilities in order to comply with the NDZ.
Ecology, as the authorized NPDES regulatory authority, projects that the design capacity
flow for all Puget Sound WWTPs is a peak flow of 708.8 million gallons per day, averaged over
a 30 day period (see p.14 of Ecology's January 8, 2021 submission). As of 2016, actual average
monthly flow was 335.7 million gallons per day - 47% of the design capacity (based on permit
defined design capacity and actual flows as reported to Ecology in NPDES Discharge
Monitoring Reports).
7 See discussions of recreational and commercial vessel sewage generation rates, above.
30
-------
Not surprisingly, however, monthly average actual WWTP flows vary seasonally. During
the May-September recreational boating season, monthly average actual WWTP flows are 3.618
million gallons per day; monthly average actual flows during the October-April period are 6.006
million gallons per day. WWTP design capacity flow averages 10.5 million gallons per day,
indicating there is ample capacity for the safe and sanitary treatment of vessel sewage
throughout the course of the year, with additional capacity during the summer boating season.
According to Ecology, "[treatment capacity is more than adequate because Puget Sound
WWTPs have hundreds of millions of gallons of design capacity per day and pumped vessel
sewage is estimated to be tens of millions of gallons per year" (Ecology's January 2021
submission, p. 3).
During the peak vessel sewage volume season, EPA agrees with Ecology's determination
that "[f]or commercial vessels, the volume generated by the 676 commercial vessels that are
likely to be in regular need of pumpout facilities in the NDZ is minimal as compared to the
significant capacity at the WWTPs in the Puget Sound area" (Ecology's January 2021
submission, p. 14). WWTP capacity dwarves the additional vessel sewage generated by a Puget
Sound NDZ, especially considering that the summer boating season occurs when there is
maximum design capacity. During the non-peak volume season, when recreational vessel use
diminishes, the overall treatment capacity available for sewage from commercial vessels remains
and effectively increases as a proportion of all vessel demand for treatment relative to the use by
recreational vessels.
In its January 2021 submission, AWO raised "the serious potential that future restrictions
on nutrient loading by the Washington Department of Ecology will preclude shoreside treatment
plants from accepting any additional sewage effluent," citing materials from a Puget Sound
Nutrient General Permit Advisory Committee meeting. EPA is aware of and has reviewed the
preliminary draft General Permit. The preliminary draft General Permit will likely establish
action levels for Total Inorganic Nitrogen that would trigger WWTPs to implement measures to
improve or optimize treatment. Accordingly, the draft General Permit does not suggest
reductions in treatment capacity but rather enhancements of treatment performance. All
terrestrial WWTPs will likely be required to report annually on their plans and actions to
optimize nitrogen reductions. The preliminary draft General Permit is focused on improving
treatment, and nothing in the draft permit places restrictions or limits on the quantity of sewage
that a WWTP can accept. The permit is further evidence of Ecology's efforts to ensure that all
sewage (transferred from a vessel or generated on land) is treated in a safe and sanitary manner.
EPA concurs with Ecology's assessment that there is adequate capacity to pump out and
treat sewage from recreational and commercial vessels to accommodate the incremental increase
of sewage generated from a Puget Sound NDZ.
Conclusion
After considering the information presented by the parties to the litigation, the existing
administrative record, and additional fact-finding to inform its further consideration of the issue,
EPA determines that there are adequate sewage treatment facilities with available capacity to
accommodate vessel sewage that must be pumped out as a result of the Puget Sound NDZ.
EPA determines that Puget Sound sewage facilities are regulated at the federal, state, and
local levels and in Indian Country and that there are adequate treatment facilities reasonably
31
-------
available in Puget Sound. Existing WWTPs can accommodate the extra sewage that is estimated
to be generated under a Puget Sound NDZ.
EPA's Use of a Ratio of Commercial Vessels to Pumpout Facilities
This section explains EPA's use of a ratio of commercial vessels to pumpout facilities in
the determination that adequate pumpout facilities are available in Puget Sound to support the
NDZ. In review of EPA's methodology for determining the availability of pumpout facilities, the
Court's remand directed EPA to explain why a ratio of commercial vessels to pumpout facilities
was helpful to its determination and why the particular ratio cited by EPA supported its
conclusion that pumpout facilities are reasonably available in Puget Sound.
In its 2017 determination, EPA considered the availability of sewage pumpout facilities
for recreational and commercial vessels separately, in part because EPA acknowledged that
commercial vessels serve a different purpose and face different constraints than recreational
vessels. Puget Sound has a larger and more complex commercial vessel constituency than many
other, previously designated, NDZs. Accordingly, EPA engaged AWO and commercial vessel
groups to understand their unique concerns and constraints prior to making a decision regarding
this NDZ. The information submitted by Ecology also bifurcated recreational and commercial
vessel and respective pumpout capabilities, in part because of the State's outreach and
stakeholder engagement efforts.
In its determination, EPA explained its rationale for the use of a ratio of pumpout
facilities to recreational vessels, the most conservative estimate of which was one pumpout
facility per 171 recreational vessels (1:171), not including mobile pumpout services. EPA
concluded that this ratio was well below the minimum ratio of 600 recreational vessels per
pumpout facility that the Fish and Wildlife Service recommended was reasonable under the CVA
and therefore determined that adequate pumpout facilities were reasonably available in Puget
Sound for recreational vessels, in addition to other factors described in this document and in the
record. EPA described its methodology for developing the ratios of pumpout facilities to vessels
in its final determination. 82 FR 11219-20.
Regarding commercial vessels, EPA found that there were at least 56 pumpouts available
for commercial vessels in Puget Sound, including both stationary and mobile pumpout facilities.
Based on the estimated 631 commercial vessels in Puget Sound, this created a ratio of 11
commercial vessels per pumpout facility (11:1). Id. EPA has since updated its analysis based on
new information regarding vessel populations (567 vessels) and the available pumpout facilities
(69 facilities), reflecting facility closures and available facilities that were newly identified (see
the cost section of this supplemental record for more detail on inputs to the analysis).
Unlike the CVA ratio for recreational vessels, EPA was unable to rely on an existing
benchmark to determine an appropriate ratio for commercial vessels. Whether the number of
available pumpout facilities is adequate is, at its core, a question of whether these pumpout
facilities can meet the demand from vessels. In the screening analysis conducted by EPA as part
of the Agency's review of cost, EPA projected that, based on available data and information,
32
-------
there are no days when existing pumpout capacity does not meet the demand for pumpout
services.
In its 2017 determination, EPA noted that the 11:1 ratio for commercial vessels supports
a "reasonable availability" determination because it is significantly lower (by a factor of 27) than
the conservative (low) end of the CVA technical guidance that there should be "one pumpout
station for every 300-600 boats," and 54 times lower than the high end of the CVA technical
guidance. In addition, mobile pumpout services can be scheduled by appointment to
accommodate vessel needs and itineraries and are sufficiently diversified such that they do not
experience seasonal fluctuations (e.g. during the summer boating season). As further supported
by the screening analysis conducted in the cost assessment, the identification of a vessel to
pumpout facility ratio is informative but not critical to EPA's determination of the reasonable
availability of pumpout facilities to service commercial vessel sewage needs in Puget Sound.
Unless and until EPA establishes otherwise by rulemaking, any determination about the
reasonable availability of pumpout facilities would be unique to each proposed NDZ and require
consideration of a range of factors relevant to the pumpout needs and capacity for each NDZ. As
the Court observed, EPA's affirmative determination of the reasonable availability of pumpout
facilities in Puget Sound was more nuanced than the simple calculation of a ratio. A WO, Dkt.
#66 at 32-33. Indeed, EPA considered other factors including the State's certificate of need,
geographic distribution of pumpout facilities, type of commercial vessels serviced, hours of
operation, capacity, draught requirements, time to pump out, dock access, seasonality, impact to
large cruise ships, impact on vessel itineraries, and information on vessel population and vessel
usage in Puget Sound, in addition to whether treatment of wastes from such pumpout facilities is
in conformance with federal law. See EPA's implementing regulations in 40 CFR 140.4(a).
Although no two NDZs are the same, prior EPA determinations of reasonable availability
that considered pumpout facility to vessel ratios are informative. For example, in its 2014
determination related to the establishment of a NDZ for the New York State (NYS) area of Lake
Erie, EPA calculated the ratio of commercial vessels to commercial pumpout facilities. (79 FR
35347). In its determination, EPA stated:
"Assuming, conservatively, that 100 large commercial vessels use the NYS area of Lake
Erie and given that at least four companies with as many as ten pumpout trucks are able
to provide pumpout services to these vessels at both New York ports, the ratio of
pumpout facilities to commercial vessels is at least 4:100, or 1:25. While the CVA
guidance applies, by its terms, only to recreational vessels, the ratio it recommends is
instructive for purposes of determining the reasonable availability of pumpout services
for large commercial vessels as well. In light of the relatively low ratio of pumpout
companies to large commercial vessels (and the even lower ratio of pumpout trucks to
large commercial vessels), adequate pumpout facilities for the safe and sanitary removal
of sewage for large commercial vessels are reasonably available for the New York State
area of Lake Erie."
33
-------
The ratio of pumpout facilities to commercial vessels in Puget Sound (11:1) is lower than the
25:1 ratio in the NYS areas of Lake Erie (although, as explained, other non-ratio factors were
also considered for each determination). Other NDZ determinations have also relied on a ratio of
vessels to facilities, whereby this ratio was compared to the ratio of 1 facility for every 300-600
vessels recommended in EPA's 1994 guidance. For two NDZs in New Jersey, a ratio of 1 facility
for every 200-300 vessels was used based on a New Jersey CVA steering committee
recommendation (63 FR 30742 and 63 FR 30740). These determinations provide further support
for EPA's determination that pumpout facilities are reasonably available for commercial vessels
in Puget Sound.
The 11:1 commercial vessel to pumpout ratio is a surrogate for pumpout capacity. Upon
remand, EPA has again analyzed volume demand and capacity; the screening analysis detailed
above now more quantitatively demonstrates that there is sufficient capacity to treat the volume
of sewage from the NDZ. See supra, pp. 15-16.
