Revised DRAFT report

Technical Support for EPA Development of a Permitting Framework to
Address the Vacatur of the NPDES Vessel Exclusion

Prepared for:

Oceans and Coastal Protection Division

U.S. Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, D.C.  20460

Prepared by:

BATTELLE

397 Washington St.

Duxbury, MA 02332

EPA Contract No. 68-C-03-041

Work Assignment No. 4-50

Project No. G921350

This page intentionally left blank.CONTENTS

  TOC \o "1-3" \u  ACRONYMS AND ABBREVIATIONS	  PAGEREF _Toc177791317 \h
 vii

1.0	INTRODUCTION	  PAGEREF _Toc177791318 \h  9

1.1	The Clean Water Act	  PAGEREF _Toc177791319 \h  9

1.2	Northwest Environmental Advocates, et al. v. EPA	  PAGEREF
_Toc177791320 \h  9

1.3	Scope of the Vessel Vacatur	  PAGEREF _Toc177791321 \h  10

1.3.1	Exemptions to the Vessel Vacatur	  PAGEREF _Toc177791322 \h  10

2.0	DATA GATHERING AND ANALYSIS	  PAGEREF _Toc177791323 \h  11

2.1	Recreational Vessel Data	  PAGEREF _Toc177791324 \h  11

2.1.1	National Marine Manufacturers Association (NMMA) 2006 Boating
Statistics Report	  PAGEREF _Toc177791325 \h  11

2.2	Commercial Vessel Data	  PAGEREF _Toc177791326 \h  11

2.2.1	Merchant Vessels of the United States (VESDOC)	  PAGEREF
_Toc177791327 \h  11

2.2.2	Waterborne Transportation Lines of the United States (WTLUS)
PAGEREF _Toc177791328 \h  12

2.3	Foreign Vessel Data	  PAGEREF _Toc177791329 \h  12

2.3.1	U.S. Customs Entrances/Clearances Records	  PAGEREF _Toc177791330
\h  12

2.4	Port Data	  PAGEREF _Toc177791331 \h  12

2.4.1	MARAD Vessel Calls	  PAGEREF _Toc177791332 \h  12

2.4.2	U.S. Customs Entrances/Clearances Records	  PAGEREF _Toc177791333
\h  12

2.4.3	National Ballast Information Clearinghouse	  PAGEREF _Toc177791334
\h  12

2.4.4	EPA National Total Maximum Daily Load (TMDL) Database	  PAGEREF
_Toc177791335 \h  13

2.4.5	National Estuary Program 2007 Coastal Condition Report	  PAGEREF
_Toc177791336 \h  13

2.5	Discharge Data	  PAGEREF _Toc177791337 \h  14

2.5.1	Uniform National Discharge Standards Reports	  PAGEREF
_Toc177791338 \h  14

2.6	Pollution Control Technologies/Best Management Practices Data
PAGEREF _Toc177791339 \h  15

2.6.1	Uniform National Discharge Standards Reports	  PAGEREF
_Toc177791340 \h  15

2.6.2	Lloyd’s Register Ballast Water Treatment Technology Report
PAGEREF _Toc177791341 \h  15

2.6.3	Miscellaneous Literature, Reports, and Phone Conversations
PAGEREF _Toc177791342 \h  15

3.0	VESSEL POPULATION STATISTICS	  PAGEREF _Toc177791343 \h  15

3.1	Recreational Vessels	  PAGEREF _Toc177791344 \h  15

3.1.1	Recreational Vessel Numbers	  PAGEREF _Toc177791345 \h  16

3.1.2	Recreational Vessel Propulsion and Size Data	  PAGEREF
_Toc177791346 \h  17

3.2	Commercial Vessels	  PAGEREF _Toc177791347 \h  19

3.2.1	Domestic Commercial Vessel Numbers and Types	  PAGEREF
_Toc177791348 \h  19

3.2.2	Domestic Commercial Fishing Vessel Numbers	  PAGEREF _Toc177791349
\h  24

3.2.3	Foreign Commercial Vessel Numbers	  PAGEREF _Toc177791350 \h  26

4.0	PORT FINDINGS	  PAGEREF _Toc177791351 \h  27

4.1	Calls to U.S. Ports	  PAGEREF _Toc177791352 \h  27

4.2	Receiving Water Characteristics	  PAGEREF _Toc177791353 \h  33

4.2.1	Houston, Texas	  PAGEREF _Toc177791354 \h  33

4.2.2	New York City, NY	  PAGEREF _Toc177791355 \h  34

4.2.3	Port Everglades, Florida	  PAGEREF _Toc177791356 \h  34

4.2.4	Miami, Florida	  PAGEREF _Toc177791357 \h  34

4.2.5	Los Angeles/Long Beach, CA	  PAGEREF _Toc177791358 \h  34

4.2.6	San Juan, Puerto Rico	  PAGEREF _Toc177791359 \h  35

4.2.7	Savannah, GA	  PAGEREF _Toc177791360 \h  35

4.2.8	St. Thomas, Virgin Islands	  PAGEREF _Toc177791361 \h  35

4.2.9	Seattle, WA	  PAGEREF _Toc177791362 \h  35

4.2.10	New Orleans, LA	  PAGEREF _Toc177791363 \h  36

4.2.11	Charleston, SC	  PAGEREF _Toc177791364 \h  36

4.2.12	Baltimore, MD	  PAGEREF _Toc177791365 \h  36

4.2.13	Elizabeth River, VA	  PAGEREF _Toc177791366 \h  36

4.2.14	Oakland, CA	  PAGEREF _Toc177791367 \h  36

4.2.15	Bayou Lafourche, LA	  PAGEREF _Toc177791368 \h  37

4.2.16	Galveston, TX	  PAGEREF _Toc177791369 \h  37

4.2.17	Tacoma, WA	  PAGEREF _Toc177791370 \h  37

4.2.18	Jacksonville, FL	  PAGEREF _Toc177791371 \h  38

4.2.19	South Louisiana, LA	  PAGEREF _Toc177791372 \h  38

5.0	DISCHARGE FINDINGS	  PAGEREF _Toc177791373 \h  38

5.1	Discharges Incidental to the Normal Operation of a Vessel	  PAGEREF
_Toc177791374 \h  38

5.1.1	Aqueous Film Forming Foam (AFFF)	  PAGEREF _Toc177791375 \h  41

5.1.2	Boiler Blowdown	  PAGEREF _Toc177791376 \h  42

5.1.3	Cathodic Protection	  PAGEREF _Toc177791377 \h  43

5.1.4	Chain Locker Effluent	  PAGEREF _Toc177791378 \h  44

5.1.5	Clean Ballast	  PAGEREF _Toc177791379 \h  45

5.1.6	Compensated Fuel Ballast	  PAGEREF _Toc177791380 \h  46

5.1.7	Controllable Pitch Propeller Hydraulic Fluid	  PAGEREF
_Toc177791381 \h  47

5.1.8	Deck Runoff	  PAGEREF _Toc177791382 \h  48

5.1.9	Dirty Ballast	  PAGEREF _Toc177791383 \h  49

5.1.10	Distillation and Reverse Osmosis Brine	  PAGEREF _Toc177791384 \h
 49

5.1.11	Elevator Pit Effluent	  PAGEREF _Toc177791385 \h  50

5.1.12	Firemain Systems	  PAGEREF _Toc177791386 \h  51

5.1.13	Freshwater Layup	  PAGEREF _Toc177791387 \h  52

5.1.14	Gas Turbine Water Wash	  PAGEREF _Toc177791388 \h  53

5.1.15	Grey Water	  PAGEREF _Toc177791389 \h  53

5.1.16	Hull Coating Leachate	  PAGEREF _Toc177791390 \h  55

5.1.17	Motor Gasoline Compensating Discharge	  PAGEREF _Toc177791391 \h
56

5.1.18	Non-Oily Machinery Wastewater	  PAGEREF _Toc177791392 \h  56

5.1.19	Photographic Laboratory Drains	  PAGEREF _Toc177791393 \h  57

5.1.20	Refrigeration/Air Conditioning Condensate Discharge	  PAGEREF
_Toc177791394 \h  58

5.1.21	Rudder Bearing Lubrication Discharge	  PAGEREF _Toc177791395 \h
58

5.1.22	Seawater Cooling Overboard Discharge	  PAGEREF _Toc177791396 \h
59

5.1.23	Seawater Piping Biofouling Prevention	  PAGEREF _Toc177791397 \h
60

5.1.24	Small Boat Engine Wet Exhaust	  PAGEREF _Toc177791398 \h  60

5.1.25	Sonar Dome Discharge	  PAGEREF _Toc177791399 \h  61

5.1.26	Steam Condensate	  PAGEREF _Toc177791400 \h  62

5.1.27	Stern Tube Seals and Underwater Bearing Lubrication	  PAGEREF
_Toc177791401 \h  62

5.1.28	Submarine Bilge Water	  PAGEREF _Toc177791402 \h  63

5.1.29	Surface Vessel Bilge Water/Oil-Water Separator (OWS) Discharge
PAGEREF _Toc177791403 \h  64

5.1.30	Underwater Ship Husbandry	  PAGEREF _Toc177791404 \h  64

5.1.31	Welldeck Discharges	  PAGEREF _Toc177791405 \h  66

6.0	Pollution Control Technologies and Best Management Practices
PAGEREF _Toc177791406 \h  66

6.1	Aqueous Film Forming Foam	  PAGEREF _Toc177791407 \h  66

6.2	Chain Locker Effluent	  PAGEREF _Toc177791408 \h  66

6.3	Clean Ballast	  PAGEREF _Toc177791409 \h  67

6.4	Compensated Fuel Ballast	  PAGEREF _Toc177791410 \h  70

6.5	Controllable Pitch Propeller Hydraulic Fluid	  PAGEREF _Toc177791411
\h  70

6.6	Deck Runoff	  PAGEREF _Toc177791412 \h  71

6.7	Dirty Ballast	  PAGEREF _Toc177791413 \h  71

6.8	Distillation and Reverse Osmosis Brine	  PAGEREF _Toc177791414 \h
71

6.9	Elevator Pit Effluent	  PAGEREF _Toc177791415 \h  72

6.10	Firemain Systems	  PAGEREF _Toc177791416 \h  72

6.11	Freshwater Layup	  PAGEREF _Toc177791417 \h  72

6.12	Gas Turbine Water Wash	  PAGEREF _Toc177791418 \h  72

6.13	Grey Water	  PAGEREF _Toc177791419 \h  72

6.14	Hull Coating Leachate	  PAGEREF _Toc177791420 \h  74

6.15	Motor Gasoline Compensating Discharge	  PAGEREF _Toc177791421 \h
75

6.16	Photographic Laboratory Drains	  PAGEREF _Toc177791422 \h  76

6.17	Small Boat Engine Wet Exhaust	  PAGEREF _Toc177791423 \h  76

6.18	Sonar Dome Discharge	  PAGEREF _Toc177791424 \h  76

6.19	Surface Vessel Bilge Water/Oil-Water Separator Discharge	  PAGEREF
_Toc177791425 \h  76

6.20	Underwater Ship Husbandry	  PAGEREF _Toc177791426 \h  78

7.0	Laws, Regulations, and Conventions	  PAGEREF _Toc177791427 \h  81

7.1	International and National Laws and Regulations	  PAGEREF
_Toc177791428 \h  81

7.1.1	International Standards	  PAGEREF _Toc177791429 \h  81

7.1.2	National Law	  PAGEREF _Toc177791430 \h  81

7.1.3	State Law	  PAGEREF _Toc177791431 \h  82

8.0	CONCLUSIONS	  PAGEREF _Toc177791432 \h  83

9.0	REFERENCES	  PAGEREF _Toc177791433 \h  84

LIST OF TABLES

  TOC \c "Table"  Table 3-1.  Top 20 U.S. States for Total Registered
Recreational Vessels, with General Type of Vessel Indicated.	  PAGEREF
_Toc177806314 \h  17

Table 3-2.  Type of Propulsion for All Registered Mechanically-Propelled
Recreational Vessels.	  PAGEREF _Toc177806315 \h  18

Table 3-3.  Lengths of All Registered Mechanically-Propelled
Recreational Vessels.	  PAGEREF _Toc177806316 \h  18

Table 3-4.  Summary of the U.S.-Flag Cargo or Passenger Vessels
Operating in U.S. Waters by Region.	  PAGEREF _Toc177806317 \h  20

Table 3-5. Top Twenty U.S. TSO Companies Operating Cargo or Passenger
Vessels in U.S. Waters by Number of Vessels Operated.	  PAGEREF
_Toc177806318 \h  22

Table 3-6. Total Number of U.S. Documented Vessels by Service Type.
PAGEREF _Toc177806319 \h  23

Table 3-7. Top 20 Most Frequently Recorded Flags Entering U.S. Ports or
Waterways in 2005	  PAGEREF _Toc177806320 \h  26

Table 4-1.  2005 Vessel Calls at All U.S. Coastal Ports Organized by
Geographic Region	  PAGEREF _Toc177806321 \h  28

Table 4-2. Top 20 U.S. Ports by Number of Vessel Calls in 2005.
PAGEREF _Toc177806322 \h  31

Table 4-3. 2005 Domestic and Foreign Vessel Calls at Top 20 U.S. Ports.
 PAGEREF _Toc177806323 \h  32

Table 5-1.  Phase I UNDS Armed Forces Vessel Discharges Requiring an
MPCD.	  PAGEREF _Toc177806324 \h  39

Table 6-1. Characteristics of Example Ballast Water Treatment Systems
PAGEREF _Toc177806325 \h  68

Table 6-2. Ballast Water Treatment System Standards.	  PAGEREF
_Toc177806326 \h  70

Table 6-3. Grey Water Treatment Technology Costs	  PAGEREF _Toc177806327
\h  74

Table 6-4. Bilge Water Treatment Technology Costs	  PAGEREF
_Toc177806328 \h  78

Table 6-5.  Global BMPs for Preventing Vessel Hulls from being Invasive
Species Vectors.	  PAGEREF _Toc177806329 \h  79