Given the widespread availability and flexibility of these services, including but not
limited to the resulting overall ratio of 11 commercial vessels per pumpout facility, EPA re-
affirms its earlier determination that adequate pumpout facilities for the safe and sanitary
removal and treatment of sewage for commercial vessels are reasonably available for the waters
of Puget Sound. EPA further notes that the estimated ratio may be conservative, given that
several mobile pumpout boats and pumpout trucks described above may also provide
commercial pumpout services. This determination is further supported by EPA's screening
analysis, which demonstrates that sufficient capacity would always be available in Puget Sound
to meet the demand for pumpout services from commercial vessels.
Conclusion
After consideration of the issues remanded by the Court - assessment of cost due to
pump out of vessel sewage, assessment of whether adequate sewage treatment facilities are
reasonably available, and addressing EPA's use of a ratio of commercial vessels to pumpout
facilities to determine whether adequate treatment and removal facilities are reasonably available
- EPA reaffirms its determination that adequate facilities for the safe and sanitary removal and
treatment of vessel sewage (pumpout facilities) are reasonably available in Puget Sound.
34
-------
References
ACCSP (2019). Data Warehouse. Retrieved from:
https://safis.accsp.org:8443/accsp prod/f?p=1490:1:10966397088
Alaska Clean Harbors. Resources: Sewage & Graywater. Retrieved
from: http://www.alaskacleanharbors. org/sewage-gravwater.
Boston Harbor Cruises. Whale Watch. Retrieved
from: https://www.bostonharborcmises.com/whale-watch/.
Cambridge Systematics, Inc. (2011). Hillsborough County Water Ferry Feasibility Study.
Prepared for Hillsborough County Metropolitan Planning Organization. Retrieved
from: http://www.planhillsborough.org/wp-content/uploads/2012/08/Water-Ferrv-
Feasibilitv-Studv-Final-Reportl.pdf.
Chamber of Shipping of America. (2010). Comments and Supplemental Data on Petition to
Revise the Performance Standards for Type II Marine Sanitation Devices (Document
Number EP A-HQ-OW-2010-0126-0042.1).
Economic & Planning Systems, Inc. (2015). Financial Feasibility of Contra Costa County Ferry
Service, 2015-2024. Prepared for Contra Costa Transportation Authority. Retrieved
from: https://ccta.net/wp-content/uploads/2018/10/54c0124fe52d8.pdf.
Economic & Planning Systems, Inc. (2019). Water Transit Feasibility Study. Prepared for Solano
Transportation Authority. Retrieved from: https://sta.ca.gov/wp-
content/uploads/2019/07/Water-Transit-Services-Feasibilitv-Stud'1 2.pdf.
Energy Information Administration (EIA) (2019). Refiner Petroleum Product Prices by Sales
Type. Retrieved from: https://www.eia.gov/dnav/pet/pet pri refoth dcu nusm.htm.
Friends of the Earth (2016). 2016 Cruise Ship Report Card. Retrieved
from: http://www.foe.org/cruise-report-card.
Herrera Environmental Consultants, Inc and Veda Environmental (2013). Phase 2 Commercial
Vessel Sewage Management and Pumpout. Prepared for the Washington Start
Department of Ecology. November 20, 2013.
Herrera Environmental Consultants, Inc. (2015). Technical Memorandum: Puget Sound NDZ
Commercial Vessel Economic Evaluation. June 25, 2015.
Keco Pump and Equipment. 1000-Series Vacuum Pumps. Retrieved
from: https://www.piimpahead.com/vaciiiim-pumps.html.
Lake Carriers Association. (2010). Comments on Petition to Revise the Performance Standards
for Type II Marine Sanitation Devices (Document Number EP A-HQ-OW-2010-0126-
0040).
Lee, E-Ching (2013). ON THE WATER: Save Fuel, Money: Running Your Boat by the
Numbers. North Carolina Sea Grant Coastwatch. Retrieved from:
https://ncseagrant.ncsu.edu/coastwatch/previous-issues/2013-2/summer-2013/on-the-
water-save-fuel-money-running-your-boat-by-the-numbers/.
North San Juan County. Ferries Fact Sheet. Retrieved
from: https://www.sanmanco.com/DocuiroentCenter/View/1824/Ferry-Fact-Sheet-
PDF?bidId=.
Mauric Sea Novators. Tuna Seiner 350. Retrieved from: https://www.maiiric.ecagroup.com/tuna-
seiner-350.
35
-------
National Oceanic and Atmospheric Administration (NOAA) (2016). The NOAA Fleet Plan:
Building NOAA's 21st Century Fleet. Retrieved
from: https://www.omao.noaa.eov/sites/defaiilt/files/documents/The%20'' %20Fleet
%20Plan Final jfoCT.pdf.
National Oceanic and Atmospheric Administration (NOAA) (March 2018). NOAA Fleet
Societal Benefit Study. Prepared by Abt Associaties Inc. Retrieved
from: https://www.omao.noaa.eov/sites/defaiilt/files/documents/Final%20Societal%20Be
nefit%20Studv%20Report%2i f.
Nelson Nygaard Consulting Associates (2006). Willamette River Ferry Feasibility Study: City of
Portland River Renaissance Initiative. Prepared for Portland Department of
Transportation. Retrieved from: https://www.portland.gov/sites/default/files/2020-
01/willamette-river-ferry-feasibilitv-studv-2006.pdf.
Pacific Fisheries Information Network (2019). ALL001 WOC All Species. Retrieved from:
https://reports.psmfc.ore/pacfin/f?p=: 3:::::
Walsh, G.M. (2008). "Fuel Management for Tugs Becoming an Increasing Challenge."
Professional Mariner: Journal of the Maritime Industry. Retrieved from:
https://www.professionalmariner.com/fuel-management-for-tugs-becoming-an-
increasing-challenge/.
Rose Head Service (2020). Accessed February 10, 2020. Retrieved
from: http://www.roseheadservice.com/index.html.
San Juan County. Ferries Fact Sheet. Retrieved from:
https://www.sanjuanco.eom/DocumentCenter/View/1824/Ferry-Fact-Sheet-
PDF?bidId= Skagit County, WA (2019). Guemes Island Ferry Replacement Project.
Retrieved
from: https://www.skaeitooiintY.net/PublicWorksFerrYReplacement/Dociiments/Proiectyo
20Memo%20to%20BCC%20RE ¥essel%20Size.pdf
South Coast Air Quality Management District (South Coast AQMD) (2015). Technology
Assessment: Commercial Harbor Craft. August 2015. Retrieved
from: https://ww3.arb.ca.eov/msproe/tech/techreport/di s technoloev assessments
df-
SS Head (2020). Accessed February 10, 2020. Retrieved from: http://www.sshead-
pumpout.com/.
State of Washington Department of Ecology (2016a). Final Petition to Designate the Waters of
Puget Sound as a No Discharge Zone. July 2016.
State of Washington Department of Ecology (2016b). Supplemental Information on Commercial
Vessel Pumpout Availability to the Final Petition to Designate the Water of Puget Sound
as a No Discharge Zone. October 2016.
State of Washington Department of Ecology (2018). Final Regulatory Analyses. April 2018.
State of Washington Joint Transportation Committee (JTC) (2006). Passenger-Only Ferry Cost
Analysis. Retrieved from: http://lee.wa.eov/JTC/Dociiments/POFCostAnalysis.pdf.
U.S. Army Corps of Engineers (2004). Economic Guidance Memorandum 05-06: Shallow Draft
Vessels Operating Costs, Fiscal Year 2004. Retrieved
from: https://plannine.erdc.dren.mil/toolbox/library/EGMs/eem05-06.pdf.
U.S. Army Corps of Engineers (December 2009). The US Waterway System — Transportation
Facts. Retrieved
from: https://iisace.contentdm.oclc.ore/dieital/collection/pl6021coll2/id/1821.
36
-------
U.S. Army Corps of Engineers (2010). Valdez Harbor Expansion Feasibility Study Economics
Appendix B. September 2010. Retrieved
from: https://www.poa.iisace.armY.mil/Portals/34/docs/civilworks/ciirrentproi/vol2appen
dixb econ om i can al v si s%20(2). pdf.
U.S. Bureau of Labor Statistics (U.S. BLS) (2009). Career Guide to Industries, 2010-2011
Edition: Agriculture, Forestry, and Fishing. Accessed April 2016.
U.S. Bureau of Labor Statistics (U.S. BLS) (2019). Producer Price Index, NAICS 483: Water
Transportation. Retrieved September 12, 2019 from https://www.bls.eov/ppi/.
U.S. Coast Guard (2016). 2015 Recreational Boating Statistics. Retrieved
from: https://www.uscgboating.org/librarv/accident-statistics/Recreational-Boating-
Statistics-2015 .pdf.
U.S. Department of the Interior National Park Service (U.S. DOI) (2010). Passenger Ferry
Transportation Feasibility Study: Cape Lookout National Seashore. Retrieved
from: https://parkplannine.nps.eov/showFile.cfm7proie MIMEType=applic
ation%252Fpdf&filena> v \ I o i2QFeasibilitv%20Studv%5Flowres2.pdf&sf^ 101 _ •>
8.
U.S. Department of Transportation (201 la). Ferry Lifecycle Cost Model. December 2011.
Retrieved
from: https://www.volpe.dot.eov/sites/volpe.dot.eov/files/docs/ferry lifecycle cost mod
el.xlsx.
U.S. Department of Transportation (201 lb). Ferry Lifecycle Cost Model for Federal Land
Management Agencies User's Guide. December 2011. Retrieved
from: https://rosap.ntl.bts.eov/view/dot/9549.
U.S. EPA (1999). Phase I Final Rule and Technical Development Document of Uniform
National Discharge Standards (UNDS); Graywater: Nature of Discharge. U.S.
Environmental Protection Agency, Washington, DC, EPA-842-R-99-001. Retrieved
from: https://www.epa.gov/sites/production/files/2015-
08/documents/2 ceans regulatory unds tdddocuments appaeraywater.pdf.
U.S. EPA (2007). Category 2 Vessel Census, Activity, and Spatial Allocation Assessment and
Category 1 and Category 2 In-Port/At-Sea Splits. U.S. Environmental Protection Agency,
Ann Arbor, MI. Retrieved
from: https://gaftp.epa.gov/air/nei/2011/doc/ ipportingdata/rail cmv/Cateeorv%
202%20vessel%20census.pdf.
U.S. EPA (2008). Cruise Ship Discharge Assessment Report. U.S. Environmental Protection
Agency, Washington, DC, EPA842-R-07-005. Retrieved
from: https://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=P1002SVS.TXT.
U.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.
U.S. Environmental Protection Agency, Washington, DC, EPA-833-R-10-005. Retrieved
from: https://www3.epa.eov/npdes/piibs/vesselsreporttoconeress all final.pdf.
Weeks Marine (2019). Tugboats. Accessed August 13, 2019. Retrieved
from: https://www.weeksmarine.com/eqiiipment-division/tueboats.
Whatcom County Public Works (2018). Ferry Operations Report: Fiscal Year 2018 with 2019-
2020 Projections. Retrieved
from: https://www.whatcomcoiinty.iis/DocumentCenter/View/42034/Ferry-Ops-Report-
2018—Final.
37
-------
Whitman, Requardt, & Associates (2015). City Alternative Transportation Expansion Study:
Water Transit Strategic Plan. Prepared for Baltimore City Department of Transportation
(BCDOT). Retrieved from: http://baltimorewaterfront.com/wp-
content/uploads/2016/06/Water-Transit-Strategic-Plan-Final-8-6-15.pdf.
38
-------
Appendix A - Microsoft Excel file of Cost Tool available upon request
Appendix B - Definitions and Source Information for "Sewage Gen & Pumpout Int" Tab of Cost
Tool
Appendix C - Tables provided by Ecology in its January, 2021 submission
39
-------
Appendix B: Definitions and Source Information for "Sewage Gen &
Pumpout Int" Tab of Cost Tool
The contents of this section include definitions and source information for data used within
the "Sewage Gen & Pumpout Int" tab of the No-Discharge Zone Cost Analysis Tool. The
research underlying these values was conducted previously by Eastern Research Group (ERG)
on behalf of EPA, and the definitions and source information provided below explains how each
value was determined by ERG. The "a-1" superscript notations correspond to the rows in the
"Sewage Gen & Pumpout Int" tab for ease of reference.
The Vessel General Permit (VGP) eNOI database referenced in this section is EPA's database
for all vessels that have submitted a Notice of Intent, Notice of Termination or annual report
under EPA's 2013 Vessel General Permit. In instances where the database was queried, entries
were not included: (1) if a Notice of Termination was submitted for the vessel, or (2) if the vessel
did not visit US ports.
a Large cruise ships
A large cruise ship is defined in Part 5.1 of the Vessel General Permit (VGP) as a passenger ship,
used commercially for pleasure cruises, that provides overnight accommodations to passengers,
and is authorized by the Coast Guard to carry 500 or more passengers. Vessel numbers were
estimated using the VGP eNOI database to search for "large cruise ship (500+ passengers)". This
analysis assumes 54% of large cruise ships have advanced wastewater treatment systems
(sophisticated Type II MSDs) based on the Friends of the Earth (2016) "Cruise Ship Report
Card." Average number of passengers/crew was also obtained from the "Cruise Ship Report
Card" for vessels entering U.S. waters only. Number of days operating in U.S. waters was
calculated based on 31 cruise ships in Alaska from May through September assumed operating in
U.S. waters 60% of the time, and 17 additional cruise ships operating in U.S. waters other than
Alaska 2 days per week and 52 weeks per year. Sewage generation rate was obtained from
U.S. EPA's 2008 "Cruise Ship Discharge Assessment Report."
bMedium and small cruise ships (excursion vessels)
A medium cruise ship is defined in Part 7 of the VGP as a passenger ship, used commercially for
pleasure cruises, that provides overnight accommodations to passengers, and is authorized by the
Coast Guard to carry 100 to 499 passengers. Vessel numbers were estimated using the VGP
eNOI database to search for "medium cruise ships (100-499 passengers)". This analysis assumes
45% of small cruise ships have advanced wastewater treatment systems (sophisticated Type II
MSDs), based on the Friends of the Earth (2016) "Cruise Ship Report Card." Number of days
operating in U.S. waters was estimated from U.S. EPA's 2007 "Category 2 Vessel Census,
Activity, and Spatial Allocation Assessment and Category 1 and Category 2 In-Port/At-
Sea Splits." Average number of passengers/crew from information provided by 23 medium/small
cruise ships. Sewage generation rate was considered comparable to large cruise ships and was
transferred from there.
c Passenger ferries with overnight accommodations
Passenger ferries with overnight accommodations were characterized by looking at five Alaska
Marine Highway ferries and one Great Lakes ferry. The Great Lakes ferry (Badger) uses a Type
40
-------
Ill MSD, and the remainder use Type II MSDs (Lake Carriers Association, 2010). Average
number of passengers/crew calculated based on the six ferries. Number of days operating in U.S.
waters was estimated from U.S. EPA's 2007 "Category 2 Vessel Census, Activity, and Spatial
Allocation Assessment and Category 1 and Category 2 In-Port/At-Sea Splits"; assumes vessels
generate sewage while underway and discharge to shore-side facilities while in port. Sewage
generation rate was transferred from large cruise ships.
d Passenger vessels without overnight accommodations (ferries)
The number of vessels was calculated based on a total of 7,833 inspected passenger vessels
without overnight accommodations, 89% of which were less than 65 feet in length (U.S. EPA,
2010). It was assumed that 15% of these passenger vessels greater than 65 feet in length (107
vessels) use Type II MSDs based on information provided by the Passenger Vessel Association.
It was also assumed that 15% of passenger vessels less than 65 feet in length (868 vessels)
operate Type I MSDs. Remainder of all vessels (greater than or less than 65 feet length) were
assumed to use Type III MSDs. The estimate for average number of passengers/crew was based
on information provided by internet searches for 17 passenger vessels ranging from dinner cruise
vessels, tour boats, wedding party boats, and shuttles. Number of days operating in U.S. waters
was estimated from U.S. EPA's 2007 "Category 2 Vessel Census, Activity, and Spatial
Allocation Assessment and Category 1 and Category 2 In-Port/At-Sea Splits." The sewage
generation rate was determined based on telephone conversation between Eastern Research
Group (ERG) and the Victoria Clipper (3,000-liter sewage holding tanks are 80% full after a 3-
hour trip with 300 persons). Total time passengers are on board the vessel was estimated at 10.5
hours per day: (3000 L/trip x 0.8 x 1/3.8 L/gal)/300 persons x 1/3hrs/trip x 10.5 hrs/day = 7.3
gal/day/person
c Cargo/container/tanker ships
Vessel numbers were estimated using the VGP eNOI database. Vessels included were listed as
"bulk carrier," "general cargo," "hopper barge," "oil gas tanker," "tank barge," or "other barge."
The estimate for number of passengers/crew was obtained from Chamber of Shipping of
America (2010). Number of days operating in U.S. waters was estimated
from a U.S. EPA Region 9 analysis of USCG port data that indicates 2.3 days per port call, and
telephone contact with Horizon Lines indicating vessels make port calls every 2 weeks. Per
capita sewage generation rate of 11 gallon/day/person was selected as the median of sewage
generation rates provided by Chamber of Shipping of America (2010) (median selected rather
than mean as the better indicator of the middle).
f Great Lakes freighters
Number of vessels and number of passengers/crew were obtained from the Lake Carriers
Association (2010). This includes 54 total vessels with two having Type III MSDs and 52 having
Type II MSDs. Number of days operating in U.S. waters was estimated from U.S. EPA's 2007
"Category 2 Vessel Census, Activity, and Spatial Allocation Assessment and Category 1 and
Category 2 In-Port/At-Sea Splits." Sewage generation rate was transferred from
cargo/container/tankers ships.
g Off-shore utility vessels
Off-shore utility vessels include school ships, research vessels, offshore supply vessels, industrial
vessels, and mobile offshore drilling units. Of the 11,034 vessels, 5,610 are tug and tow boats,
41
-------
and 50% are greater than 65 feet in length and 50% are less than 65 feet in length (U.S. EPA,
2010). As a conservative estimate, it was assumed that all utility vessels greater than 65 feet in
length have Type II MSDs and that all utility vessels less than 65 feet in length have Type I
MSDs. It was also assumed that all utility vessels have a minimum of 4 crew members. Number
of days operating in U.S. waters was obtained from U.S. EPA's 2007 "Category 2 Vessel
Census, Activity, and Spatial Allocation Assessment and Category 1 and Category 2 In-Port/At-
Sea Splits." Sewage generation rate was transferred from cargo/container/tanker ships.
11 Public vessels, unclassified
Public vessels include lighthouse tenders, hospital ships, law enforcement vessels, and ice
breakers. Of the 622 total vessels, 7% are less than 65 feet in length (U.S. EPA, 2010). As a
conservative estimate, it was assumed that all public vessels greater than 65 feet in length have
Type II MSDs and that all public vessels less than 65 feet in length have Type I MSDs. It was
assumed that public vessels have a minimum of 4 crew members. Number of days operating in
U.S. waters was obtained from U.S. EPA's 2007 "Category 2 Vessel Census, Activity, and
Spatial Allocation Assessment and Category 1 and Category 2 In-Port/At-Sea Splits" with an
assumption that while vessels are in port, they do not discharge to shoreside facilities. Sewage
generation rate was transferred from cargo/container/tanker ships.
'Tugboats/push boats
Total number of tugs is 5,424 (U.S. Army Corp of Engineers, December 2009). It was assumed
that all tugboats have Type II MSDs based on telephone conversation between Eastern Research
Group (ERG) and AEP River, a barge company. Average number of crew was estimated based
on this conversation, as well. The value for number of days operating in U.S. waters was based
on an assumption of daily operation, except for 15 days out of service per year for maintenance,
based on telephone conversation with AEP River. Sewage generation rate was transferred from
cargo/container/tanker ships.
J Commercial fishing vessels
Of the 69,944 commercial fishing vessels, 89% are less than 65 feet in length (U.S. EPA, 2010).