Table 7-1. Current or Pending State Permitting Systems Pertaining to
Vessel Discharges Covered in this Report.	  PAGEREF _Toc177806330 \h  82

Table 8-1.  Summary of Statistical Findings for Vessels and Ports.
PAGEREF _Toc177806331 \h  83

LIST OF FIGURES

  TOC \c "Figure"  Figure 3-1. 2006 U.S. Regional Recreational Vessel
Registration.	  PAGEREF _Toc177806846 \h  16

Figure 3-2. Summary of U.S. Flag Cargo and Passenger Vessels Operating
in U.S. Waters by Region.	  PAGEREF _Toc177806847 \h  21

Figure 3-3.  Documented Commercial Fishing Vessels by Owner’s Contact
State.	  PAGEREF _Toc177806848 \h  25

Figure 4-1. 2005 Vessel Calls to U.S. Coastal Ports by Geographic
Region.	  PAGEREF _Toc177806849 \h  27

Figure 6-1. Types of Processes Utilized by Ballast Water Treatment
Technologies.	  PAGEREF _Toc177806850 \h  68

Figure 6-2. Grey Water Treatment System	  PAGEREF _Toc177806851 \h  73

LIST OF ATTACHMENTS

ATTACHMENT A:  Table 1–State-by-state Recreational Vessel Registration
Information

ACRONYMS AND ABBREVIATIONS

AFFF			aqueous film-forming foam

ANPRM		advanced notice of proposed rulemaking

APPS			Act to Prevent Pollution from Ships

AWO			American Waterways Operators

BMP			best management practice

CBP			U.S. Customs and Border Protection

CERCLA	Comprehensive Environmental Response and Community Right-to-Know
Act

CFR			Code of Federal Regulations

CLIA			Cruise Lines International Association

CMC			Crowley Maritime Corporation

CPO			chlorine-produced oxidant

CPP			controllable pitch propeller

CSLC			California State Lands Commission

CWA			Clean Water Act

DA			Discharge Assessment

DB			deck barge

DCB			dry cargo barge

DDT			dichloro-diphenyl-trichloroethane

DEC			Department of Environmental Conservation (Alaska)

DHTB			double-hull tanker barge

DIN			dissolved inorganic nitrogen

DIP			dissolved inorganic phosphorus

DO			dissolved oxygen

DOB			dry open barge

DoD			Department of Defense

EEZ			exclusive economic zone

EPA			United States Environmental Protection Agency

gph			gallons per hour

gpm			gallons per minute

HEM			hexane extractable material

HEP			Harbor Estuary Program (New York/New Jersey)

IMO			International Maritime Organization

LMC			Liberty Maritime Corporation

LSB			lash/seabee barge

MARAD		Maritime Administration

MARPOL 73/78	International Convention for the Prevention of Pollution
from Ships,

			1973, as modified by the Protocol of 1978 relating thereto

MOGAS		motor gasoline

MPCD			marine pollution control device

NAISA			National Aquatic Invasive Species Act

NAS			National Academy of Sciences

NBIC			National Ballast Information Clearinghouse

NDC			Navigation Data Center

NEA			Northwest Environmental Advocates

NEP			National Estuary Program

NISA			National Invasive Species Act

nmi			nautical mile

NMMA			National Marine Manufacturers Association

NOD			Nature of Discharge

NPDES			National Pollutant Discharge Elimination System

NVDC			National Vessel Documentation Center

OPA			Oil Pollution Act

OTB			other tank barge

OWS			oil/water separator

PAHs			polycyclic aromatic hydrocarbons

PCBs			polychlorinated biphenyls

PCT			pollution control technology

PSPA			Pacific Seafood Processors Association

RO			reverse osmosis

SBT			segregated ballast tanks

SERC			Smithsonian Environmental Research Center

TBT			tributyltins

TMDL			total maximum daily load

TMP			topside management plan

TOC			total organic carbon

TPH			total petroleum hydrocarbons

TSO			Transportation Series Operator

UNDS			Uniform National Discharge Standards

USACE		United States Army Corps of Engineers

USCG			United States Coast Guard

USDA			United States Department of Agriculture

USHMP		underwater ship husbandry management plan

UV			ultraviolet

VESDOC		Merchant Vessels of the United States

WCSC			Waterborne Commerce Statistics Center

WSC			World Shipping Council

WTLUS		Waterborne Transportation Lines of the United States

INTRODUCTION

The Clean Water Act

Originally enacted in 1972, the Clean Water Act (CWA) is the primary
federal law governing water pollution in the United States (U.S.).
Among other authorities, it allows the U.S. Environmental Protection
Agency (EPA) to regulate discharges to the nation’s waterways through
the National Pollutant Discharge Elimination System (NPDES).  The NPDES
program “requires permits for the discharge of pollutants from any
point source into the waters of the United States” (40 CFR 122.1(b)),
with the definition of point source including, among other things,
“vessel or other floating craft” (40 CFR 122.2).  The term pollutant
includes the following list of potential contaminants:

dredged spoil, solid waste, incinerator residue, filter backwash,
sewage, garbage, sewage sludge, munitions, chemical wastes, biological
materials, radioactive materials…, heat, wrecked or discarded
equipment, rock, sand, cellar dirt and industrial, municipal, and
agricultural waste. (40 CFR 122.2)

However, section 122.3(a) of the CWA regulations (40 CFR 122.3(a))
exempts some vessel discharges from requiring a NPDES permit, stating:

The following discharges do not require NPDES permits:

(a) Any discharge of sewage from vessels, effluent from properly
functioning marine engines, laundry, shower, and galley sink wastes, or
any other discharge incidental to the normal operation of a vessel. (40
CFR 122.3(a))

Although the CWA regulations do not specifically define “discharges
incidental to the normal operation of a vessel”, this term is broadly
described in “Phase I: Uniform National Discharge Standards (UNDS) for
Vessels of the Armed Forces”, a 1999 technical document developed by
the EPA and the Department of Defense (DoD) under Section 312 of the
CWA.  This UNDS document further breaks down incidental discharges of
Armed Forces vessels to include “discharges from the operation,
maintenance, repair, or testing of vessel propulsion systems,
maneuvering systems, habitability systems, or installed major systems
such as elevators or catapults, and discharges from protective,
preservative, or adsorptive hull coatings” (EPA, 1999a).  During the
development of the UNDS document, the authors consulted with Armed
Forces technical experts and developed a list of 39 different discharges
considered to be incidental to the normal operation of an Armed Forces
vessel.  While some of these 39 incidental discharges would not apply to
civilian vessels (e.g., catapult wet accumulator discharge, which can be
found on aircraft carriers), and some of the standards set for others
would not apply to civilian vessels, some of the studies developed for
the UNDS rule may be instructive for this effort. Discharge reports were
also developed for each of the discharges, with some of the more
critical ones receiving a more in-depth examination (Section 2.5.1).

Northwest Environmental Advocates, et al. v. EPA

In January 1999, several environmental groups, including Northwest
Environmental Advocates (NEA) (hereafter referred to as NEA et al.),
collectively petitioned the EPA to repeal 40 CFR 122.3(a) (hereafter
referred to as the ‘vessel exclusion clause’).  As explained in
their petition, the primary concern of NEA et al. was for the discharge
of ballast water and any potentially invasive or harmful organisms
contained therein from vessels into United States waters.  Referring to
the CWA definition of pollutant (40 CFR 122.2) and the inclusion of
‘biological materials’ in that definition, NEA et al. stated that
the vessel exclusion clause was illegal because it ran counter to the
CWA and case law (e.g., Natural Resources Defense Council v. Costle
(1977)).  The petition asked that the EPA repeal this exclusion “to
help prevent the further degradation of aquatic resources from”
invasive species (Johnston, 1999).

EPA denied the petition in September 2003, stating that other federal
statutes (e.g., the Act to Prevent Pollution from Ships [APPS], the
National Invasive Species Act [NISA]) and federal-sponsored activities
(e.g., workshops, research and development funding, and participation in
the International Maritime Organization’s (IMO) invasive species
control efforts) are sufficient to address the invasive species issue in
U.S. waters.

In response to the petition denial, NEA et al. filed a lawsuit (C
03-05760 SI) in the U.S. District Court for the Northern District of
California in December 2003 seeking to compel the EPA to repeal the
vessel exclusion clause.  While the court found for the plaintiffs (NEA
et al.) in March 2005 and ordered the EPA to repeal 40 CFR 122.3(a), the
EPA returned to the court to request that the repeal apply solely to
ballast water and not to all “discharges incidental to the normal
operation of a vessel”.  This request was denied in a September 2006
injunction in which the court directed the EPA to vacate “the blanket
exemption for discharges incidental to the normal operation of a vessel,
contained in 40 CFR 122.3(a)” by September 30, 2008 (NEA et al. v.
EPA, 2006).  Hereafter, the vacating of the vessel exclusion clause
shall be referred to as the ‘vessel vacatur’.

Scope of the Vessel Vacatur

As a result of the court-ordered vessel vacatur, the EPA must develop a
feasible permitting system that will cover millions of formerly-exempt
vessel discharges under the NPDES program.  This permitting system must
be conceived, developed, and implemented by September 30, 2008 or the
EPA risks legal challenges.  Prior to determining the type and manner of
permitting system to implement, EPA must fully understand the scope of
the issue, including the number and types of vessels that must be
covered and the nature and type of discharges incidental to their normal
operation.  In addition, the EPA will need information on U.S. ports and
waterways, current national and international regulations that apply to
vessel discharges, and the current state of shipboard and land-based
pollution control technologies (PCTs) and best management practices
(BMPs).

Exemptions to the Vessel Vacatur

Under the pending NPDES permitting framework for the vessel vacatur,
some discharges incidental to the normal operation of a vessel will not
be affected due to their coverage or exemption under other federal
regulations.  As stated in the court’s injunction (NEA et al. v. EPA,
2006), NEA et al. sought to only vacate the first sentence of 40 CFR
122.3(a).  The manner in which the following discharge types are
regulated will not be affected by the vessel vacatur.

In CWA §312(a)(12)(B)(i), the discharge of rubbish, trash, and garbage
is specifically excluded as being ‘incidental to the normal operation
of a vessel’.  Rubbish, trash, and garbage discharge is regulated
under APPS, which is the U.S. implementation of the International
Convention for the Prevention of Pollution from Ships, 1973, as modified
by the Protocol of 1978 relating thereto (MARPOL 73/78).

Discharges originating from a vessel when it is operating in a capacity
other than a means of transportation, as specifically exempted in the
second sentence of 40 CFR 122.3(a), which is not being vacated.

Discharges from a vessel or other floating craft outside the U.S. three
mile territorial sea limit do not constitute “the discharge of a
pollutant” under CWA §502(12)(A) and thus are not subject to NPDES
permitting.

Sewage discharge from a vessel is specifically excluded from CWA’s
definition of pollutant (CWA §502(6)(A)) and thus is not subject to
NPDES permitting.

Discharges incidental to the normal operation of a vessel of the U.S.
Armed Forces are excluded from NPDES permitting requirements under the
CWA’s definition of pollutant (CWA §502(6)(A)) and thus are not
subject to NPDES permitting.

This report summarizes the findings of a search of available literature
and databases and aims to provide EPA with the scope of existing
conditions (as available) in four major categories: vessels, ports,
discharges, and PCTs/BMPs.  Because the field of information is
constantly developing, particularly with regards to treatment
technologies, and data on vessels and ports are updated at least
annually, this report will be a living document to be added to and
amended based on the state of the most current knowledge.

DATA GATHERING AND ANALYSIS

Recreational Vessel Data

National Marine Manufacturers Association (NMMA) 2006 Boating Statistics
Report

Data on recreational vessels operating in U.S. waters were obtained
primarily from the 2006 National Marine Manufacturers Association’s
(NMMA) Recreational Boat Registration Statistics report (NMMA, 2007)
which compiles data from the registration agencies in each state and
territory, among other sources.  At the time of publication of this
document, the 2006 version of the NMMA report was the latest available.
However, the overall state-by-state vessel registration numbers had not
been re-compiled for the 2006 version of the report; therefore, while
the report contains some data that are updated for 2006, much of the
data with which this report is concerned were from 2005.

Commercial Vessel Data

Merchant Vessels of the United States (VESDOC)

Vessel data were obtained from the United States Coast Guard (USCG) in
the form of the Merchant Vessels of the United States (VESDOC) data
file, which contained updated data through May 5, 2007 (USCG, 2007a).
These data were sent from the USCG’s National Vessel Documentation
Center (NVDC) on CD-ROM to Battelle on May 14, 2007.  The CD-ROM
contained data in both tab-delimited and fixed-length formats as well as
a metadata document.  There were a total of 328,234 records in the file.
 These data were loaded into a table within the Battelle database on May
23, 2007.

VESDOC contains information on domestic merchant and recreational
vessels with a valid Certificate of Documentation, which is a form of
registration used to track U.S.-owned vessels involved in certain trade
activities.  Any vessel involved in fishing activities,
passenger/merchandise transportation, towing, or dredging within U.S.
navigable waters or the Exclusive Economic Zone (EEZ) and that measures
five net tons or greater must be documented.  A Certificate of
Documentation can allow a vessel to be ‘endorsed’ for a specific
trade, such as fishing or recreation, although a vessel that is only
documented for recreation cannot be used for any other purpose.  Some
states do not require a documented recreational vessel to also register
with the relevant state agency, a fact that has implications for the
statistics gathered from the NMMA report (Section 2.1.1)

VESDOC data presented some difficulties when database queries were
developed.  For example, the VESDOC field ‘hailing port’ provides
the state and/or city displayed on the vessel stern and is a good
indicator of the vessel’s geographic area of operation.  However, the
data entered for this field varied from city only to state only to a
city/state combination and the syntax used was inconsistent (e.g.,
commas were not always used to separate city from state, some state
abbreviations had periods, etc.).  These variations in data entry style
made some of the VESDOC querying difficult because the field could not
efficiently be parsed out.