As a conservative estimate, it was assumed that all commercial fishing vessels greater than 65
feet in length have Type II MSDs and that all commercial fishing vessels less than 65 feet in
length have Type I MSDs. The number of crew - seven — includes a captain, first mate,
engineer, boatswain, and three deck hands according to the U.S. Bureau of Labor
Statistics (2009). Number of days operating in U.S. waters was obtained from U.S. EPA's 2007
"Category 2 Vessel Census, Activity, and Spatial Allocation Assessment and Category 1 and
Category 2 In-Port/At-Sea Splits." Sewage generation rate was transferred from
cargo/container/tanker ships.
k Military vessels
Approximate total number of U.S. military vessels is 6,265 and includes Navy, Coast Guard,
Marines, Army, Military Sealift Command, and Air Force vessels (U.S. EPA, 1999). Of the total
vessels, only 587 report discharging graywater, which was used as a surrogate for the number of
vessels with installed toilets. Average number of crew and days operating in U.S. waters was
obtained from EPA's "Phase I Final Rule and Technical Development Document of Uniform
National Discharge Standards (UNDS); Graywater: Nature of Discharge" report (1999).
42
-------
'Recreational vessels
Recreational vessel numbers were taken from the US Coast Guard (2016) "2015 Recreational
Boating Statistics Report". Only registered vessels that are mechanically propelled were included
(11,034,479). Rowboats (97,067), canoes/kayaks (419,536), motor-less sailboats (110,261), and
other watercraft which were not mechanically propelled (205,706) were excluded. The number
of vessels with MSDs was estimated based on the assumptions laid out in the "Clean Vessel Act:
Pumpout Station and Dump Station Technical Guidelines," where 20% of vessels between 16
and 25 feet, 50% of vessels between 26 and 39 feet and 100% of vessels 40 feet and over have an
MSD. Of these vessels, the National Marine Manufacturers Association (NMMA) assumes that
9% have type I MSDs, 0.1% have type II MSDs, and 90.9% have type III MSDs (Comments on
Petition to Revise the Performance Standards for Marine Sanitation Devices, Docket Number
EPA-HQ-OW-2010-0126-0041.1). Eight persons were assumed for a typical recreational vessel
having a Type II MSD based on best engineering judgement, since recreational vessels requiring
a Type II MSD would either be larger or support more passengers. Sewage generation rate was
transferred from large cruise ships and is a likely overestimate for recreational vessels.
43
-------
Appendix C: Ecology Tables
Table L Recreational Pumpouts in the Puget Sound NDZ (from Ecology's 2021 submission)
Location
Water Body
Category
Contact Phone
Latitude
Longitude
Type
of
Facility
Number
of
Moorage
Slips
Number
of
Moorage
Number of
Stationary
Number of
Portable
Number of
Pumpouts
Number
of
Dump
Hours of
Operation
Max
Vessel
Length (ft)
Min
Depth at
Low Tide
(ft)
Where Treated
Regulatory Structure
Note
Port of All'yn Dock at North
Bay Case Inlet
Allyn
North Bay
Case Inlet
Public
Stationary
(360) 275-2430
47*23*0.53'
122*49*30.48"
Public
Manna
250 LF
0
'
0
0
<
24 hours
50 feet
20 feet
North Bay/Case Inlet
Water Reclamation
NPDES or SWDP 1
RCW 90.48 / WAC 173-
201 / WAC 221/218/219
Details updated.
NorthWest Marine Center
(formerly Marine
Seivi center)
Anacortes
Puget
Sound
Public
Stationary
(380) 293-8200
48°30'0e*
122*36*02"
Private
Marina
¦
0
3
0
0
Unknow
Variable
80
20+
Anacortes WWTP
NPDES or SWDP /
RCW 90.48.' WAC 173-
201 WAC 221/216/219
Port of Anacortes - Cap
Anacortes
Puget
Sound
Public
Stationary
(380) 293-0694
48*30*39"
122*38*13"
Public
Marin3
950
»
2
4
0
2
24 hours
90
12
Anacortes WWTP
NPDES or SWDP !
RCW 90.48 / WAC 173-
201 / WAC 221/218/219
Details updated.
Skyline Marina
Anacortes
Puget
Sound
Public
Stationary
(380) 293-5134
48°29'i8"
122*40*37'
Private
50
0
2
0
0
1
Mon-Friday
100
10
Anacortes WWTP
NPDES or SWDP /
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Details updated.
City of Bainbridge Island.
Eagle Harbor Waterfront
Park (Dock at 301
Shannon Drive SE)
Bainbridge
Puget
Sound
Public
Stationary
(206) 786-7627
47*37*16"
122*31*10*
Public
15
16
2
0
0
'
24 hours
150
5
Bainbridge Island
WWTP
NPDES or SWDP 1
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Details updated. 1
new stationary
pumpou addedt.
Eagle Harbor Marina
Bambridge
Island
Puget
Sound
Public
Stationary
(206) 842-4003
47" 36'
58.82" N
122* 30'
48.22" W
Private
Manna
125
0
0
'
0
0
24 hours
60
6
Central Kitsap WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/218/219
Harbour Marina
Bainbridge
Puget
Sound
Public
Stationary
(206) 842-6502
47*37*25*
122*31"3r
Private
Marina
50
0
I
0
0
'
24 hours
60
15
Bainbridge Island
WWTP
NPDES or SWDP 1
RCW 90.481 WAC 173-
201 / WAC 221/218/219
Winslow Wharf Marina
Bainbridge
Island
Puget
Sound
Private
(206) 842-4202
47°37'4Q"
122*31*20*
Private
Marina
225
0
'
'
0
<
9:00 am - 5:00
pm
80
12
Bainbridge Island
WWTP
NPDES or SWDP /
RCW 90.48 / WAC 173-
201/WAC221/21&219
Port of Allyn North Shore
Dock
Belfair
Hood Canal
Public
Stationary
(360) 275-2430
47"25'15.02
122*547.75*
Public
Marina
6
0
2
0
0
0
24 hours
(Closed
October-Apnl)
50
3
North Bay/Case Inlet
Water Reclamation
NPDES or SWDP 1
RCW 90.48 / WAC 173-
201 / WAC 221/218^219
Details updated.
3ellingham Cruise
Terminal - Port of
Bellinoham
Bellingham
Puget
Sound
Public
Stationary
(360) 876-
2500. ext. 304
48*43'18"
122*30*47"
Public
Dock
400 LF
0
3 (1 for
femes. 2
for others!
0
0
0
24 hours
150
30
Bellingham WWTP
NPDES or SWDP 1
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Details updated.
Squalicum Harbor-Port of
Bellingham
Bellingham
Puget
Sound
Public
Stationary
(360) 678-2542
48*45*13"
122*30*29"
Public
Marina
1200
0
2
8
0
¦
24 hours
100
25
Bellingham WWTP
NPDES or SWDP 1
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated.
Seacrest Marina
Marysville
and Everett
Sound
Public
Stationary
(425) 252-4823
48*01'52*
122*11*17"
Private
Marina
110
0
'
0
0
0
24 hours
40 ft
¦
Everett WWTP
NPDES or SWDP 1
RCW 90.48/ WAC 173-
201 / WAC 221/216/219
Details updated.
Bellingham
Blaine
Drayton
Public
Stationary
(360)647-6176
48°S9'26"
122*45*56"
Public
629
0
0
6
0
<
8:00 an - 5:00
120
12
Blaine WWTP
NPDES or SWDP
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Details updated. 2
new portable
pumpouts 3dded.
Semiahmoo Manna
Blaine
Drayton
Harbor
Public
Stationary
and boat
(380) 371-0440
48*59*22"
122*48*02"
Marina
»
°
I
<
1
0
24 hours
n
12
Blaine WWTP
NPDES or SWDP /
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Bremerton Yacht Club
Bremerton
Phinney
Bay
Private
(360) 479-2662
47" 35'
14.17"
122*39*
45.78"
Private
193
0
1
<
0
0
unknown
65
3
Bio Recyling facility,
in Union WA
WAC 173-308 / RCW
70.95/BisoBds Permit
Port of Brownsville
Burke Bay
Public
Stationary
and boat
(380) 692-5498
47*38'58"
122*38*46"
Public
403
»
2
•
1
2
24 hours
05
25
Central Kitsap WWTP
NPDES or SWDP /
RCW 90.481 WAC 173-
201 / WAC 221/216/219
Pleasant Harbor Marina
Brinnon
Hood Canal
Public
Stationary
(380)798-4811
47*3970"
122*55*07"
Private
Marina
285
0
•
1
0
D
8:00 am - 8:00
pm 24hrs if no
needed
120
8
Onsite Septic system
WAC 248-272A/ RCW
43.20 1 RCW 43.7
Port of CoupeviHe
Coupeville
Penn Cove
Public
Stationary
(360) 678-5020
48*13'29"
122*41*34"
PubBc
Marina
12
-
•
0
0
0
24 hours
80
2
City of Coupeville
WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Deer Harbor Marina
Deer
Harbor
San Juan
Islands
Public
Stationary
(380) 376-3037
48*37*14*
123*0*17"
Marina
125
2
1
0
0
0
8:30 am - 4:30
150
5
Onsite Septic system
WAC 246-272AI RCW
43.20/ RCW 43.7
Details updated.
City of Des Moines Marina
Des Moines
Puget
Sound
Pubfic
Stationary
(206J-824-5700
47'24'OB"
122* 19*58"
PubBc
Marina
S dry
0
-
1
0
<
24 hours
75
—¦
System WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Rosano Resort Marina
Eastsound
ss£r
Public
Portable
(380)376-2152
48° 38' 48"
122*52*13"
Marina
»
8
0
1
•
0
9am-5pm
140
Mobile Pumpout
WWTP
NPDES or SWDP /
RCW 90.48 / WAC 173-
201 / WAC 221/218/219
Details updated.
Facility name
Location
Water Body
Category
Contact Phone
Latitude
Longitude
Type
of
Facility
Number
of
Moorage
Slips
Number
of
Moorage
Number of
Stationary
Pumpouts
Number of
Portable
Pumpouts
Number of
Boat
Pumpouts
Number
of
Dump
Stations
Hours of
Operation
Max
Vessel
Length (ft)
Min
Depth at
Low Tide
(ft)
Where Treated
Regulatory Structure
Note
Port of Edmonds
Edmonds
Puget
Sound
Public
Stationary
(425) 774-0549
47"48'36"
122*23*31"
Private
Marina
100
0
2
0
0
2
24 hours
110
13
Edmonds WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201/WAC 221/216/219
Port of Everett Marina
Everett
Puget
Sound
Pubfic
Stationary
(425) 259-6001
47*59*51"
122*13*26"
Public
Marina
1969
0
2
0
0
2
24 hours
143
11
Everett WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Everett Marine Park
& Boat Ramp
Everett
Puget
Sound
Public
Stationary
(425)259-6001
47*59'52"
122" 13*26"
Public
Marina
198
0
3
0
0
2
24 hours
143
14,18
Everett WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201/WAC 221/216/219
Sandy Point Marina
Femdale
Strait of
Georgia
Public
Stationary
(360) 384-4373
48*47*
48.46" N
122*42*
24.06" W
Marina
72
0
0
1
0
0
24 hrs
(pumpout)
40
15-30 at
tide
shallow at
Lummi Sewer and
Water District (Sandy
Point WWTP)
Federal Permit - EPA
Details updated.
Port of South Whidbey
Freeland
Puget
Sound
Public
Stationary
(360) 331-5494
48*02*18"
122*24'11"
Public
Marina
34
0
1
0
0
1
24 Hours
70
6
Pumpout Service to
Coupeville WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Gray Goose Landing
2%
San Juan
Private
48*31' 59"
122*49* 39"
Marina
10
0
1
0
0
0
unknown
unknown
unknown
Friday Harbor WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 /WAC 221/216/219
Port of Friday Harbor
M3rina
Harbor
San Juan
Public
Stationary
(plus boat!
(360) 378-2688
48*32*21"
123*00*48"
Public
Marina
500
0
1
1
2
24 hours
64
10
Friday Harbor WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201/WAC 221/216/219
Warbass Way Marina
Friday
Harbor
San Juan
Islands
Private
N/A
(llg@rockisland
48*31*59"
122*49*39"
Marina
50
0
1
0
0
0
Varies
Unknown
Unknown
Friday Harbor WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
15 slip
connections to the
pumpout.
Arabella's Landing Marina
Gig Harbor
Gig Harbor
Public
Stationary
(253) 255-5050
47*20'03"
122*35*00"
Private
Marina
47 slips +
160 LF
0
1
0
0
0
24 hours
120
8
City of Gig Harbor
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
City of Gig Harbor Jeresich
Dock
G^ Harbor
Gig Harbor
Pubfic
Stationary
(253) 851-6170
47*19*54*
122*34*46"
Public
Marina
1160 LF
0
1
0
0
1
Variable
50
19
City of Gig Harbor
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
City of Gig Harbor
Maritime Pier
Gig Harbor
Gig Harbor
Pubfic
Stationary
(253)851-6174
47*19- 47"
122* 34* 42*
Public
Marina
40 LF
0
1
0
0
1
24 hours
70
16
City of Gig Harbor
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Murphy's LarxSng Marina
Gig Harbor
Gig Harbor
Pubfic
Stationary
(253) 851-3093
47*20*13"
122*35*19"
Private
Marina
85
0
1
0
0
0
Year Round
Monday Wed
Friday
66
10
City of Gig Harbor
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Driftwood Keys Club
Hansviile
Hood Canal
Pubfic
Stationary
(360) 638-2077
47*54*26"
122*35*11"
Private
Marina
97
0
1
0
0
1
24 hours
40
10
Large Onsite Sewage
System
WAC 246-272B / RCW
7Q.118B/ RCW 90.48
Haibour Village Marina
Kenmore
Lake
Washington
Pubfic
Stationary
(425) 485-7557
47*45*35"
122*15*77-
Private
Marina
135
0
1
0
0
«
24 hours
50
6
West Point WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Kingston
Kingston
Puget
Sound
Pubfic
Stationary
(360) 297-3545
47*47*38"
122*29*58"
Marina
311
4
1
1
0
1
Variable
90
15
Kitsap County
Kingston WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
portable hose cart
with stanchions
accessible from
each transient slip
Carillon Point Marina
Kiritland
Washington
Pubfic
Stationary
(425) 822-1700
47*39*21"
122*12*34"
Private
Marina
200
0
1
0
0
0
24 hours
90
6
King County South
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated.
La Conner Landing Marine
Services
La Conner
Swinomish
Chanel
Pubfic
Stationary
(360)466-3118
48*23'48"
122°29"47"
Public
Marina
200 LF
0
0
0
0
Variable
80
Unknown
La Conner WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201 /WAC 221/216/219
Port of SkacpL La Conner
Marina
La Conner
Swinomish
Chanel
Public
Stationary
(360)466-3118
48*24*04"
122°29'48"
Public
Marina
497
0
0
0
2
24 hours
60
10
La Conner WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Shelter Bay
La Conner
Swinomish
Chanel
Piijfic
Stationary
(360) 333-2952
48*22*59"
122*3053"
Marina
320
0
1
0
0
0
24 Hours
70
5
La Conner WWTP
NPDES or SWDP/
RCW 90.48 /WAC 173-
201 / WAC 221/216/219
Penrose Point State Parti
Lakebay
Puget
Sound
Pubfic
Stationary
(253) 884-2514
47*15*29"
122*4515"
Public
Marina
380 LF
8
1
0
0
'
24 hours
30
3
Onsite Septic system
WAC 246-272A / RCW
43.20/RCW 43.7
44
-------
Facility name
Location
Water Body
Category
Contact Phone
Latitude
Longitude
Type
of
Facility
Number
of
Slips
Number
of
Number of
Stationary
Pumpouts
Number of
Portable
Pumpouts
Number of
Boat
Pisvipouts
Number
of
Operation
Max
Vessel
Length (ft)
Min
Depth at
Low Tide
(ft)
Where Treated
Regulatory Structure
Note
Islands Marine Center
Island
San Juan
Islands
Public
Stationary
(360) 468-3377
48*30-55*
122*54'56"
Private
Marina
56
Unknown
5
0
0
1
Variable
80
30
Fisherman's Bay
Sewer District WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201/WAC 221/216/219
Blake Island State Park
Manchester
Puget
Sound
Public
Stationary
(360) 731-8330
47*32" 21"
122*29'56"
Public
Marina
1500 LF
»
1
0
0
1
24 hours
40
10
Large Onsite Sewage
System
WAC 246-272B / RCW
70.118B/RCW 90.48
Twin Bridges Marina (dry
stack)
Mt Vernon
Puget
Sound
Pitoiic
Stationary
(360)466-1443
48" 2T 19"
122°3CT34-
Marina
1160 LF
0
'
1
0
<
24 hrs
34
7
La Conner WWTP or
City of Burlington
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated.
Mystery Bay State Parte
NorcBand
Admiralty
Inlet
Public
Stationary
(360) 385-1258
48*03-27*
122°41'42"
State
Park
1000 LF
7
1
0
0
0
24 hours
55
•
Bio Recyfing facility,
in Union WA
WAC 173-308/RCW
70.95 / Bisdids Permit
City of Oak Harbor Marina
Oak Harbor
Puget
Sound
Pubtic
Stationary
(360) 279-4575
48*17-12*
122°38U3"
Public
Marina
420
0
2
2
0
2
24
75
12
City of Oak Harbor
WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Deception Pass State Park
Oak Harbor
Puget
Sound
Public
Stationary
(360)675-3767
48°24'06"
122*3730"
State
Park
Marina
2400 LF
11
1
0
0
0
24 hours
40 ft
10
Naval Base Oak
Harbor WWTP
Federal Permit-EPA
City of Olympia, Percival
Landing Park
Olympia
Budd Inlet
Public
Stationary
(360) 753-8380
47°02'55*
122°54'19"
Public
Marina
980 LF
0
1
0
0
1
24 hours
50
8
LOTT WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Olympia -
Swantown Manna
Olympia
Budd Inlet
Public
Stationary
(360) 528-8049
47°03'31"
122*53T46"
Public
Marina
733
0
1
0
0
1
24 hours
100
12
LOTT WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201/WAC 221/216/219
Westbay Marina
Olympia
Budd Inlet
Public
Stationary
(360) 943-2022
47*03-56"
122*54'47"
Private
Marina
350
0
1
0
0
1
24 hours
50
•
LOTT WWTP
NPDES or SWDP/
RCW 90.48 /WAC 173-
201 / WAC 221/216/219
Zittel's Marina
Olympia
Nisqually
Reach
Public
Stationary
(360) 459-1950
47*09-56*
122°48"28"
Private
Marina
200
0
0
2
0
1
Variable
45
8
LOTT WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
West Beach Resort
Ores.
San Juan
Piitfc
Stationary
(877)937-8224
48*41'18"
122*5735"
Marina
750 LF
10
'
0
0
0
Variable
55
4.5
Anacortes WWTP.
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated. 1
new stationary
pumpout added.
West Sound Marina
Orcas
Islands
Public
Stationary
(360) 376-2314
48,37'46'
122'57"36*
Private
Marina
580
0
1
0
0
0
Variable
40
5
Holding tank, pumped
out likely to Rosario
WWTP.
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Point Roberts Marina
Point
Roberts
Strait of
Georgia
Public
Stationary
plus boat
(360) 945-2255
48*58'21"
123°03'46"
Private
Marina
920
0
2
1
1
1
24 hours
200
7
Large Onsite Sewage
WAC 246-272B / RCW
70.118B/ RCW 90-48
Details updated.
Port of Port Angeles Boat
Haven
Port
Angeles
Port
Harbor
Public
Stationary
(360) 457-4505
48*07'33"
123*2707*
Public
Marina
443
0
2
0
0
2
24 hours
160
10
City of Port Angeles
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated.