Waterborne Transportation Lines of the United States (WTLUS)

The Waterborne Transportation Lines of the United States (WTLUS) is an
annual three-volume product provided by the U.S. Army Corps of
Engineers’ (USACE) Navigation Data Center’s (NDC) Waterborne
Commerce Statistics Center (WCSC) (USACE 2005a, 2005b, 2005c).  At the
time of publication, the 2005 version of WTLUS was the latest available.
 Battelle downloaded 2005 WTLUS data in Microsoft Excel format directly
from the NDC website on April 25, 2007.  These data were loaded into a
table in the Battelle database.

WTLUS contains summary information on vessel companies and their
U.S.-flagged vessels available for operation as of December 31, 2005
(for vessels capable of carrying passengers or freight, the information
is updated through August 1, 2006).  The three volumes contain summary
statistics, characteristics of the vessels available (e.g., net tonnage,
length, type, year built, etc.), and information on the companies that
own the vessels (e.g., contact information, number of vessels owned by
the company, etc.).

Foreign Vessel Data

U.S. Customs Entrances/Clearances Records

Data on the comings and goings (entrances and clearances) of vessels at
U.S. ports were collected by U.S. Customs and Border Protection (CBP).
The CBP gathers these data during the normal processing of imports and
exports.  Available information included the vessel name, the U.S. port
that it was entering/clearing, the type of vessel, the vessel’s flag
of registry, and the last port (domestic or foreign) that the vessel had
visited.  The CBP entrances and clearances data were used as an
indicator of the numbers and types of non-U.S. flag vessels coming to
U.S. ports.  Therefore, only the data on entrances have been described
in this report.  Battelle downloaded the most recently available (2005)
entrances data from USACE’s NDC website on May 10, 2007.

Port Data

MARAD Vessel Calls

The U.S. Maritime Administration (MARAD) collects annual data on calls
by oceangoing vessels of 10,000 deadweight tons or greater at U.S.
coastal ports.  These data are published in a report entitled Vessel
Calls at U.S. Ports (the most recently available report contained 2005
data [MARAD, 2006a]) as well as in Excel spreadsheets.  Battelle
downloaded the most recently available (2005) data from the MARAD
website as an Excel spreadsheet on April 18, 2007.  The MARAD data
downloaded by Battelle contained information on the number of vessel
calls at U.S. coastal ports, separated by vessel type.

U.S. Customs Entrances/Clearances Records

See Section 2.3.1.

National Ballast Information Clearinghouse

The Smithsonian Environmental Research Center (SERC) and the USCG
maintain the National Ballast Information Clearinghouse (NBIC), which
maintains a database of the ballast water management practices and
activities of commercial ships operating in U.S. waters and seeks to
keep track of the amount and origins of discharged ballast water.  This
database (NBIC, 2004) stores information from ballast water reports,
which must be submitted to the USCG by all ballast tank-equipped vessels
entering U.S. waters, as required under the National Aquatic Invasive
Species Act (NAISA) (33 CFR 151.2045).  The information provided by the
NBIC database includes state, port, vessel name, arrival date, the last
port/country the vessel called at, vessel type, and data on the ballast
water management (e.g., volume discharged [if any] and treatment
method).  The NBIC currently has data available from 1999 through 2004,
although in this report, only the most recent year of data were
provided.

Similar to the problems encountered with the VESDOC data, the NBIC
database proved to be difficult to work with.  The NBIC website allows
users to download data by text file, which can then be exported into
Excel.  However, when the data were imported into Excel, the fields were
not consistent and the rows did not necessarily line up with the correct
column headers.  For example, a column that was supposed to contain
locations may have contained some dates because the rows had been
shifted or were misaligned.  These errors were inherent in the text
files and were not caused by incorrect importing.  Additional problems
were encountered when the data were downloaded in XML format: the
arrival dates for the vessels were not included in the output and,
therefore, could not be imported into Excel (despite the fact that the
arrival dates were included in the text file and HTML output types,
which were unusable in their own right).  Some of the states with the
busiest ports (i.e., the most amount of available data) contained
unallowable characters somewhere embedded in their files, preventing the
files from being imported into Excel at all.  After several attempts
were made to correct the data output through NBIC, Battelle determined
that, given these errors in the data and the inability to correct them
in a timely manner, the data available through NBIC were unusable for
the stated purposes.

EPA National Total Maximum Daily Load (TMDL) Database

To describe the current conditions of the major U.S. ports, information
on pollutants that exceed water quality standards was gathered from
EPA’s collection of water bodies listed under §303(d) of the CWA
(EPA, 2007a).  Based on sampling activities, water bodies that do not
meet state water quality standards for particular pollutants are placed
on a list mandated by CWA §303(d).  The water bodies placed on this
list must have an evaluative report created for them, in which the
pollutant sources are assessed and future loading rates for the listed
pollutant(s) are set.  Current CWA §303(d) lists were available from
the EPA National TMDL database, which contains information on what
pollutants were exceeding state water quality standards in each port, at
the time of the most recent assessment (typically 2002 or 2004).

National Estuary Program 2007 Coastal Condition Report

The National Estuary Program’s (NEP) Coastal Condition report (EPA,
2007b) evaluates the 28 NEPs based on water quality, sediment quality,
benthic condition, and fish tissue contamination.  Five parameters are
measured as indicators of overall water quality of an NEP: dissolved
inorganic nitrogen (DIN), dissolved inorganic phosphorus (DIP),
chlorophyll a, water clarity, and dissolved oxygen (DO).  For each water
quality indicator, EPA has assigned a range of values that, depending on
the sampling data, allows the water quality station in question to be
rated as ‘good’, fair’, or ‘poor’.  For example, if DO
concentrations are measured as >5 mg/L, then the station is rated as
having ‘good’ DO levels.  If the measured concentrations are 2-5
mg/L or <2 mg/L, the station DO level is  rated as ‘fair’ or
‘poor’, respectively.  Once a station’s condition has been
assessed for each of the five indicators, the station’s health as a
whole can be rated as ‘good’, ‘fair’, or ‘poor’, depending
on the combination of indicator ratings.  Finally, once several stations
in an estuary have been evaluated in this manner, the estuary itself can
be rated for overall water quality using the same scale.  Because the
NEP water bodies listed below are described based on their overall
estuarine rating, the following guide can help put the estuarine
conditions in context.

Good: Less than 10% of the NEP estuarine area is in poor condition, and
more than 50% of the NEP estuarine area is in good condition.

Fair: 10% to 20% of the NEP estuarine area is in poor condition, or more
than 50% of the NEP estuarine area is in combined poor and fair
condition.

Poor: More than 20% of the NEP estuarine area is in poor condition.

The same fundamental rating methodologies apply to the sediment quality,
benthic condition, and fish tissue contamination indices.

Discharge Data

Uniform National Discharge Standards Reports

The vast majority of information on discharges originating from vessels
came from the UNDS reports.  A few other sources were helpful, but the
UNDS reports are the greatest single source of information on vessel
discharges.  Although these reports focus on Armed Forces vessels, some
of the discharge studies may be instructive for the evaluation of
discharges from civilian vessels.

The team of federal agencies that is tasked with setting UNDS includes
EPA and the DoD.  Their activities are grouped into phases, with Phase I
consisting of “determining for which Armed Forces vessel discharges it
is reasonable and practicable to require control with a marine pollution
control device (MPCD)” (EPA, 1999a).  Phase II includes setting
performance standards for any MPCD that would be required based on Phase
I determinations.  Finally, Phase III consists of setting requirements
for the designing, constructing, installing, and operating the MPCDs
identified in Phase II.

One of the results of Phase I was a technical development document
entitled “Phase I Uniform National Discharge Standards for Vessels of
the Armed Forces” (EPA, 1999a) which included as appendices separate
“Nature of Discharge” (NOD) reports for each of the 39 discharges
incidental to the normal operation of an Armed Forces vessel identified
during Phase I.  Each NOD report included a description of the discharge
and discussion on the discharge characteristics (e.g., constituents,
rates, concentrations, etc.), as applicable to vessels of the Armed
Forces.  Some of the information presented in the NOD reports was
gathered from primary research, while some of it was taken from existing
literature, expert opinion, and expert workshop results.  During Phase
I, EPA and DoD determined that 14 of the 39 discharges would not require
a MPCD when discharged from an Armed Forces vessel and, therefore, would
not be examined in more detail beyond the NOD report.  Therefore, only
25 discharges were chosen to undergo more extensive assessment for UNDS
purposes.

For Phase II, EPA and DoD split up the 25 remaining discharges into
batches and developed “Discharge Assessment” (DA) reports for the
first batch of seven.  For four of the seven discharges, EPA and DoD
also developed reports on the environmental effects, feasibility impact
analysis, and a characterization analysis.  Therefore, each of the 39
discharges has a NOD report, seven of them have a DA report, and four of
them currently have more in-depth analytical studies.  Phase II is
currently ongoing and more reports from EPA and DoD are expected in the
future.

Pollution Control Technologies/Best Management Practices Data

Uniform National Discharge Standards Reports

While the UNDS NOD reports primarily cover the discharge characteristics
and constituents, the DA reports focus partially on some of the PCTs or
BMPs that were investigated by EPA and DoD for their feasibility in
treating discharges from Armed Forces vessels.  Although the DA reports
are slightly dated (which matters more for technological advances than
it does for the discharge characteristics discussed in the NOD reports),
many of the fundamental technologies and management practices are still
applicable today.   The DA reports were primarily used for PCT and BMP
information on chain locker effluent, deck runoff, elevator pit
effluent, firemain systems, and small boat engine wet exhaust.  In
addition, the Phase I  report (EPA, 1999a) included short separate MPCD
reports for four of the discharges: distillation and reverse osmosis
brine, hull coating leachate, small boat engine wet exhaust, and
underwater ship husbandry.  These four MPCD reports contained more
detailed cost-benefit/feasibility analyses than the DA reports and the
results are described in the appropriate sections of this report.

Lloyd’s Register Ballast Water Treatment Technology Report

In June 2007, a report was published by Lloyd’s Register that
summarized the current status of ballast water treatment technology.
This document was very useful for identifying the technologies that are
currently available or soon to be approved as well as the costs of the
technologies.

Miscellaneous Literature, Reports, and Phone Conversations

Much of what was learned about current PCTs and BMPs for operational
vessel discharges was gained through contacting equipment manufacturers,
conducting literature searches, and searching the endless available
information found on the internet.  For example, California Sea Grant
and California State Lands Commission had a wealth of information on
vessel hulls as vectors for invasive species introductions that helped
to inform the sections on hull coating leachate and underwater ship
husbandry.  Contacts were made with numerous representatives of various
PCTs, especially bilge water and grey water, which helped to establish
the estimated costs for some technologies.  Finally, state government
websites provided information on BMPs for some of the more common
discharges that may be found in a marina.

VESSEL POPULATION STATISTICS

To help EPA fully comprehend the universe of vessels that may need to be
covered by the NPDES permitting program (Section 1.3), Battelle has
compiled the most recently available data on the vessel population that
operates in U.S. waters.  The following sections present current data on
recreational vessels (Section 3.1) and commercial vessels (Section 3.2),
and includes (to the extent that the information was available) data on
numbers and types of vessels.  Section 2.0 describes the data sources
consulted for this section.

Recreational Vessels

Battelle assumed that the vast majority of recreational vessels using
U.S. waters are registered in one of the fifty United States or in one
of the U.S. territories.  Some recreational traffic may come to U.S.
waters from Mexico or Canada, but, of the total population, these
numbers are expected to be minimal.

Each of the states has different registration requirements for
recreational vessels (see Table A-1 in the attachments), so the numbers
provided in the NMMA report may not accurately represent the entire
picture of recreational vessels in any given state.  NMMA’s report
(NMMA, 2007) provides total and state-by-state numbers, in addition to
information on vessel type and size.  However, as indicated in Section
2.2.1, in some states recreational vessels that are documented in VESDOC
are not required to register with the relevant state agency.  The NMMA
report (NMMA, 2007) identifies those states that do not require the
registration of documented vessels and provides the numbers of
documented vessels in those states at the time of publication. Those
states are noted with an asterisk in Tables 3-1 and A-1 and the state
totals in Table 3-1 include both registered and documented recreational
vessels.

Specific ownership information for recreational vessels as well as data
on the port or harbor in which a recreational vessel is primarily used
are not available through NMMA.  However, Table A-1 includes the most
current contact information for the registration agency in each state.
These states can be contacted individually for answers to specific
questions.

Recreational Vessel Numbers

According to NMMA’s 2006 data (NMMA, 2007), the U.S. population of
registered recreational vessels numbers 12,942,414.  Figure 3-1
illustrates the NMMA’s 2006 data on recreational vessel registration
separated by U.S. region.  Although it only encompasses five states, the
Great Lakes region boasts the greatest number of registered recreational
vessels, almost 44% more vessels than the next highest region, Inland.

Figure   STYLEREF 1 \s  3 -  SEQ Figure \* ARABIC \s 1  1 . 2006 U.S.
Regional Recreational Vessel Registration.

Source: NMMA, 2007.

On a state-by-state basis, California had the greatest number of
registered recreational vessels in 2005, with Florida and Michigan
rounding out the top three.  Table 3-1 lists the top twenty states for
numbers of registered recreational vessels and also indicates that the
vast majority of registered vessels in the top twenty states were
mechanically-propelled.  However, as shown in Table A-1, not all states
require non-mechanically propelled vessels to be registered, and in
those states that do require such registration, some vessel owners
either may not be aware of the requirement or may ignore it.  Because
the registration of mechanically-propelled vessels is likely

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  1 .  Top 20 U.S.
States for Total Registered Recreational Vessels, with General Type of
Vessel Indicated.