Port Hadlock Marina
Pert
Hadlock
Admiralty
Inlet
Public
Stationary
(360) 385-6368
48*01'54*
122*44*43"
Private
Marina
160
0
plumbed
throughout
1
0
1
24 hrs
150
15
Onsite Septic system
WAC 246-272A / RCW
43.20/RCW 43.7
Port Ludlow Bay Marina
Port Ludlow
Port Ludlow
Bay
Public
Stationary
(360)437-0513
47°55'17"
122*41'08*
Private
Marina
300
0
1
1
0
1
24 hours
100
15
Port Ludlow WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Bremerton
Port
Orchard
Sinclair
Piitfc
Stationary
(360) 876-5535
47°33'48"
122*3721*
Public
Marina
321
0
2
1
0
24 hrs
130
20
Bremerton WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Bremerton, Port
Orchard Marina
Pert
Orchard
Sinclair
Inlet
Public
Stationary
and boat
(360) 876-5535
47*32
35.92" N
122' 36'
16.60* W
Public
Marina
unknown
0
2
0
1
1
unknown
130
12 ft
South Kitsap Water
Reclamation Facility
JPort Orchard WWTP)
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Pert Towns end -
Boat Haven
Port
Tcwnsend
Admiralty
Inlet
Public
Stationary
(800) 228-2803
48*6'
25.87" N
122*46'
26.68* W
Public
Marina
375
0
'
0
0
0
unknown
100
Unknown
Holding tank, pumped
out, likely to Port
Townsend WWTP.
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Port Townsend.
Point Hudson Marina
Port
Tcwnsend
Admiralty
Inlet
Public
Stationary
(800) 228-2803
48*06-57"
122*44'58*
Public
Marina
32 slips
and 800
LF
0
1
0
0
1
24 hours
100
8
Port Townsend
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201/WAC 221/216/219
Facility name
Location
Water Body
Category
Contact Phone
Latitude
Longitude
Type
of
Facility
Number
of
Slips
Number
of
Number of
Stationary
Punpouts
Number of
Portable
Pumpouts
Number of
Boat
Pimpouts
Number
of
Dump
Stations
Hours of
Operation
Max
Vessel
Length (ft)
Min
Depth at
Lew Tide
(ft)
Where Treated
Regulatory Structure
Note
Liberty Bay Marina
Poulsbo
Liberty 8ay
Public
Stationary
(360) 779-7762
47*43-27*
122*38-38"
Private
Marina
152
0
1
0
'
8.00 am - 6:00
pm
80
6
City of Poulsbo to
Central Kitsap WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Poulsbo Marina
Poulsbo
Liberty Bay
Public
Stationary
(360) 779-9905
47*43-58"
122*39-52*
Public
Marina
130
0
2
2
0
'
6:00 an-4:30
pm
80
7
City of Poulsbo to
Central Kitsap WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port of Pert Townsend
Herb Beck Marina,
Quilcene
Quilcene
Quilcene
Bay
Public
Stationary
(360) 765-3131
47*48-07*
122*51'58*
Public
Marina
40
0
1
0
0
0
24 hours
40
6
Onsite Septic system
WAC 246-272A / RCW
43.20/RCW 43.7
Port Orchard Railway
Marina
Reno
Puget
Sound
Public
Stationary
(360)876-2522
47*32-29"
122*38-43*
Marina
60
0
1
0
0
0
24 hours
150
0
South Kitsap Water
Reclamation Facility
(Port Orchard WWTP)
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Roche Harbor Resort
Roche
Harbor
Puget
Sound
Public
Stationary
(plus boat)
(360) 378-2155
48*36'43"
123*09-25"
Marina
377
0
1
0
1
0
24 hours
80
15
Roche Harbor Resort
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Ballard Mill Marina
Seattle
Lake Union
Public
Stationary
(206) 789-4777
47*39-44"
122*22-58*
Marina
117
0
1
Unknown
0
0
24 hours
50
15
Seattle City Sewer-
West Point WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Boat Street Marina
Seattle
Lake Union
Public
Stationary
(206) 634-2050
47*38'9"
122*18-8*
Public
Marina
90
0
1
0
0
1
24 hours
70
>15
Seattle City Sewer -
West Point WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201/WAC 221/216/219
Elliott Bay Marina
Seattle
Elliott Bay
Pi&tic
Stationary
plus boat
(206) 285-4817
47*37-36*
122*23-31*
Marina
1250
0
1
'
1
'
24 hours
160
30
Seattle City Sewer -
West Pdnt WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Fishermen's Terminal -
Port of Seattle
Seattle
Lake Union
Ship Canal
Ptfcfic
Stationary
(206) 787-3395
47*39-33"
122*22-39"
Public
Marina
350
0
1
0
0
0
7:00 am - 9:00
pm
100
0
West Point WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Gas Works Park Marina
Seattle
Lake Union
Public
Stationary
47*38-
49.1" N
122* 19*
57.44" W
Marina
70
0
t
0
0
0
unknown
unknown
unknown
West Point WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Morrison's North Star Fuel
Dock/Diamond Manna
Seattle
Lake Union
Public
Stationary
(206) 284-6600
47"38'41"
122*20"38"
Private
Fuel
Dock
500 LF
for
fueling &
pumpout
only
0
0
0
0
Variable
200
>15
Seattle City Sewer -
West Point WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Parkshore Marina
Seattle
Lake
Washington
Public
Stationary
(206)725-3330
47*31-20*
122*15-40*
Private
Marina
183
0
1
1
0
0
24 hours
50
5
Seattle City Sewer -
West Pdnt WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Port o< Seattle-Bell
Harbor Marina
Seattle
Puget
Sound
Public
Stationary
(206) 787-3914
47*36-31*
122*20-48-
Marina
47
0
1
1
0
<
24 hours
100
22
Seattle City Sewer -
West Point WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated.
Port of Seattle - Harbor
Island Marina
Seattle
Puget
Sound
Public
Stationary
(206) 787-7236
47*34-
6.82" N
122*20'
49.13'W
Public
Marina
97
0
1
0
0
1
Shilshole Bay
Manna staff
70
12
West Point WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Details updated.
Port of Seattle - Shilshole
Bay Marina
Seattle
Shilshole
Bay
Putofic
Stationary
(206) 787-3006
47*40-33*
122*24-46"
Public
Marina
1410
0
4
0
0
2
24 hours
75 (to
pumpout)
16
Seattle City Sewer -
West Point WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated.
The Farview Marinas
Seattle
Lake Union
Public
Stationary
(888)673-1118
47*3754*
122"19"51*
Private
Marina
165
0
1
0
0
0
24 hours
40
>15
Seattle City Sewer -
West Point WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Port of Pert Angeles John
Wayne Marina
Sequim
Sequim Bay
Public
Stationary
(360)417-3440
48°03'56*
123*0723*
Public
Marina
300
0
t
0
0
2
24 hours
100
12
Large Onsite Sewage
WAC 246-272B / RCW
70.118B/RCW 90.48
Details updated.
Captain's Landing on Blind
Bay
Shaw
San Juan
Islands
Pitoiic
Stationary
(360) 468-2288
48*35'4"
122*55-4*
Private
Marina
Unknown
0
1
0
0
0
unknown
50
unknown
Pumped out of
holding tank, pumper
truck takes it to
Anacortes WWTP.
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated. 1
new stationary
pumpout added.
Jarred Cove State Park
Shetton
Case Inlet
Public
Stationary
(360) 426-9226
47*16-53"
122*53-16*
State
Park
1040 LF
14
1
0
0
0
24 hours
40
4
Bio Recyling facility,
in Union WA
WAC 173-308 / RCW
70.95/ Bisdids Permit
Details updated.
45
-------
Location
Water Body
Category
Contact Phone
Latitude
Longitude
Type
of
Number
of
Moorage
Slips
Number
of
Number of
Stationary
Pumpouts
Number of
Portable
Pumpouts
Number of
Boat
Pumpouts
Number
of
Dump
Stations
Operation
Max
Vessel
Length (ft)
Min
Depth at
Low Tide
(ft)
Where Treated
Regulatory Structure
Note
JarrelPs Cove Marina
Shelton
Case Inlet
Public
Stationary
(360) 426-8823
47°17W
122*53'12"
Marina
38 slips
& 1815
LF
0
1
0
0
0
10:00 am-
6:00 pm
100
5
Bio Recyiing facility,
in Union WA
WAC 173-308 1RCW
70.95 / Bisdids Permit
Details updated.
Port of Shelton, Oakland
Bay Marina
Shelton
Oakland
Bay
Public
Stationary
(360)426-1151
47°13'24"
123°06"18"
Public
Marina
109
0
1
0
0
Unknow
24 hours
50
20
Bio Recyting facility,
in Union WA
WAC 173-308 / RCW
70.95 / Bisdids Permit
Port of Silverdale
Silverdale
Dyes Inlet
Public
Stationary
(360) 696-4918
47°38'30"
122*41"41"
Public
1780LF
0
1
0
0
1
6:00 am-
10:00 pm
150
10
Central Kitsap WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201/WAC 221*216/219
Stuart Island State
Park/Reid Harbor &
Prevost Harbor Marine
Parks
Stuart
Island
San Juan
Islands
Public
Stationary
(360) 378-2044
48°40'3CT
123M2W
0
12
<
0
0
!
24 hours
60
<
Roche Harbor Resort
WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
16th Street Moorage (now
Dock St Marina)
Tacoma
TheaFoss
Waterway
Public
Stationary
(253) 572-2524
47°1473"
122°26W
Public
Marina
320 LF
0
0
0
1
8:00 am -
1200 am
130
15
Tacoma Central
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Breakwater Marina, Inc.
Taccma
Puget
Sound
Public
Stationary
(253) 752-6663
4ri8'27-
122"30"48"
Marina
182
0
0
1
0
1
7:00 am - 8:00
pm
unknown
15
Tacoma North End
WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Chinook Landing Marina
Tacoma
Commence
merit Bay
Public
Stationary
(253) 627-7676
47*16'5Q"
122*24'09"
Private
Marina
213
0
1
0
0
1
8:30 am - 5:00
pm
65
8
Tacoma Central
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Crow's Nest Marina (aka
Marina at Brown's Point)
Tacoma
Commence
merit Bay
Public
Stationary
(253) 272-2827
47*17'37"
122*25,14"
Private
Marina
140
0
1
1
0
1
Variable
40
38
Tacoma Central
WWTP
NPDES or SWDP 1
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Delin Docks
Tacoma
Thea Foss
Waterway
Public
Stationary
(206) 391-6431
47°15'00"
122°2548"
Marina
,«
0
3
0
0
I
8:00 am-
12:00 am
60
6
Tacoma Central
WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Dock Street Marina
(combined 16th Street,
Marina 17 and Albers)
Tacoma
Thea Foss
Waterway
Public
Stationary
(253) 572-2524
47*14'29"
122°26W
Public
Marina
78
0
2
0
0
2
8:00 am -
12:00 am
130
6
Tacoma Central
WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Dock Street Marina 17
Tacoma
Thea Foss
Waterway
Public
Stationary
(253) 572-2524
47°14'29"
122°26'00"
Public
Marina
77
0
2
0
0
2
8:00 am-
12:00 am
130
6
Tacoma Central
WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Dock Street Marina Albers
Tacoma
Thea Foss
Waterway
Public
Stationary
(253) 572-2524
47°14'29"
122*26"l 00"
Public
Marina
78
0
2
0
0
2
8:00 am -
12:00 am
130
6
Tacoma Central
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Foss Harbor Marina
Tacoma
Thea Foss
Waterway
Public
Stationary
and boat
(253) 272-4404
47°15'22"
122°26"01"
Private
Marina
402
0
1
0
'
<
8-5 M-S Sun
9-4, Summer
hours
extended by
2.