State	Total Registered Recreational Vessels	Mechanically-Propelleda
Non-Mechanically- Propelledb

California*	989,021	892,722	71,036

Florida	973,859	932,673	41,186

Michigan	944,138	891,937	52,201

Minnesota*	856,411	640,862	212,627

Wisconsin	639,198	635,862	3,336

Texas*	623,868	604,929	9,687

New York	508,536	499,136	9,400

South Carolina*	419,841	393,341	23,422

Ohio	412,375	325,632	86,743

Illinois	380,865	308,875	71,990

North Carolina	362,784	357,253	5,531

Pennsylvania*	355,300	308,851	40,308

Missouri	326,749	277,433	49,316

Georgia	318,212	317,315	897

Louisiana*	310,772	308,104	0

Washington	267,793	267,793	0

Tennessee	267,567	265,966	1,601

Alabama	265,172	262,295	2,877

Virginia*	255,948	240,097	4,976

Iowa	243,924	115,044	128,880

Total	9,722,333	8,846,120	816,014

           Source: NMMA, 2007.

         * Indicates those states that do not require a documented
recreational vessel to be registered with the state.  Totals

            for these states include both registered and documented
recreational vessel numbers. Information on propulsion

            type is for registered vessels only; no data on propulsion
type for recreational documented vessels were

            available.

             a  Mechanically-propelled includes power inboard, power
outboard, power sterndrive (or inboard/

           outboard), personal watercraft (PWC), auxiliary sail inboard,
and auxiliary sail outboard.

         b Non-mechanically propelled includes rowboats, sailboats,
kayaks/canoes, and other.

to be more strictly enforced and monitored (by the state agencies and
entities charged with enforcing vessel registration) than the
registration of non-mechanically-propelled vessels, it is assumed that
the NMMA numbers fully or nearly fully capture the national population
of recreational mechanically-propelled vessels.

Recreational Vessel Propulsion and Size Data

The particular type of engine used on a mechanically-propelled vessel
may have implications for the types of discharges it emits (Section
5.0).  For example, some engine types take up ambient water to act as a
cooling mechanism before discharging it back into receiving waters.  As
shown in Table 3-2, NMMA’s data indicates that almost 66% of all
registered mechanically-propelled recreational vessels are powered by
outboard engines.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  2 . Type of
Propulsion for All Registered Mechanically-Propelled Recreational
Vessels.

Propulsion Type	Number of Boats

Outboard	7,911,509

Inboard/PWC	2,269,542

Sterndrive	1,680,045

Auxiliary Sail Inboard	67,742

Auxiliary Sail Outboard	69,890

TOTAL	11,998,728

		                 Source: NMMA, 2007.

Along with the propulsion type of a recreational vessel, the size is
also important when considering potential discharges.  Smaller vessels
are more likely than larger vessels to be removed from the water for
repairs and maintenance.  Larger vessels are more likely to have greater
deck surface area, may generate grey water from an onboard galley or
bathroom, and have bilge water tanks with greater capacities.

The NMMA data indicate that over 95% of all registered
mechanically-propelled recreational vessels in the U.S. are less than 26
feet in length (NMMA, 2007).  No data are available for sizes of
non-mechanically-propelled vessels.  Table 3-3 presents the number of
vessels less than 26 feet in length and the number of vessels 26 feet
and over in length for each state, organized by the percent of the total
registered mechanically-propelled recreational vessels that are less
than 26 feet in length.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  3 .  Lengths of
All Registered Mechanically-Propelled Recreational Vessels.

State	Number of Recreational Mechanically-Propelled Vessels	Percent of
total less than 26 feet

	Less than 26 feet in length	26 feet and over in length

	Nebraska*	78,499	483	99.39%

North Dakota*	43,431	297	99.32%

South Dakota*	48,013	514	98.94%

Kansas*	92,385	1019	98.91%

Arkansas*	185,139	2,162	98.85%

Montana*	69,020	911	98.70%

Minnesota*	631,838	9,024	98.59%

West Virginia*	43,674	630	98.58%

Wyoming*	25,110	400	98.43%

Georgia	312,222	5,093	98.39%

Louisiana*	302,857	5,247	98.30%

Wisconsin	623,542	12,320	98.06%

New Mexico	36,430	766	97.94%

Pennsylvania*	302,432	6,419	97.92%

Colorado*	92,248	1,958	97.92%

Iowa	112,651	2,393	97.92%

Mississippi*	198,807	4,413	97.83%

South Carolina*	383,366	9,975	97.46%

Maine*	108,402	2,911	97.38%

Oklahoma	211,034	5,879	97.29%

Idaho*	79,756	2,279	97.22%

Alabama	254,566	7,729	97.05%

Table 3–3.  Lengths of All Registered Mechanically-Propelled
Recreational Vessels, continued.

State	Number of Recreational Mechanically-Propelled Vessels	Percent of
total less than 26 feet

	Less than 26 feet in length	26 feet and over in length

	Missouri	268,975	8,458	96.95%

North Carolina	345,986	11,267	96.85%

Texas*	585,715	19,214	96.82%

Indiana	197,760	6,765	96.69%

Kentucky*	157,855	5,579	96.59%

Oregon	178,295	6,348	96.56%

Virginia*	231,629	8,468	96.47%

Vermont	31,120	1,266	96.09%

Utah	71,423	3,001	95.97%

Tennessee	254,708	11,258	95.77%

Michigan	850,848	41,089	95.39%

Illinois	294,328	14,547	95.29%

New Hampshire	93,501	4,669	95.24%

Massachusetts*	134,498	6,892	95.13%

California*	848,098	44,624	95.00%

Nevada*	53,436	3,150	94.43%

Arizona*	133,708	8,019	94.34%

Ohio	305,363	20,269	93.78%

Alaska*	40,379	3,027	93.03%

Connecticut	98,378	9,625	91.09%

Florida	847,626	85,047	90.88%

Washington	242,777	25,016	90.66%

New York	451,654	47,482	90.49%

New Jersey	171,450	20,463	89.34%

Hawaii*	12,461	1,851	87.07%

Delaware*	44,218	7,111	86.15%

Maryland	165,018	31,677	83.90%

Rhode Island	35,930	7,726	82.30%

District of Columbia	1228	784	61.03%

TOTAL	11,383,787	547,514	95.41%

                    Source: NMMA, 2007.

	        * Documented recreational vessel numbers are not included in
this table for those states that do not require a

	         documented vessel to also be registered with the state.

Commercial Vessels

As described in Section 2.0, data on commercial vessels operating in
U.S. waters were obtained primarily from the USCG (VESDOC) and USACE
(WTLUS).

Domestic Commercial Vessel Numbers and Types

USACE’s most recent WTLUS volumes (USACE, 2005a, 2005b, 2005c) contain
substantial and well-organized data on U.S.-flagged passenger and cargo
vessels operating in U.S. waters.  Table 3-4 presents the summary
findings by propulsion type (self-propelled or non-self-propelled); the
subtypes contained within these general categories are provided in the
table footnote.  Figure 3-2 illustrates that the vast majority (78%) of
cargo and passenger vessels operating in U.S. waters can be found in the
Mississippi River System or the Gulf Intracoastal Waterway.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  4 .  Summary of
the U.S.-Flag Cargo or Passenger Vessels Operating in U.S. Waters by
Region.

Type of Vessel	Total Number of Vessels	Atlantic, Gulf, and Pacific
Coasts	Mississippi River System and the Gulf Intracoastal Waterway	Great
Lakes System

SELF-PROPELLED

Dry Cargo and/or Passenger, Offshore Support	2,967	1,638	1,162	167

Vehicular Ferries and Railroad Cars	619	472	82	65

Tankers	100	90	6	4

Towboats	5,290	1,864	3,303	123

TOTAL SELF-PROPELLED	8,976	4,064	4,553	359

TOTAL CARGO CAPACITYa (short tons)	12,342,485	9,175,249	894,749
2,272,487

TOTAL PASSENGER CAPACITYb (persons)	451,723	330,271	85,072	36,380

NON-SELF-PROPELLED

Barges, Dry Cargo	27,876	3,961	23,739	176

Barges, Tanker	4,151	618	3,525	8

Railroad Car Barge	25	24	1	0

TOTAL NON-SELF-PROPELLED	32,052	4,603	27,265	184

TOTAL CARGO CAPACITYc (short tons)	57,035,748	11,398,711	45,259,164
377,873

TOTAL PASSENGER CAPACITYd (persons)	553	167	386	0

GRAND TOTAL SELF- AND NON-SELF-PROPELLED	41,028	8,667	31,818	543

Source: USACE, 2005a.

a Includes cargo capacity of dry cargo vessels and tankers.

b Includes passenger capacity of passenger vessels and vehicular ferries

c Includes cargo capacity of dry cargo barges, tanker barges, and
railroad car floats

d Includes passenger capacity of dry cargo barges

Self-Propelled, Dry Cargo: Crewboat / Supply / Utility Vessel; Vehicle
Carrier; General Cargo Freighter; Passenger Carrier; Break Bulk / RO-RO
Carrier; Combination Passenger and Cargo; RO-RO Vessel; Ferry; Bulk
Carrier; Railroad Car Ferry; Containership; Lash Vessel; Partial
Containership; Excursion / Sightseeing Vessel; Container / Vehicle /
Trailer (RO-RO) Carrier

Self-Propelled, Tanker: Petroleum / Chemical Carrier; Liquid Gas
Carrier; Chemical Carrier; Other Tanker; Liquid Bulk Tanker

Towboat: Pushboat; Tugboat

Non-Self-Propelled, Tanker: Liquid Cargo Barge (Single Hull); Liquid
Cargo Barge (Double Bottom Only); Liquid Cargo Barge (Double Hull);
Other Liquid Cargo Barge, Not; Liquid Cargo Barge (Double Sided Only)
Elsewhere Included

Non-Self-Propelled, Dry Cargo: Open Hopper Barge; Covered Dry Cargo
Barge; Covered Hopper Barge; RO-RO Barge; Carfloat (Railroad Car Barge);
Container Barge; Flat / Deck Barge; Lash / Seabee Barge; Pontoon Barge;
Convertible Barge; Open Dry Cargo Barge; Other

Figure   STYLEREF 1 \s  3 -  SEQ Figure \* ARABIC \s 1  2 . Summary of
U.S. Flag Cargo and Passenger Vessels Operating in U.S. Waters by
Region.

Source: USACE, 2005a

As described in Section 2.2.3, WTLUS also provides information on the
Transportation Series Operator (TSO) company that operates these 41,028
passenger or cargo vessels (Volume 2) as well as the relevant
characteristics of the vessels themselves (Volume 3).  There are 2,732
TSO companies that own the 41,028 vessels (USACE, 2005b).  Table 3-5
lists the top twenty U.S. TSO companies according to the number of
vessels operated and includes the principal types of vessels operated as
well as a list of the major commodities carried.  More detailed
information on all 2,732 TSO companies with specific contact information
can be found in USACE (2005b).  USACE (2005c) also provides more detail
on each vessel, including in which specific subtype (in list above) the
vessel is categorized, the vessel’s registered length/depth/breadth,
and horsepower.

As described in Section 2.2.1, VESDOC is another source for data on
commercial vessels operating in U.S. waters.  All U.S.-owned commercial
vessels involved in passenger or merchandise transportation as well as
towing or dredging must be documented with the USCG.  One of the ways
VESDOC data are organized is by “Vessel Service Type”, which
indicates the primary service for which the vessel was documented.  The
VESDOC metadata (USCG, 2007b), however, caution that the vessel service
type may not be the most reliable indicator of the specific use of a
vessel.  Rather, USCG (2007b) recommends using the vessel numbers
provided in the ‘trade indicator’ fields, as described in Section
2.2.1, for a more complete picture.  However, the vessel service type
field is broken into more categories than the trade indicator field; in
addition, the trade indicator field appeared to be focused more on where
the vessel could be operated and less on the general use of the vessel.
Table 3-6 provides the VESDOC statistics for the various vessel service
types.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  5 . Top Twenty
U.S. TSO Companies Operating Cargo or Passenger Vessels in U.S. Waters
by Number of Vessels Operated.

TSO Name	City/State Location of the TSO	Total Number of Vessels Operated
by TSO	Principal Types of Vessels Operated by TSOa	List of Principal
Commodities Carried by TSO’s Vessels

Ingram Barge Co.	Nashville, TN	4,256	DCB, DOB, DHTB	Towing, petroleum
products, bulk freight, coal, coke, grain and aggregates

American Commercial Lines, LLC	Jeffersonville, IN	3,249	DCB, DOB, DHTB
Towing, steel, petroleum products, coal, coke, sulphur, sugar, creosote,
grain, scrap iron, chemicals, salt and general commodities

American River Transportation Co.	Ama, LA	2,221	DCB, DHTB, DB	Grain and
grain products, coal, fertilizer, salt and scrap

AEP Memco, LLC	Chesterfield, MO	1,620	DOB, DCB, PUSH	Towing, coal,
grain, grain products, cement, chemicals, salt, steel, lime, coke, slag,
and aggregates

Kirby Inland Marine, LP	Houston, TX	1,013	DHTB, PUSH, OTB	Chemical and
petroleum products

Crounse Corporation	Paducah, KY	939	DOB, PUSH	Towing, bulk freight and
coal

Cargill Marine and Terminal, Inc.	Minneapolis, MN	673	DCB	Coal, grain,
vegetable oil, salt and miscellaneous commodities

McDonough Marine Service (Div. of Marmac Corporation)	Metarie, LA	672
DB, DOB, DHTB	Miscellaneous freight

Teco Barge Line	Metropolis, IL	612	DOB, DCB	Coal, phosphate sulphur and
bulk commodities

Canal Barge Company, Inc.	New Orleans, LA	608	DOB, DHTB, DB	Towing, bulk
petroleum, molten sulphur, chemicals, coal, grain, fertilizer and
general cargo

SCF Marine, Inc.	St. Louis, MO	581	DCB, DOB, DB	Grain, industrial
commodities, rice, meals, salt, coal and dry bulk commodities

Campbell Transportation Co.	Charleroi, PA	404	DOB	Coal, sand & gravel

American Commercial Barge Line, LLC	Jeffersonville, IN	383	DCB	Towing,
liquid chemicals, petroleum, crude oil and refined oil products

Central Gulf Lines, Inc.	New Orleans, LA	378	LSB	Steel, paper products
and miscellaneous cargo - rubber, timber, flour and rice

Forest Lines, LLC	New Orleans, LA	332	LSB	Paper products

Table 3–5. Top Twenty U.S. TSO Companies Operating Cargo or Passenger
Vessels in U.S. Waters by Number of Vessels Operated, continued.

TSO Name	City/State Location of the TSO	Total Number of Vessels Operated
by TSO	Principal Types of Vessels Operated by TSOa	List of Principal
Commodities Carried by TSO’s Vessels

Alter Barge Line, Inc.	Bettendorf, IA	327	DCB, DB	Coal, steel, scrap,
grain, containers and general commodities; bulk products - regulated and
exempt

Consolidation Coal Company (River Division)	Elizabeth, PA	297	DOB	Coal

Marquette Transportation Company	Paducah, KY	285	DCB, DB, PUSH	Grain,
coal, salt, fertilizer and rock

Pine Bluff Sand and Gravel Company	Pine Bluff, AR	253	DB, DOB, PUSH
Construction equipment and materials, sand and gravel

Luhr Bros., Inc.	Columbia, IL	245	DB, DOB, PUSH	Crushed limestone
products, rip-rap and heavy construction equipment

Source: USACE, 2005b.

a Vessel type abbreviations: DCB = dry covered barge; DOB = dry open
barge; DB = deck barge; DHTB = double hull tank barge; PUSH = pushboat;
LSB = lash/seabee barge; OTB = other tank barge

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  6 . Total Number
of U.S. Documented Vessels by Service Type.

VESDOC Vessel Service Type	Total Number of Vessels Documented

Commercial Fishing Vessel	28,972

Fish Processing Vessel	35

Freight Barge	23,153

Freight Ship	651

Industrial Vessel (e.g., cable layer, dredge, crane barge)	823

Mobile Offshore Drilling Unit	118

Offshore Supply Vessel	1,114

Oil Recovery	372

Passenger (Inspected)	9,539

Passenger (Uninspected)	2,311

Passenger Barge  (Inspected)	109

Passenger Barge  (Uninspected)	127

Public Freight	6

Public Tankship/Barge	2

Public Vessel, Unclassified	24

Research Vessel	234

School Ship	38

Tank Barge	4,134

Tank Ship	129

Towing Vessel	6,898

Unclassified/Unknown/Unspecified	5,357

Source: VESDOC, 2007

Domestic Commercial Fishing Vessel Numbers

Because the USCG differentiates between commercial vessels and
commercial fishing vessels (see Section 3.2), these two categories of
vessels are dealt with separately in this report.  As described in
Section 2.2.1, VESDOC categorizes documented vessels based on the trade
for which the vessel is licensed.  One of the trade categories is
‘fishery’, which applies to vessels “licensed to engage in the
fisheries trade in the navigable waters of the U.S. and on the Exclusive
Economic Zone” (USCG, 2007b).  Another trade category is ‘limited
fishery only’, but the VESDOC metadata (USCG, 2007b) does not define
this category further.  Battelle has included this latter category in
the commercial fishing vessel totals in the next paragraph.  Any vessel
owned by a U.S. citizen that commercially fishes in U.S. waters must be
documented and, therefore, is included in the most recent VESDOC data.

The May 2007 VESDOC data indicate that there are 33,550 commercial
fishing vessels licensed to fish in U.S. navigable waters and the EEZ.
Due to the data problems associated with VESDOC (as described in Section
2.2.1), Battelle was unable to query the database by ‘hailing port’
which would have been a good indicator of the vessel’s geographic area
of operation (USCG, 2007b).  The contact state and/or city of a given
vessel’s managing owner was available and, although the owner’s
state may not in all cases be equivalent to the ‘hailing port’
state, it may also be a reasonable indicator of where the fishing vessel
typically operates.  Figure 3-3 illustrates the number of documented
commercial fishing vessels by owner’s contact state.

Figure   STYLEREF 1 \s  3 -  SEQ Figure \* ARABIC \s 1  3 .  Documented
Commercial Fishing Vessels by Owner’s Contact State.

Source: USCG, 2007a

Foreign Commercial Vessel Numbers

Information on foreign commercial vessels operating in U.S. waters was
more difficult to obtain.  MARAD provides general world fleet
statistics, but does not have data on which waterways world fleet
vessels typically operate.

One source for the number of foreign commercial vessels visiting U.S.
waters is the U.S. Customs Entrances/Clearances records (U.S. CBP,
2007).  These data are also discussed in Section 4.0, although in terms
of what type of port (domestic or foreign) a vessel had visited
immediately prior to entering the U.S. port at which it was recorded.
As described in Section 2.3, the 2005 Entrances/Clearances records were
the most recent available from the NDC.  According to these data, there
were a total of 90,328 vessel entrances to a major U.S. port or waterway
in 2005 and 7,726 different vessels made these entrances (U.S. CBP,
2007).  Of the 7,726 unique vessels making entrance, 6,982 flew one of
83 different foreign flags (the remaining 744 flew U.S. flags).  In the
CBP (2007) data, a foreign vessel may have been recorded under more than
one flag; this was due to some vessels changing their flag of registry
during the year and, therefore, being recorded under more than one flag.
Table 3-7 presents the top twenty most frequently recorded flags of
vessels entering a major U.S. port or waterway in 2005.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  7 . Top 20 Most
Frequently Recorded Flags Entering U.S. Ports or Waterways in 2005

COUNTRY	TOTAL ENTRANCES

Panama	13,670

United States and territories	11,216

Bahamas	9,682

Liberia	8,569

Canada	4,662

Antigua and Barbuda	4,578

Marshall Islands	3,227

Singapore	3,169

Cyprus	2,745

Norway	2,600

Greece	2,216

Netherlands	2,123

St. Vincent and the Grenadines	1,963

Hong Kong	1,946

Malta	1,839

Bermuda	1,743

Germany	1,641

United Kingdom	1,525

Danish International Register	868

Italy	692

		           Source: U.S. CBP, 2007.

PORT FINDINGS

Information on the busiest ports in the U.S. is useful for understanding
the characteristics of national waterway traffic, of both domestic and
foreign arrivals.  The following sections describe the various available
information on U.S. port traffic, including number of vessel calls, flag
registration of arriving vessels, and the last port of call of arriving
vessels.

Calls to U.S. Ports

Figure 4-1 illustrates the number of vessel calls to U.S. coastal ports
in 2005 by geographic region as provided by MARAD (2006).  MARAD only
recorded self-propelled vessels of greater than 10,000 tons deadweight.

The U.S. Gulf region received nearly 31% of all coastal vessel calls in
2005, followed by the South Atlantic region with approximately 19%.
Table 4-1 lists the total number of calls made by vessels to all coastal
U.S. ports in 2005 (MARAD, 2006) along with the most frequent type of
vessel calling there.  Table 4-2 shows the top 20 coastal U.S. ports for
2005 vessel calls; these 20 ports will hereafter be referred to as the
‘major ports’.

Figure   STYLEREF 1 \s  4 -  SEQ Figure \* ARABIC \s 1  1 . 2005 Vessel
Calls to U.S. Coastal Ports by Geographic Region.

Source: MARAD, 2006

North Atlantic: Ports from Eastport, ME to Baltimore, MD

South Atlantic: Ports from Alexandria, VA to Miami, FL

U.S. Gulf: Ports from Key West, FL to Brownsville, TX

Pacific Southwest: Ports from Crockett, CA to San Diego, CA and all
Hawaiian ports

Pacific Northwest: Ports from Barrow, AK to Coos Bay, OR

Puerto Rico: Ports in Puerto RicoTable   STYLEREF 1 \s  4 -  SEQ Table
\* ARABIC \s 1  1 .  2005 Vessel Calls at All U.S. Coastal Ports
Organized by Geographic Region

State	Porta	Number of Calls	Most Frequently Calling Vessels

NORTH ATLANTIC

CT	Bridgeport	87	General cargo vessels

CT	Groton	4	Tanker

CT	New Haven	185	Tanker, General cargo vessels

CT	New London	32	General cargo vessels

MA	Boston	332	General cargo vessels, Tanker

MA	Fall River	1	General cargo vessels

MA	Salem	2	General cargo vessels

MA	Sandwich	2	Tanker

MD	Annapolis	134	General cargo vessels

MD	Baltimore	1,825	General cargo vessels, Roll on-Roll Off cargo vessels

MD	Cove Point	74	Tanker

MD	Piney Point	50	Tanker

ME	Bucksport	2	Tanker

ME	Camden	1	General cargo vessels

ME	Eastport	13	General cargo vessels

ME	Portland	364	Tanker

ME	Sandy Point	1	Tanker

ME	Searsport	19	Tanker

NH	Portsmouth	129	General cargo vessels, Tanker

NY	Albany	1	General cargo vessels

NY	Kingston	2	General cargo vessels

NY	New York	4,902	General cargo vessels, Tanker

NY	Northport	9	Tanker

NY	Northville	47	Tanker

NY	Riverhead	2	Tanker

NY	Stony Point	2	General cargo vessels

PA	Philadelphia	2,998	Tanker, General cargo vessels

RI	Brayton Point	5	General cargo vessels

RI	Davisville	78	Roll on-Roll Off Cargo Vessels

RI	Jamestown	1	General cargo vessels

RI	Newport	1	General cargo vessels

RI	Providence	193	Tanker, General cargo vessels

PACIFIC NORTHWEST

AK	Afognak	95	Roll on-Roll Off Cargo Vessels

AK	Anchorage	150	General cargo vessels

AK	Drift River Term.	1	Tanker

AK	Dutch Hbr.	157	General cargo vessels

AK	Hawk Inlet	2	General cargo vessels

AK	Homer	79	Tanker

AK	Hoonah	5	General cargo vessels

AK	Hydaburg	15	General cargo vessels

AK	Juneau	1	Tanker

AK	Kake	5	General cargo vessels

Table 4–1.  2005 Vessel Calls at All U.S. Coastal Ports Organized by
Geographic Region, continued

State	Porta	Number of Calls	Most Frequently Calling Vessels

AK	Kenai	11	General cargo vessels

AK	Ketchikan	4	General cargo vessels

AK	Klawock	12	General cargo vessels

AK	Kodiak	97	General cargo vessels

AK	Nikiski	143	Tanker

AK	Red Dog	9	General cargo vessels

AK	Seward	7	General cargo vessels

AK	Tolstoi Bay	5	General cargo vessels

AK	Valdez	399	Tanker

OR	Columbia River	2,189	General cargo vessels

OR	Coos Bay	43	General cargo vessels

WA	Anacortes	8	General cargo vessels

WA	Bellingham	2	General cargo vessels

WA	Bremerton	2	General cargo vessels

WA	Cherry Point	209	Tanker

WA	Everett	33	General cargo vessels, Roll on-Roll Off cargo vessels

WA	Ferndale	123	Tanker

WA	Manchester	11	Tanker

WA	March Point	342	Tanker

WA	Olympia	20	General cargo vessels, Roll on-Roll Off cargo vessels

WA	Point Wells	19	Tanker

WA	Port Angeles	277	Tanker

WA	Port Townsend	3	General cargo vessels

WA	Seattle	1,186	General cargo vessels

WA	Tacoma	1,270	General cargo vessels

WA	Westport	7	General cargo vessels

PUERTO RICO

PR	Guanica	1	General cargo vessels

PR	Guayanilla	125	Tanker

PR	Las Mareas	7	General cargo vessels

PR	Mayaguez	1	General cargo vessels

PR	Ponce	19	General cargo vessels

PR	Puerto Rico	9	Tanker

PR	San Juan	1,086	General cargo vessels

PR	Yabucoa	42	Tanker

PACIFIC SOUTHWEST

CA	El Segundo	245	Tanker

CA	LA/Long Beach	5,178	General cargo vessels

CA	Port Hueneme	397	Roll on-Roll Off cargo vessels

CA	S. California light. area	24	Tanker

CA	San Diego	319	Roll on-Roll Off cargo vessels, General cargo vessels

CA	San Francisco	3,871	General cargo vessels

HI	Barbers Point	162	Tanker

HI	Hilo	54	Roll on-Roll Off cargo vessels

HI	Honolulu	586	General cargo vessels

Table 4–1.  2005 Vessel Calls at All U.S. Coastal Ports Organized by
Geographic Region, continued

State	Porta	Number of Calls	Most Frequently Calling Vessels

HI	Kahului	77	Roll on-Roll Off cargo vessels

HI	Kawaihae	1	General cargo vessels

HI	Nawiliwili	11	Roll on-Roll Off cargo vessels

HI	Port Allen	1	Roll on-Roll Off cargo vessels

SOUTH ATLANTIC

FL	Cape Canaveral	2	General cargo vessels, Roll on-Roll Off cargo
vessels

FL	Fernandina	6	General cargo vessels

FL	Jacksonville	1,237	General cargo vessels, Roll on-Roll Off cargo
vessels

FL	Miami	1,299	General cargo vessels

FL	Palm Beach	116	General cargo vessels

FL	Port Canaveral	55	General cargo vessels, Roll on-Roll Off cargo
vessels

FL	Port Everglades	1,182	General cargo vessels, Tanker

GA	Brunswick	243	Roll on-Roll Off cargo vessels

GA	Savannah	2,333	General cargo vessels

NC	Morehead City	36	General cargo vessels

NC	Southport	1	Tanker

NC	Wilmington	600	General cargo vessels, Tanker

SC	Charleston	2,046	General cargo vessels

SC	Georgetown	6	General cargo vessels

VA	Virginia Ports	2,547	General cargo vessels

U.S. GULF

AL	Mobile	811	General cargo vessels

FL	Key West	2	Tanker

FL	Panama City	6	General cargo vessels

FL	Pensacola	19	General cargo vessels

FL	Port Manatee	159	General cargo vessels

FL	Tampa	1,003	Tanker, General cargo vessels

LA	Gulf Gateway Term.	2	Tanker

LA	Lake Charles	701	Tanker

LA	LOOP Term.	401	Tanker

LA	New Orleans	3,749	General cargo vessels, Tanker

LA	Port Fourchon	1	Tanker

LA	Southwest Pass light. area	3	Tanker

MS	Gulfport	39	General cargo vessels

MS	Pascagoula	233	Tanker

MS	Pascagoula light. area	5	Tanker

TX	Beaumont	72	General cargo vessels

TX	Brownsville	158	General cargo vessels

TX	Corpus Christi	989	Tanker

TX	Freeport	759	Tanker

TX	Freeport light. area	2	Tanker, Roll on-Roll Off cargo vessels

TX	Galveston	429	General cargo vessels, Tanker

TX	Galveston light. area	98	Tanker

Table 4–1.  2005 Vessel Calls at All U.S. Coastal Ports Organized by
Geographic Region, continued

State	Porta	Number of Calls	Most Frequently Calling Vessels

TX	Houston	5,891	Tanker, General cargo vessels

TX	Ingleside	107	General cargo vessels, Tanker

TX	Point Comfort	321	Tanker

TX	Port Arthur	1,563	Tanker

TX	S. Sabine Point light. Area	17	Tanker

TX	Smith’s Bluff	1	Tanker

TX	Texas City	1,142	Tanker

 Source: MARAD, 2006.

a Some of the port names in this table refer to groupings of
geographically-similar ports.  This was done to decrease the
unwieldiness of the table and had been done by MARAD in previous years
(MARAD, 2006).  The groupings are described below.