90
60
Tacoma Central
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Foss Landing Marina
Tacono
Thea Foss
Waterway
Public
Stationary
(253) 627-4344
47*14'38*
t22°25"55"
Marina
190
0
1
0
0
0
8:00 am - 5:00
pm
75
5
Tacoma Central
WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Foss Waterway Seaport
Authority
Tacoma
Thea Foss
Waterway
Pifclic
Stationary
(253)272-4404
47'15'27"
122*26*07"
Public
Marina
1768 LF
0
1
0
0
0
24 hours
90
60
Tacoma Central
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Marrows Marina
Tacoma
Puget
Sound
Public
Stationary
(253) 564-3032
47-14'39*
122°33"23"
Private
Marina
204
0
1
0
1
1
Variable
40
'
Chambers Creek
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Point Defiance Marina
Complex
Tacoma
Puget
Sound
Public
Stationary
(253) 591-5325
47"18'22"
122*30"48"
Public
Marina
1225 LF
0
1
0
0
0
24 hours
60
16
Tacoma North End
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Tacoma Fuel
Dock/Commencement
Bay Manne services
Tacoma
Thea Foss
Waterway
Public
Stationary
(253) 383-0851
47"15'20"
122°25"58"
Marina
930 LF
0
2
0
0
0
8-4:30
120
restrictio
Tacoma Central
WWTP
NPDES or SWDP /
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Tyee Marina
Tacoma
Commence
mentBay
Public
Stationary
(253) 383-5321
47°17,42"
122°25"28"
Private
Marina
650
0
2
0
0
2
Variable
65
65
Tacoma Central
WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Alderbrook Resort and Spa
Unbn
Hood Canal
Public
Stationary
(360) 898-2252
47*21 "00*
123"04'05"
Private
Marina
1500 LF
0
1
0
0
0
By
appointment
85
12
Alderbrook Resort
WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Details updated.
Water Body
Category
Contact Phone
Latitude
Longitude
Type
of
Facility
Number
of
Slips
Number
of
Number of
Stationary
Pumpouts
Number of
Portable
Pumpouts
Number of
Boat
Pumpouts
Number
of
Dump
Stations
Hours of
Operation
Max
Vessel
Length (ft)
Min
Depth at
Low Tide
(ft)
Where Treated
Regulatory Structure
Note
Hood Canal Marina
Union
Hood Canal
Public
Stationary
(360) 898-2252
47*21'54*
123°05"67"
Private
Marina
30
0
1
0
0
0
9:00 am - 5:00
pm
45
5
Bio Recyting facility,
in Union WA
WAC 173-308 / RCW
70.95 / Bisoiids Permit
Details updated.
Twanoh State Park
Union
Hood Canal
Public
Stationary
(360)275-2222
47*22'49"
\22'58%r
State
Park
Marina
100 LF
7
1
0
0
0
24 hours
40
3
Large Onsite Sewage
System
WAC 246-272B / RCW
70.11BB/ RCW 90.48
Day Island Yacht Club
Unrversity
Place
Puget
Sound
Private
(253) 565-3777
47" 14- 27
122" 33" 34"
Private
Marina
0
1
unknown
0
unknown
unknowi
unknowi
Chambers Creek
WWTP
NPDES or SWDP/
RCW 90.48 / WAC 173-
201 / WAC 221/216/219
Quartermaster Marina
Vashon
Quartermas
ter Hartocr
Public
Stationary
(206) 463-3624
47* 23' 28"
122*27 56"
Private
Marina
100
0
1
0
0
0
9:00 an-5:00
pm
50
2
Onsite Septic system
WAC 246-272A / RCW
43.20/RCW 43.7
Details updated.
Lake Union SkyLaunch
Marina, operated by
Seattle Boat Co.
Seattle
Lake Union
Public
Stationary
(425) 641-2090
Unknown
Unknown
Private
Marina
Dry stack
0
1
0
0
0
24 hours
(closed for
No
restrictions
Unknown
Seattle City Sewer -
West Point WWTP
NPDES or SWDP/
RCW 90.48/WAC 173-
201 / WAC 221/216/219
Details updated. 1
new stationary
pumpout added.
Quartermaster Yacht Club
Vashon
Quartermas
ter Harbor
Public
Stationary
(206) 979-2125
Unknown
(23428
Vashon
Way SW)
Unknown
Marina
115
0
1
0
0
0
Variable
40
•
Onsite Septic system
WAC 246-272A / RCW
43.20/RCW 43.7
New entry.
Pumpout
connections along
dock approx.
every 50ft. 2
visitor slips.
a. The pumpout facil ities
sted in Append
x A primarily came from the
Washington State
arks Pumpout
Datable with a few additions thai were
identified during this study. This should still be considered a partia
6sting. Other mannas, such as private facil
ties, may also have pumpout facilities.
b. Hours of operation fisted as 'variable' refers to pumpout facilities vrfiose hours vary by season, day of the week, or are not open on some days of the week,
c. WA State Ferries, Washington DOC ferries, the Victoria Clipper, and mobile pumpouts have been removed from this list since the 2016 version. Those facilities are included in other tables.
d. WWTP = Wastewater Treatment Plait; SWDP = State Waste Discharge Perniit.
e. Pumpout cells shaded in blue indicate an increase since the 2016 version of this table.
46
-------
Table 2. Commercial Marine Work Companies that Pump Out Commercial Vessels in Puget
Sound (from Ecology's January 2021 submission)
Company
# Trucks or
Vessels
Vessels serviced
Additional Pumping Details
Marine
Vacuum
Services
-15-17 Trucks
(3,000-5,000
gallons each) +
poly tanks
Services all of Puget Sound
and all types of commercial
vessels (has been pumping
sewage from tugs, large
fishing vessels, Navy,
USCG, some smaller
vessels, etc. and has poly
tanks for use at docks)
Pumped vessel sewage is brought back to the main Seattle
facility then discharged to the King County sewer system
(likely West Point or South Treatment Plants), under a
discharge permit.
The company completes monthly and annual reporting,
required by the permit.
Annual 2019 marine sewage pumped: 297,386 gallons.
Company charqes vessels by the hour and by the gallon.
Washington
Marine
Cleaning
~7 Trucks
(3,000-7,500
gallons each)
Services all of Puget Sound
and all types of commercial
vessels (has been pumping
sewage from Navy, USCG,
ferries, fishing vessels, tug
boats, etc.)
No further information.
NRC, a US
Ecology
Company
~5 Trucks (2,200
-3780 gallons
each) + 20,000
gallon poly tanks
Can service ali of Puget
Sound, typically
Bellingham, Pier 90,
Fisherman's Terminal (has
been pumping sewage from
fishing vessels etc.; and
has poly tanks for use at
docks)
Company discharges to King County WWTPs, under a King
County Public Heallh Liquid Waste Pumping/Hauling
certification and annual Septage Disposal Permit.
Company documents scale tickets from the WWTP and Bills
of Lading.
Annual 2019 marine sewage pumped: 900 tons (28,579
gallons)
Pumping rates are for time and materials and disposal costs
(2019 King County disposal rate: $31.65 per ton plus NRC's
20% markup)
Pumpout is
performed by
Emerald's
parent
company
Clean Harbors
~17 Trucks
(3,000-6,500
gallons each)
Services all of Puget Sound
and all types of commercial
vessels (has been pumping
sewage from tugs, fishing
vessels, smaller vessels,
etc.)
Company sends the vessel sewage to the King County
South WWTP and has a septage perm.it with King County (#
KC-2019-01).
Annual 2019 marine sewage pumped: 58,000 gallons
Company keeps the weight ticket and Bill of Lading for each
load, including information on the vessel of origin and the
amount of sewage.
Company invoices customers per load
Pumping costs estimated at $1,700 for about 6 hours of
work and 1,500 gallons of sewage ($0.25/gallon King
County rate).
Arrow Launch
Services
2 Mobile Barges
(3,000 gallons
each)
Services all of Puget Sound
docks and anchorages and
all types of commercial
vessels, one barge usually
in Anacortes, one in Port
Angeles, can travel all of
Puget Sound (has been
pumping sewage from ATB
tugs, oil tankers, bulkers,
etc.)
Company pumps vessel sewage, typically from tankers, and
brings it to the closest shore location with available pumper
truck services. The pumper truck company then takes the
sewage to the closest WWTP for disposal.
With only about 2 or 3 pumping events a year, the company
estimates that the annual vessel sewage pumped is less
than 10,000 gallons.
Company charges for time and materials (hourly rate for
boat and staff) and what the pumper truck company
charqes.
Certified
Cleaning
Services Inc.
8 Vacuum
tankers
(2 x 3000, 5 x
5000,1 x 6300
gallons)
Services fishing vessels in
Puget Sound
Company takes pumped sewage in trucks to Qualco
anaerobic digester in Monroe, WA.
Company keeps records using Bill of Lading but annual
volume was not readily available at the time of inquiry.
Company charged for time and materials plus the disposal
costs at Qualco.
Sound
Marine and
Industrial
Services Inc.