Columbia River

Includes the ports of Astoria, Kalama, Longview, Portland, Rainier,
Vancouver, and Willbridge.

L.A/Long Beach

Includes the ports of Los Angles and Long Beach.

New Orleans

Includes the ports of Ama, Arabi, Avondale, Baton Rouge, Belle Chasse,
Boothville, Braithwaite, Burnside, Chalmette, Convent, Darrow, Davant,
Destrechan, Donaldsonville, Empire, Garyville, Geismar, Good Hope,
Gramercy, Gretna, Harvey, La Place, Magnolia, Marrero, Meraux, Michound,
Myrtle Grove, New Orleans, Norco, Ostrica, Paulina, Pilottown,
Plaquemine, Port Allen, Port Sulfur, Reserve, St. Bernard, St. James,
St. Rose, Taft, Violet, Waggaman, and Westwago.

Philadelphia

Includes the ports of Burlington, NJ, Camden NJ, Claymont, DE, Chester,
PA, Delair, NJ, Delaware City, DE, Eddystone, PA, Fairless Hills,
Gloucester, NJ,  Marcus Hook, PA, Paulsboro, NJ, Philadelphia, PA, Reedy
Point, DE, Salem, NJ, Tullytown, PA, Westville, NJ, and Wilmington, DE.

San Francisco Bay

Includes the ports of Alameda, Antioch, Bencia, Concord, Crockett,
Martinez, Oakland, Pittsburg, Redwood City, Richmond, Rodeo, Sacramento,
San Francisco, Selby, and Stockton.

Virginia

Includes the ports of Chesapeake, Hampton Roads, Hopewell, Lynnhaven
Roads, Newport News, Norfolk, Portsmouth, Richmond, and Yorktown

Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  2 . Top 20 U.S.
Ports by Number of Vessel Calls in 2005.

Coastal Region	Port	State	Number of Calls

U.S. Gulf	Houston	TX	5,891

Pacific Southwest	LA/Long Beach	CA	5,178

North Atlantic	New York	NY	4,902

Pacific Southwest	San Francisco	CA	3,871

U.S. Gulf	New Orleans	LA	3,749

North Atlantic	Philadelphia	PA	2,998

South Atlantic	Virginia Ports	VA	2,547

South Atlantic	Savannah	GA	2,333

Pacific Northwest	Columbia River	OR	2,189

South Atlantic	Charleston	SC	2,046

North Atlantic	Baltimore	MD	1,825

U.S. Gulf	Port Arthur	TX	1,563

South Atlantic	Miami	FL	1,299

Pacific Northwest	Tacoma	WA	1,270

Table 4–2. Top 20 U.S. Ports by Number of Vessel Calls in 2005,
continued.

Coastal Region	Port	State	Number of Calls

South Atlantic	Jacksonville	FL	1,237

Pacific Northwest	Seattle	WA	1,186

South Atlantic	Port Everglades	FL	1,182

U.S. Gulf	Texas City	TX	1,142

Puerto Rico	San Juan	PR	1,086

U.S. Gulf	Tampa	FL	1,003

        Source: MARAD, 2006.

Table 4-2 shows that Houston, TX had more vessel calls than any other
coastal U.S. port in 2005.

The U.S. CBP data on vessel entrances and clearances (CBP, 2007) provide
information on all U.S. ports (coastal and inland), including the date a
vessel entered a given port (i.e., filed an entrance record), the
vessel’s flag, and the previous port the vessel had called at.  Having
information on the previous port visited by a vessel can help evaluate
the threat of invasive species introductions.  Table 4-3 presents the
number of calls that the previous port was foreign (‘foreign calls’)
and the number of calls that the previous port was domestic (‘domestic
calls’) for the 20 U.S ports with the most total calls in 2005,
according to the CBP data.  The top 20 ports with the most calls in 2005
according to CBP may differ slightly from the MARAD data; MARAD recorded
data only at coastal ports, while CBP recorded data at all U.S. ports.
In addition, MARAD grouped some of the geographically similar coastal
ports (see Table 4-1) and CBP did not.

Table 4-3 shows that a number of the top 20 U.S. ports primarily receive
foreign calls: Port Everglades, FL; Long Beach, CA; San Juan, PR; and
Seattle, WA.  Elizabeth River, VA was the U.S. port with the highest
percentage of domestic calls, followed by Oakland, CA.  One caveat
presents itself with these data: a domestic call does not necessarily
mean that there is less of an invasive species introduction threat than
a foreign call.

Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  3 . 2005 Domestic
and Foreign Vessel Calls at Top 20 U.S. Ports.

U.S Port	Number of Domestic Calls	Number of Foreign Calls	Percent
Domestic Calls	Most Frequently Cited Last Port*

Houston, TX	2,032	3,585	36.2%	Mexico

New York, NY	1,565	3,218	32.7%	Canada

Port Everglades, FL	642	3,665	14.9%	Bahamas

Miami, FL	788	2,937	21.2%	Bahamas

Long Beach, CA	469	2,159	17.8%	Mexico

San Juan, PR	333	2,186	13.2%	U.S. Virgin Islands

Savannah, GA	1,671	725	69.7%	Elizabeth River, VA

St. Thomas, VI	1,235	1,128	52.3%	San Juan, PR

Seattle, WA	142	2,197	6.1%	Canada

New Orleans, LA	1,067	1,222	46.6%	Houston, TX (D); Mexico (F)

Charleston, SC	1,565	709	68.8%	Elizabeth River, VA

Los Angeles, CA	368	1,856	16.5%	Mexico

Baltimore, MD	1,175	812	59.1%	New York, NY

Elizabeth River, VA	1,689	134	92.6%	New York, NY

Table 4–3. 2005 Domestic and Foreign Vessel Calls at Top 20 U.S.
Ports, continued.

U.S Port	Number of Domestic Calls	Number of Foreign Calls	Percent
Domestic Calls	Most Frequently Cited Last Port*

Oakland, CA	1,248	471	72.6%	Los Angeles, CA

Bayou Lafourche, LA	14	1,679	0.8%	Unknown*

Galveston, TX	75	1,520	4.7%	Unknown*

Tacoma, WA	188	1,406	11.8%	Canada

Jacksonville, FL	662	880	42.9%	Bahamas

South Louisiana, LA	332	1,141	22.5%	Mexico

 Source: CBP, 2007

* According to CBP (2007), a port cited as ‘Unknown’ reported its
last port as “high seas”

Receiving Water Characteristics

For each of the top 20 U.S. ports (as determined by total number of
vessel calls and listed in Table 4-3), several sources were consulted to
assess the current water quality conditions.  In the following sections,
each of the top 20 ports are briefly described in terms of their water
quality and general condition.   As described in Sections 2.4.4 and
2.4.5, the sources consulted for the following descriptions included
EPA’s National TMDL database (EPA, 2007a), the 2007 NEP Coastal
Condition Report (EPA, 2007b), and a collection of other sources that
are cited below in the relevant sections.  The water quality
characteristics of the top 20 ports are described below from most vessel
calls to fewest (based on CBP, 2007).

Houston, Texas

EPA’s National TMDL database lists chlordane (in tissue), dieldrin (in
tissue), dioxin, heptachlor epoxide, polychlorinated biphenyls (PCBs)
(in tissue), and sediment toxicity as the pollutants in exceedance of
water quality standards in Port of Houston waters (as of 2004, the most
recently-available year).  According to the mapping feature of the
National TMDL database, the water body segments that comprise the
Houston Ship Channel and the Port of Houston include: Barbour’s Cut,
Houston Ship Channel/San Jacinto River Tidal, Black Duck Bay, Tabbs Bay,
Scott Bay, and Houston Ship Channel/Buffalo Bayou Tidal.  All of these
segments are impaired for one or more of the pollutants listed above.
In addition, vessels traveling to and from the Port of Houston must
traverse Upper Galveston Bay, which is impaired for bacteria, dioxins,
and PCBs, prior to entering the Houston Ship Channel (EPA, 2007a).

Galveston Bay is designated as an NEP estuary, with the 2007 Coastal
Condition Report describing Galveston Bay as well-mixed and shallow and
strewn with extensive oyster beds.  The water quality in Galveston Bay
is classified as ‘fair-to-poor’, with high DIN and DIP
concentrations being the main causes of excessive chlorophyll a levels
and poor water clarity.  DO concentrations, however, were rated as
‘good’.  Total organic carbon (TOC) concentrations and sediment
toxicity was both rated ‘good’, although sediment toxicity data were
not available for 31% of the estuary.  Finally, sediment contaminant
levels were classified as ‘fair’ (EPA, 2007b).

According to the Galveston Bay Estuary Program’s water quality
monitoring program, nutrient (e.g., total nitrogen, ammonia, and total
phosphorus) and chlorophyll a concentrations in Galveston Bay, its
sub-bays, and tributaries have been generally declining since monitoring
began in the 1970s, with many areas achieving a ‘ good’ or ‘very
good’ rating.  Other areas, however, especially those areas
surrounding the shipping route through the Bay (e.g., Upper and Lower
Galveston Bay, Houston Ship Channel, Buffalo Bayou) exhibit a ‘fair’
or ‘poor’ rating for nutrients and chlorophyll a.  Enterococcus,
Escherichia coli, and fecal coliform were also found in high
concentrations in many tributaries surrounding Galveston Bay and the
Port of Houston; for many of these tributaries, the bacterial levels
have been consistently high since the 1970s (EPA, 2007b)

New York City, NY

The Port of New York City is comprised of facilities located in both New
York and New Jersey.  EPA’s National TMDL database lists PCBs,
nitrogen, mercury, cadmium, oxygen demand, floatables, and dioxins as
the pollutants in exceedance of water quality standards in Port of New
York and New Jersey waters (as of 2004, the most recently-available
year). According to the mapping feature of the National TMDL database,
the water body segments that comprise the Port of New York include:
Lower East River, Upper New York/New Jersey Harbor, Kill Van Kull,
Newark Bay, and Arthur Kill and tidal tributaries.  All of these
segments are impaired for one or more of the pollutants listed above
(EPA, 2007a).

The water quality of the New York-New Jersey Harbor Estuary Program
(HEP) is discussed in EPA’s 2007 Coastal Condition Report and is rated
as ‘poor’; however, there are no data available for approximately
62% of the estuarine area.  According to available data, DIN and DIP
levels were elevated over a wide area of the estuary and rated as
‘fair’ and ‘poor’, respectively.  The estuary was rated
‘good’ for chlorophyll a, DO levels, and water clarity.   Sediment
quality, however, was generally considered ‘poor’, with both
sediment toxicity and sediment contaminants being elevated.  TOC in
sediment was rated ‘good’ for a majority of the estuarine area.  On
a positive note, none of the water quality indicators monitored by the
HEP (i.e., fish tissue contamination, coliform bacteria levels,
dissolved oxygen, harmful algal blooms, etc.) has exhibited downhill
trends since monitoring began.  Despite these positive trends, the
overall health of the estuary is rated as ‘poor’ primarily because
of the deteriorating trends in some wading bird and fish populations and
ongoing fish consumption advisories (EPA, 2007b).

Port Everglades, Florida

EPA’s National TMDL database lists coliforms, DO, and nutrients as the
pollutants in exceedance of water quality standards in Port Everglades
waters (as of 2002, the most recently-available year). According to the
mapping feature of the National TMDL database, the water body segment
that comprises the Port of Port Everglades includes the Intracoastal
Waterway in Dade County (EPA, 2007a).

Water quality sampling programs managed by the Broward County Department
of Natural Resources and the South Florida Water Management District did
not have stations located in or around the Port of Port Everglades.

Miami, Florida

EPA’s National TMDL database does not list any water quality
exceedances in and around the Port of Miami. Water quality sampling
programs managed by the Miami-Dade County Department of Environmental
Resource Management and the South Florida Water Management District did
not have stations located in or around the Port of Miami (EPA, 2007a).