5 Trucks (3,000-
7,000 gallons
each)+ 1,500-
20,000 gallon
tanks
Services all of Puget Sound
and all types of commercial
vessels {tugs, large fishing
vessels, USCG, etc. and
has 1500 - 20,000 gallon
tanks for use on docks)
Company currently takes pumped vessel sewage to the
Tenellco facility in Snohomish County. Annual volume was
not readily available but the company indicated it is at least
100,000 gallons but may be 2 or 3 times as much.
Company charged for time and materials plus the disposal
costs atTenelco ($0.25/gallon).
Hie blue-shaded record represents a new company that was identified in 2020.
47
-------
Table 3. Commercial Vessel Stationary Pumpouts (from Ecology's January 2021 submission)
Owner
r neihty
Location
Latitude
Longitude
Vessels Serre#
Discharge Location
WA Stale Ferries
Anacortes
48* 10' ?ff" N
122*40' 30" W
WSDOT Feny
Anacortes City Sewer (Anacortes
SfflTF. .
WA State Ferries
Friday Harbor
1236 00' 51"" W
WSDOl Feny
Friday Hatbor Sewer (Friday
Harbor WWTPTi
WA Stale Femes
Port Townseai
122* 45' OS" W
WSDOT Feny
Pen Towr,5er.d Sewer (Port
Tomnsend WWTP
WA State Femes
Makilteo
122 11' 12" W
WSDOT Feny
MnMfteo Sewer (Midtilteo
W\\TP;
WA Stale Ferries
Edmonds
4?e a- 47" h
122640'30"W
WSDOT Ferrv
Edmonds City Sewer (Edmonds
WWTP)
WA State Femes
Sesttie-Colemam
Dock
1226 23'37"W
W5DOT Feny
Kmz C'ouatv Sewer (West P;mt
wwtp>
WA State Femes
Fmiiifieioy
47° 31' 24" N
WSDOT Feny
Kinr C'oixr.- Sewer i West ?:m:
\\1\TP;.
WA State Ferries
Pt. Defiance
47® 18' 22" N
122*30' 46" W
WSDOT Ferry
Ticona Citjr Sewer (Tacoma
Central WWTP)
Alaska
Mamie Highway
Port of Bellmgham
13 puaipouts)
48°4?'2? TV
i22°30'49.rw
One serves Alaska Feme;
and two serve all other
commercial vessels
Beilingham City Sewer
(Belliiigiim WWTP)
Victoria Clipper
Port of Seattle
47":
122°2112"W
Victoria Clipper
King County Sewer (West Point
\U\TP;
McNeil Island
HBOC ferries
Steilacoam
47°10'20.4"N
jwwt 9"V
Department of Cancctioiis
Fenies and may serve others
Steilacccm '.ewer Pierce County
Treatment Plant (Tacoma Nona
WWTPi
'.S. Navy
Bremerton
47°33'17"N
,:j. oi '"W
U.S. Navy Vessels
Bremerton C':ty Sewer
¦ rWTP)
V S. Navy
Everett
47°59'26.4"N
I22oi3'05.2"w
LIS. Navy Vessels
Everett C in." Sever (Everett
\VL\TP>
^ d
Manchester
47°33'37J**N
122°32'38,5"W
U.S. Navy Vessels
Kitsap County - Manchester WWTP
1 All except for the Port'of Beilingham's two pumpouts are dedicated to-the certain vessel types.
48
-------
Table 4. Mobile Vessel Pumpout Services Available to Puget Sound Vessels (from Ecology's
January 2021 submission)
Company
Service Areas
Number
of
Boats
Cost
Primary Type of
Vessels Serviced
Capacity
Where Is Pumped Sewage
Disposed?
Port of Brownsville''
Brownsville
1
55
Vessels within their marina
300 Gallons
Central Kitsap Wastewater
Treatment Plant
Foss Hartoor Marina'
Foss Harbor Marina
Area-Taccma
1
Free (with
purchase of
<}as)
Vessels within their
marina
40D Gallons
Taconia Central Wastewater
Treatment Plant
Seattle Sanitation
Services/SartiTug
Lake Union
(Pcrtage Bay to the
Ship Canal) and
Shilshole Marina -
Seattle
2
520-525
(more for big
tanks)
Personal and
commercial vessels
200 & 300
Gallons
King County West Point or
3rkjhtwater Wastewater T reatmen
Plant
Narrow's Marina1
Marrow's Marina
area-Tacoma
1
$5
Vessels within their
marina
70 Gallons
Chambers Creek Wastewater
Treatment Plant
Pelican Pump
Olympia Area
1
$20 & up
Primarily liveaboards
(potentially others)
350 Gallons
Pumpouts at Swantcwn Marina
and West Bay Marina (Lott
Wastewater Tneahrient Plant)
Point Roberts
Marina1
Point Roberts
1
$5
Vessels within their
marina
350 Gallons
Large Onsite Septic System
Rose Head Service
Port Everett Only
1
518 & up
All vessels
300 Gallons
Public pumpouts to Everett Water
Pollution Control Facility (WWPT)
Port of Friday
Harbor's Pumpty
Dumpty1
Port of Friday
Harbor and nearby
Marinas
1
55
All within Hartoor (has
served passenger
vessels 80-90 ft)
190 Gallons
Friday Hartoor Wastewater
Treatment Plant
Port of Bremerton''
and Port Orchard
Marinas
Port Orchard and
Bremerton
1 at each
location
Free ($5 if
unattended)
Vessels within their
marina
45 Gallons
South Kitsap Water Ftedamaion
Facility (Port Orchard WWTP)
Phecal Phreak*
Roche Harbor
Marina
1
Free as part
of moorage
fee
Marina tenants & guests
300 Gallons
Roche Harbor Resort Wastewater
Treatment Plant
Elliott Bay Marina
Seattle
1
525 & up
Vessels within their
marina
250 Gallons
King County West Point
Wastewater Treatment Plant
SS Head
Seattle Area
{Shilshole to
Portage Bay)
2
S25 and up
Mostly liveaboard
300 Gallons
each
Public pumpouts at Fisherman's
Terminal and Shilshole - typically
Seattle City Sewer, to West Pant
WWTP
Pump Me Out
Seattle Area
(Shilshole to Lake
Union)
2
535-545
Liveaboards and other
vessels (has served
towboats and fishing
boats)
350 & 365
Gallons
Generally public pumpouts -
typically Seattle City Sewer, to
West Point WWTP
Semiahmoo Marina"
Semiahmoo Marina
and Drayton Harbor
- Blaine
1
Liveaboards
$5, Guests
Free
Recreational and
liveaboard vessels
40 Gallons
Blaine Wastewater Treatment
Bant
Sanitation
Offioadina Solutions
(SOS)
Greater Anacortes
Area & La Conner
1
535 & up
Recreational and
liveaboani vessels
350 Gallons
Public pumpouts at marinas (likety
to Anacortes WWTP or La Conner
WWTP}
Pumpout Seattle
Lake Union, Salmon
Bay ShilshoJe
Marina, Portage
Bay, Lake
Washington,
Duwamish River
3
525 & up
All vessels
300 Gallons
Seattle City Sewer, to West Point
WWTP
NW Mobile Pump
Out and Marine
Environmental
Services
Gig Harbor. Liberty
Bay, Port Madison,
Bainbridge Island,
Commencement
Bay
2
520-30 (more
for bigger
tanks)
Recreational and
commercial vessels
200 & 300
Gallons
Public and marina pumpouts in
Poulsbo. Bainbridge and Gig
Hartoor (Bainbridge Island WWTP
or Gig Hartoor WWTP)
'Mobile pumpout boats that are installed under Washington State Parks grants are not allowed to service commercial vessels.
Blue-shaded records represent new mobile Pumpout options since 2018.
49
-------
Table 5. Commercial Vessel Pumpout Truck Companies by County (from Ecology's January
2021 submission)
County
Number of
Pumper
Companies
Website
Typical disposal
location
Clallam
4
httD://websrv7 xlaUam.net/forais/uoloads/ehOnsiteMamteaancePro videts2.pdf
Port Angeles WWTP
(except one to
Biorecycling facility)
Island
18
https://www.islandcountvwa.gov/Heal th/EH/Documents/Current%20Licensed%2
La Conner WWTP
OMSP's.pdf
Jefferson
7
https://www.j effersoncountvpubli chealth .ore/DocumentC enter/View/1313 /List-
Depends on location,
likely Port Town send
WWTP or permitted
biosolids facility (Biosolids
Permit per WAC 173-308)
of-Certified-Septic-Svstem-PiimDers-PDF?bidId=
King
41
https:/Avww.kinecountv-eov/dept&/health/environinental-health/t>il>ina/onsite-
King County South WWTP
or a WWPT within Pierce
County
sewaae-svstems/professionals/Wniedia'deptshealth' enviionmental-
health/documents/oss/hst-of-certified-liauid-waste-Duiiioer-hauler.aslix
Kitsap
17
https://kitsappublichealth-ors/recoidsearcL'contractorhst.asDX?intlicaisetvpeid—8
Likely Central Kitsap
WWTP
Mason
32
https://www.co. mason. wa.us/forms/Env Health,''punipery3df_
Bio-Recycling North Ranch
Pierce
42
httDs://www.tDchd.orB/home/showDubhsheddocument?id=1040
Depends on location,
likely Pierce County
WWTPs or Tacoma WWTP
San Juan
9
httD://www.saniuanco.coniDocumentCenter/Home/View/8644
Anacortes WWTP
Skagit
18
https:/Avww.skaaitcountv.net'HealthEnvironmentaLfDocuments/SepticProviders.
Burlington or La Conner
WWTPs
pdf
Snohomish
25
http://www.snoM.ore/DocumentCenter/View/2413/2020-Septic-Contractors-
King County, Anacortes
and La Conner WWTPs
List?bidld=
Thurston
23
littDs://wwU'.co.thurston.wa.us/health ehoss pdf PuniperList.pdf
Likely Budd Inlet WWTP
Whatcom
13
httD: //wa-whatcomc ounHv civicolus. c om/DocumentCenter/View/2040
One of three permitted
biosolids beneficial use
facilities (Biosolids Permit
per WAC 173-308)
Blue-shaded records represent additions since the 2016 petition. It is unclear how many of the pumper trucks hi
those counties service vessels. All webpages have been updated and verified.
50
------- |