Los Angeles/Long Beach, CA

EPA’s National TMDL database lists pesticides
(dichloro-diphenyl-trichloroethane [DDT], toxaphene, chlordane, and
dieldrin), polycyclic aromatic hydrocarbons (PAHs), PCBs, zinc, copper,
chromium, lead, mercury, cadmium, nickel, and sediment toxicity as the
pollutants in exceedance of water quality standards in the waters in and
around the ports of Los Angeles/Long Beach (as of 2002, the most
recently-available year).  According to the mapping feature of the
National TMDL database, the water body segments that comprise the Port
of Los Angeles/Long Beach include: Los Angeles Harbor Main Channel, Los
Angeles Harbor Southwest Slip, Los Angeles Fish Harbor, Los Angeles
Harbor Consolidated Slip, Long Beach Harbor Main Channel, and San Pedro
Bay Near/Offshore Zones (EPA, 2007a).

Although the Port of Los Angeles/Long Beach is located adjacent to Santa
Monica Bay, one of the 28 NEPs, the geographic scope of the monitoring
described in the 2007 Coastal Condition Report does not cover the port.

San Juan, Puerto Rico

EPA’s National TMDL database lists ammonia, fecal coliform, and DO as
the pollutants in exceedance of water quality standards in the waters in
and around the port of San Juan (as of 2004, the most recently-available
year) (EPA, 2007a).

San Juan Bay is one of the NEPs described in the Coastal Condition
Report (EPA, 2007b).  The overall condition of the Bay was rated as
‘poor’, based on the water quality, sediment, benthic, and fish
tissue indices.  Water column DIN and DIP concentrations were rated as
‘fair’, although data for DIP were unavailable for 78% of the
estuarine area.   73% of the estuarine area was rated as ‘good’ for
chlorophyll a levels and water clarity measurements were found to be
‘fair’ overall.  DO concentrations were listed as ‘fair’ for 57%
of the estuary and ‘good’ for 36%.  Sediment toxicity was ‘poor’
(with PCBs, DDT, 2-ethylhexl phthalate, lead, and mercury among the most
abundant sediment contaminants) and sediment TOC levels were rated
‘good’.  Low benthic species diversity has resulted in a ‘poor’
rating for benthic conditions and, with 40% of fish tissue samples
collected in the estuary exceeding EPA’s advisory levels, the fish
tissue contaminants index was rated ‘poor’ (EPA, 2007b).

Savannah, GA

EPA’s National TMDL database lists DO and mercury as the pollutants in
exceedance of water quality standards in the waters in and around the
Port of Savannah (as of 2002, the most recently-available year) (EPA,
2007a). According to the mapping feature of the National TMDL database,
the water body segments that comprise the Port of Savannah include:
Savannah River and Savannah Harbor (EPA, 2007a).

St. Thomas, Virgin Islands

EPA’s National TMDL database lists DO, fecal coliform, oil and grease,
and pH as the pollutants in exceedance of water quality standards in the
waters in and around the Port of St. Thomas, U.S. Virgin Islands (as of
2004, the most recently-available year) (EPA, 2007a).  According to the
mapping feature of the National TMDL database, the water body segments
that comprise the Port of St. Thomas include: Hassel Island at Haulover
Cut to Regis Point and Sprat Bay (EPA, 2007a)

Seattle, WA

EPA’s National TMDL database lists total PAHs, pH, total PCBs, and
fecal coliform as the pollutants in exceedance of water quality
standards in the waters in and around the Port of Seattle (as of 2002,
the most recently-available year) (EPA, 2007a).

In the Coastal Condition Report, the Puget Sound NEP is given an overall
‘fair’ rating.  The water quality index is ‘fair’, with DIN and
DO concentrations rated ‘good’, chlorophyll a and DIP levels rated
‘fair’, and water clarity classified as ‘poor’.  ‘Poor’
sediment toxicity measurements have resulted in a ‘poor’ overall
sediment quality rating, despite a ‘good’ rating for TOC levels.
Benthic health was given a ‘good’ rating and fish tissue
contamination was rated as ‘fair’, with 14% of the fish having
contaminant levels greater than EPA advisory levels (and the most
frequently detected contaminant being PCBs) (EPA, 2007b).

New Orleans, LA

EPA’s National TMDL database lists fecal coliform as the pollutant in
exceedance of water quality standards in the waters in and around the
Port of New Orleans (as of 2002, the most recently-available year) (EPA,
2007a).

Charleston, SC

EPA’s National TMDL database does not list any water quality
exceedances in and around the Port of Charleston (EPA, 2007a).

Baltimore, MD

EPA’s National TMDL database lists PCBs, zinc, and chromium as the
pollutants in exceedance of water quality standards in and around the
Port of Baltimore (as of 2004, the most recently-available year)(EPA,
2007a).  In addition, Middle Chesapeake Bay (through which vessels must
pass en route to the Port of Baltimore) has water quality exceedances
for nutrients. According to the mapping feature of the National TMDL
database, the water body segments that comprise the Port of Baltimore
include: Curtis Bay, Bear Creek, Southern Branch Elizabeth River,
Eastern Branch Elizabeth River, and Indian River (EPA, 2007a)

Elizabeth River, VA

EPA’s National TMDL database lists phosphorus, fecal coliforms, PCBs,
and benthic (unknown) as the pollutants in exceedance of water quality
standards in the waters in and around the Port of Elizabeth River (as of
2004, the most recently-available year) (EPA, 2007a). According to the
mapping feature of the National TMDL database, the water body segments
that comprise the Port of Elizabeth River include: Western Branch
Elizabeth River, Southern Branch Elizabeth River, Eastern Branch
Elizabeth River, and Indian River (EPA, 2007a)

Dedicated to restoring the health of the river, the Elizabeth River
Project has been studying its condition for several years, focusing on
the benthic communities and toxic characteristics.  Several of their
reports have been posted on their website.  The most recent benthic
monitoring report (2005) indicates that, in general, benthic species
diversity and biomass in the Elizabeth River watershed are below
reference condition levels while abundance was often above reference
condition levels and considered excessive.

The reports characterizes the water quality of the Elizabeth River as
follows: (1) nutrients have a poor status indicating high concentration
levels, (2) there were improvements in long-term trends in total
nitrogen levels and inorganic nitrogen levels, and (3) there were
widespread improvements in long-term trends in total phosphorus levels.
Nitrogen levels are highest in the Southern Branch with smaller
differences between the branches of the river for phosphorus levels.
Chlorophyll levels are good in both the Eastern Branch and Southern
Branch in spite of high nutrient levels and good water clarity.
Chlorophyll levels are fair in the Western Branch with an improving
long-term trend. Bottom dissolved oxygen levels are fair to good in all
branches (Dauer, 2006).

Oakland, CA

EPA’s National TMDL database lists chlordane, DDT, diazinon, dieldrin,
dioxins, exotic species, mercury, PCBs, and selenium as the pollutants
in exceedance of water quality standards in the waters in and around the
Port of Oakland (as of 2002, the most recently-available year) (EPA,
2007a).

The Port of Oakland is located within the San Francisco Bay NEP and,
therefore, is included in the 2007 Coastal Condition report (EPA,
2007b).  The overall condition of the NEP is rated as ‘fair’, with
water quality in general classified as ‘fair’ to ‘poor’, with
approximately 73% of the estuary rated ‘fair’ and 20% rated
‘poor’.  Chlorophyll a and DO concentrations were ‘good’ in 90%
and 99% of the estuary, respectively.  DIN levels were ‘fair’, while
both DIP and water clarity were rated ‘poor’.  The sediment in the
estuary is in very good condition, with 100% of the estuary rated
‘good’ for sediment toxicity and 96% rated ‘good’ for TOC
levels.  Benthic invertebrate communities are in ‘good’ condition,
while fish tissue contaminants are rated ‘poor’, with 58% of fish
caught exceeding EPA’s guidance values.

Bayou Lafourche, LA

EPA’s National TMDL database lists DO, nutrients, total coliform, and
fecal coliform as the pollutants in exceedance of water quality
standards in the waters in and around Bayou LaFourche (as of 2004, the
most recently-available year) (EPA, 2007a).

Currently, the state of Louisiana and the Louisiana Department of
Natural Resources is studying a potential reintroduction of Mississippi
River water into Bayou Lafourche.  A water quality monitoring report was
developed in February 2006 in which data collected in support of a
hydrodynamic model were published.  Data were collected via 18 permanent
platforms installed along the bayou which were in data collection mode
from February 2004 until January 2005.  Parameters that were collected
included temperature, specific conductance, water surface elevation
(depth), salinity, and stream velocity, direction, and speed. Data from
this project are available online.

Galveston, TX

EPA’s National TMDL database lists bacteria as the pollutant in
exceedance of water quality standards in the waters in and around the
Port of Galveston (as of 2004, the most recently-available year) (EPA,
2007a).

The general condition of the waters surrounding the port of Galveston is
described in the Section 4.2.1 discussion of Houston.  However, the
Galveston NEP published a State of the Bay report in 2002 that described
the water quality data and trends in the estuary.  Generally speaking,
concentrations of ammonia-nitrogen and total phosphorus have been
occurring over the past three decades. Nitrate-nitrite data for the
1990s did not exhibit an upward or downward trend, but did indicate
seasonal peaks in concentrations.  Chlorophyll a levels have been
declining over the past two decades and have reached 25% of their 1975
values.  Dissolved metals have declined in the Houston Ship Channel over
the last ten years, although organic contamination in the Channel from
spillage of petroleum products is substantial (Galveston Bay Estuary
Program, 2002).

Tacoma, WA

EPA’s National TMDL database lists total PCBs, bis(2-ethylhexyl)
phthalate, DDT, PAHs, and pesticides as the pollutants in exceedance of
water quality standards in the waters in and around the Port of Tacoma
(as of 2002, the most recently-available year) (EPA, 2007a).

The Port of Tacoma is located on Puget Sound.  Refer to the Section
4.2.9 discussion on Seattle for more information on the overall
ecosystem health of the waters surrounding this port, according to
EPA’s 2007 Coastal Condition Report.

Jacksonville, FL

EPA’s National TMDL database lists coliforms, nutrients, total
suspended solids, and turbidity as the pollutants in exceedance of water
quality standards in the waters in and around the Port of Jacksonville
(as of 2002, the most recently-available year) (EPA, 2007a).

South Louisiana, LA

The Port of South Louisiana is comprised of facilities along 54 miles of
the Mississippi River in St. James, St. Charles, and St. John parishes.
EPA’s National TMDL database lists fecal coliform as the pollutant in
exceedance of water quality standards in the waters in and around the
Port of South Louisiana (as of 2002, the most recently-available year)
(EPA, 2007a).

DISCHARGE FINDINGS

Discharges Incidental to the Normal Operation of a Vessel

As described in Section 2.5, the vast majority of information on
discharges originating from vessels came from the UNDS reports on
discharges from Armed Forces vessels.  One of the products from Phase I
was a list of the 25 Armed Forces vessel discharges that should require
a MPCD.  EPA and DoD also identified 14 additional discharges that they
determined would not require an MPCD when discharged from an Armed
Forces vessel, based on the nature of the discharge, the environmental
effects, and the economic costs and practicability of a MPCD for an
Armed Forces vessel.  In the following sections, Battelle has included
information on the group of 25 Phase I discharges that should require an
MPCD, except for one: Catapult Water Brake Tank and Post-Launch
Retraction Exhaust.  A catapult is the mechanism used to help launch
aircraft from a carrier and aircraft carriers are exclusively used by
the military.  The 24 UNDS Phase I discharges that should require an
MPCD are listed in Table 5-1, along with a brief description.

On June 21, 2007, the EPA published an Advanced Notice of Proposed
Rulemaking (ANPRM) in the Federal Register (Vol. 72, No. 119, p. 34241)
providing background information on the pending NPDES permitting
program.  The ANPRM requested that commentors provide information or
data sources that might help the EPA better comprehend the universe of
vessels and discharges that will be affected by the new permitting
scheme.  Six commentors provided specific lists and/or descriptions of
discharges that were relevant to certain types of vessels:

Liberty Maritime Corporation (LMC): a civilian company that transports
military and food aid cargo for the U.S. government

Crowley Maritime Corporation (CMC): operates a fleet of vessels,
including roll on-roll off, lift on-lift off, tankers, tugs, and barges.

World Shipping Council (WSC): a trade association that represents all
types of ocean carriers.

Cruise Lines International Association (CLIA): represents the interests
of 24 cruise line companies.

Pacific Seafood Processors Association (PSPA): represents floating
seafood processing vessels.

American Waterways Operators (AWO): a national trade association for the
inland and coastal tugboat, towboat, and barge industry.

Several of these commentors stated that some UNDS vessel discharges that
had not been included in the first draft of this report (i.e., that did
not require an MPCD when discharged from an Armed Forces vessel) were
relevant to specific types of civilian vessels. In light of this new
information, these additional discharges are listed in Table 5-2 and
more detailed descriptions are included in the sections below.

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  1 .  Phase I UNDS
Armed Forces Vessel Discharges Requiring an MPCD.

Armed Forces Vessel Discharge	Description

Aqueous Film-Forming Foam	Fire-fighting agent used for flammable liquid
fires on vessels.  A concentrated liquid mixed with ambient water to
form a solution which is discharged during planned maintenance and
inspections.

Chain Locker Effluent	Ambient water and debris that collects in the
anchor chain storage locker as a result of anchor chain washdowns,
retrievals, and heavy weather. The liquid collects in a sump and is
removed by a drainage eductor powered by the shipboard firemain.

Clean Ballast	Ambient water that is transferred into and out of
dedicated tanks to adjust a surface ship’s draft and to improve
stability under various operating conditions. The discharge is generated
when the ballast is no longer required and the tanks are partially or
completely emptied.

Compensated Fuel Ballast	Ambient water that is introduced into fuel
tanks to maintain the stability of a vessel by compensating for the
weight of the expended fuel that is consumed. During refueling, this
ambient water is displaced overboard.

Controllable Pitch Propeller Hydraulic Fluid	Hydraulic oil that is
released from controllable pitch propeller (CPP) systems under three
conditions: leakage through CPP seals, releases during underwater CPP
repair and maintenance, or releases from equipment used for CPP blade
replacement.

Deck Runoff	Water runoff from precipitation, freshwater washdowns, and
ambient water that falls on the exposed decks of a vessel such as a
weather deck or flight deck. This water washes off residues from the
deck and topside equipment, can be contaminated with materials from
other deck activities, and is discharged overboard to receiving waters.

Dirty Ballast	Ambient water that is occasionally pumped into empty fuel
tanks for the specific purpose of improving ship stability. Before
taking on ambient water, fuel in the tank to be ballasted is transferred
to another fuel tank or holding tank. Dirty ballast is comprised of
residual

fuel mixed with ambient water. The discharge is generated when the
ballast is no longer required and the tanks are partially or completely
emptied.

Distillation and Reverse Osmosis Brine	Seawater concentrate or
“brine” that is left over by water purification systems that
generate freshwater from seawater for a variety of shipboard
applications including potable water for drinking. This “brine” is
discharged overboard.

Elevator Pit Effluent	Liquid from deck runoff and elevator equipment
maintenance activities that collects in the bottom of elevator shafts.
The liquid waste is either directed overboard, collected for shore-side
disposal, or processed along with bilge water.

Firemain Systems	Ambient water distributed for fire fighting and other
services aboard ships. Discharges of firemain water from normal
operations occur during firemain testing, maintenance and training
activities, anchor chain washdown, and cooling of auxiliary machinery.

Gas Turbine Water Wash	Wash water discharge from cleaning internal and
external propulsion and auxiliary gas turbine components.

Grey Water	Wastewater from showers, galleys, laundries, deck drains,
lavatories, interior deck drains, water fountains, miscellaneous shop
sinks, and similar sources.

Hull Coating Leachate	Antifouling agents that leach into surrounding
waters from hull coatings designed to prevent corrosion and to inhibit
biological growth on the hull surface.

Motor Gasoline Compensating Discharge	Ambient water used to compensate
for expended motor gasoline (MOGAS) used to operate equipment stored on
some vessels. MOGAS is stored in a compensating tank system to which
ambient water is added to fuel tanks as fuel is consumed. The discharge
occurs as a result of refueling when the displaced water is discharged
overboard.

Table 5–1.  Phase I UNDS Armed Forces Vessel Discharges Requiring an
MPCD, continued.

Armed Forces Vessel Discharge	Description

Non-Oily Machinery Wastewater	Generated from the operation of distilling
plants, water chillers, low- and high-pressure air compressors, and
propulsion engine jacket coolers. The discharge is captured in a
dedicated system of drip pans, funnels, and deck drains to segregate the
water from bilge water, and is either drained directly overboard or into
dedicated collection tanks before being discharged overboard.

Photographic Laboratory Drains	Shipboard photographic lab wastes from
processing color and black-and-white film. Typical wastes include spent
film processing chemical developers, fixer-bath solutions, and film
rinse water

Seawater Cooling Overboard Discharge	Seawater used to cool heat
exchangers, propulsion plants, and mechanical auxiliary systems.

Seawater Piping Biofouling Prevention	Anti-fouling compounds such as
sodium hypochlorite introduced in seawater cooling systems to inhibit
the growth of fouling organisms on interior piping and component
surfaces.

Small Boat Engine Wet Exhaust	Ambient water injected into the exhaust of
small boat engines for cooling and to quiet operation. Exhaust gas
constituents are entrained in the injected ambient water and discharged
overboard as wet exhaust.

Sonar Dome Discharge	Some domes that house detection, navigation, and
ranging equipment are filled with ambient water to maintain their shape
and pressure. The discharge occurs when water from inside the dome is
pumped overboard before performing maintenance or repair on the dome and
when materials leach from the dome exterior.

Submarine Bilge water	Sources of bilge water include seawater
accumulation, normal leakage from machinery, and fresh water washdowns
that collect in the bilge. On some submarines, oily wastewater is
separated from non-oily wastewater. The oily wastewater is held for
shore-side disposal and the non-oily wastewater is discharged overboard.

Surface Vessel Bilge water/Oil-Water Separator Discharge	Sources include
condensate from steam systems, boiler blowdowns, water fountains, and
machinery space sinks that drain to the bilge. Bilge water is either
held for shore-side disposal or treated in an oil-water separator before
being discharged overboard.

Underwater Ship Husbandry	Discharge from the grooming, maintenance, and
repair of hulls and hull appendages performed while a vessel is
waterborne. Underwater ship husbandry includes hull cleaning, fiberglass
repair, welding, sonar dome repair, non-destructive testing, masker belt
repairs, and painting operations.

Welldeck Discharges	Water and residuals from precipitation, equipment
and vehicle washdowns, washing gas turbine engines, grey water from
stored landing craft, and general washdowns of welldecks and vehicle
storage areas.

Source: EPA, 1999a.

Table   STYLEREF 1 \s  5 -2.  Phase I UNDS Armed Forces Vessel
Discharges Not Requiring an MPCD.

Armed Forces Vessel Discharge	Description

Boiler Blowdown	Water removed from the boiler system to prevent
particulates, sludge, and treatment chemical concentrations from
accumulating.

Cathodic Protection	Zinc, aluminum, and chlorine-produced oxidants
released during the consumption of sacrificial anodes and the operation
of impressed current cathodic protection systems. The purpose of
cathodic protection is to prevent hull corrosion.

Freshwater Lay-up	Freshwater used to fill condensers when submarine
seawater cooling systems are placed in stand-by mode, or “lay-up.”
While the condenser is in lay-up mode, the water is discharged and
refilled approximately every 30 days.

Table 5–2.  Phase I UNDS Armed Forces Vessel Discharges Not Requiring
an MPCD, continued.

Armed Forces Vessel Discharge	Description

Refrigeration /Air Conditioning

Condensate	Condensate from air conditioning, refrigerated spaces, and
stand-alone refrigeration units. The condensate is collected in drains
and is either discharged directly overboard or held in dedicated tanks
before discharge.

Rudder Bearing Lubrication	Grease and oil used to lubricate rudder
bearings. The grease and oil can be released while the vessel is moving,
when the rudder is used, or when pierside because the oil lubricant is
slightly pressurized.

Steam Condensate	Condensate from steam used to operate auxiliary
systems, such as laundry facilities, heating systems, and other
shipboard systems, that drains into collection tanks and is discharged
overboard.

Stern Tube Seals and Underwater Bearing Lubrication	Lubricants used in
propeller support struts and bearings that can be released to the
environment.

Source: EPA, 1999a

Some of these discharges listed in Tables 5-1 and 5-2 are more likely
than others to be found on civilian commercial and recreational vessels.
 Given the range of sizes and types of vessels that will potentially be
affected by the pending vessel vacatur, the entire scope of discharges
incidental to the normal operation of a vessel that could potentially be
discharged by a vessel to U.S. navigable waters were included here.

As stated in Section 2.5.1, some of the UNDS-identified discharges had
detailed reports available that included extensive information on the
discharge characteristics, while others had only summary reports with
less detailed information.  Each of the discharges is described briefly
below.  A caveat to this information that bears repeating is that the
discharge information provided by EPA and DoD relates to Armed Forces
vessels.  If data on discharge rates or concentrations were available
and are included in this section, they apply specifically to the type(s)
of Armed Forces vessel(s) discussed in the UNDS reports.

In a similar vein, Battelle’s ability to associate discharges to
particular civilian vessel types was limited, given the specific
applicability of the UNDS reports to Armed Forces vessels.  Some
discharges can be easily connected to certain types of vessels while
other discharges may or may not apply to any number of vessels.  Deck
runoff, for instance, will be a factor for virtually all commercial and
recreational vessels, whereas elevator pit effluent will not be a
discharge for vessels without elevators (i.e., smaller recreational
vessels).  With these caveats in place, the following sections describe
each of the discharges.

Aqueous Film Forming Foam (AFFF)

The information on aqueous film forming foam (AFFF) was obtained from
EPA (1999b) and five comments on EPA’s ANPRM.

Discharge Summary

AFFF is a synthetic firefighting agent used aboard USCG and Navy vessels
and possibly civilian vessels.  Consisting of fluorosurfactants and/or
fluoroproteins, AFFF can extinguish as well as prevent fires by forming
an oxygen-excluding barrier over the area.  AFFF concentrate is mixed
with ambient water to form a 6% dilution and is never discharged from a
vessel in its undiluted form.  The discharge of AFFF, as discussed in
this section, refers to the direct overboard discharging of the AFFF
system.  Some maintenance, inspection, and training activities may
result in AFFF accumulating on the vessel deck; in these cases, the AFFF
becomes a part of other discharges, such as deck runoff, chain locker
effluent, elevator pit effluent, or bilge water.

AWO, CMC, WSC, and the CLIA all cited AFFF as a potential discharge from
some of their vessels.  AWO specifically stated that some of their
towing vessels are equipped with AFFF systems, especially those
transporting flammable liquid cargo.  They also stated that maintenance,
testing, and training activities lead to AFFF being either discharged
directly overboard or discharged onto the deck and then subsequently
washed overboard.  CMC stated that commercial vessels are required by
international and U.S. law to test AFFF systems periodically, although
no specific law was cited.  They also stated that AFFF is discharged
from all commercial vessel types, including unmanned barges.  A comment
by LMC stated that they do not conduct firefighting training using foam
in U.S. waters.

When and Where Discharge Occurs

Discharge of AFFF can occur during planned maintenance and inspection
activities that, on Armed Forces vessels, take place on an annual or
semi-annual basis.  On Armed Forces vessels, these maintenance and
inspection activities occur by discharging the AFFF hose over the
vessel’s side.  Following these maintenance and inspection activities,
any AFFF on the vessel deck is washed down with the firemain and becomes
a part of other vessel discharges.  Maintenance discharges can only
occur when the Armed Forces vessel is outside territorial waters (i.e.,
12 nautical miles [nmi]).  Discharges due to inspections and
certifications can occur anywhere, unless the AFFF has been washed into
the vessel’s bilge tank, which cannot be discharged within 12 nm.
Civilian vessels may have different self-imposed restrictions for direct
AFFF discharge.

Unless equipped with a fixed extinguishing system that must be tested,
recreational vessels will not have this discharge.  When used to fight
fires on either commercial or recreational vessels, fire-fighting foam
is not considered a discharge incidental to the normal operation of a
vessel.

In their comments to the EPA’s ANPRM, CLIA stated that AFFF discharge
occurs whenever testing and maintenance activities are scheduled, which
happen as often as needed to maintain fire fighting systems, and to
ensure crew proficiency and vessel safety.  However, they also state
that these discharges typically occur outside of 12 nmi from land.

Discharge Rates, Concentrations, and Constituents

Along with the ingredients in the AFFF itself, the discharge will
contain the constituents of the firemain water and the AFFF piping.  The
specific ingredients of the AFFF concentrate will vary by manufacturer.
EPA (1999b) lists constituents, although they are specific to the brand
of concentrate used by the Armed Forces and are not necessarily relevant
to civilian vessels.  These constituents include: water (which makes up
80% of the ingredients by weight), 2-(2-butoxyethoxy)-ethanol, urea,
alkyl sulfate salts (2 in number), amphoteric fluoroalkylamide
derivative, perfluoroalkyl sulfonate salts (5), triethanolamine, and
methyl-1H-benzotriazole.  As discussed in Section 5.1.10, constituents
of the firemain water in Armed Forces vessels may include residue from
the copper-nickel alloy pipes.  AFFF piping in Armed Forces vessels is
also constructed of copper-nickel alloy; therefore, perfluoroalkyl
sulfonate salts, total nitrogen, bis(2-ethylhexyl) phthalate, copper,
nickel, sulfides, and iron may be discharge constituents.  The results
of sampling by EPA and DoD indicated that each of these pollutants
exceeded the most stringent state water quality standards in the U.S.
Ambient water from the firemain system has little potential for
harboring invasive species.

Boiler Blowdown

The information on boiler blowdown was obtained from EPA (1999c) and
from four comments on EPA’s ANPRM

Discharge Summary

For steam-powered vessels, onboard boiler systems must be supplied with
feedwater to maintain the water level.  On some Armed Forces vessels, a
treatment is added to the feedwater to prevent corrosion and minimize
scale formation in the boiler system.   As the feedwater is boiled to
produce steam, the concentration of particulates and chemicals (from the
added treatment) increases in the feedwater remaining to be boiled.
Boiler systems must periodically undergo a ‘blowdown’ to control the
treatment concentrations and to remove accumulated sludge.  A blowdown
involves releasing the water from the boiler and from the ship
altogether, into the ambient water through hull fittings below the
waterline.  Different types of blowdowns release different percentages
of boiler water, but, typically, blowdowns remove between 1% and 10% of
the total volume of water in the boiler.  The UNDS report indicates that
the volume of this discharge from Armed Forces vessels is rarely greater
than 310 gallons and that the discharge is ejected from the vessel at
high pressures (up to 1200 psi) and high temperatures (above 325°F).
Boiler blowdown discharge can originate from any vessel with steam
propulsion or a steam generator.

Comments submitted in response to the ANPRM indicated that boiler
blowdown is a discharge associated with some types of civilian vessels.
LMC, a civilian company that transports military and food aid cargo for
the U.S. government, cited boiler blowdown as one of the discharges
incidental to the operation of its vessels.  CMC operates a fleet of
vessels, including roll on-roll off, lift on-lift off, tankers, tugs,
and barges.  Their comment indicated that boiler blowdown was a relevant
discharge for their fleet, although they did not specify which types of
vessels.  The WSC is a trade association that represents all types of
ocean carriers and boiler blowdown was included in a non-annotated list
of discharges relevant to their industry.  Finally, the CLIA, which
represents the interests of 24 cruise line companies, cited
“boiler/economizer washdown waste” as a discharge relevant to cruise
ships.  A definition provided with their comment indicates that this
discharge is equivalent to boiler blowdown.

When and Where Discharge Occurs

The UNDS report states that the frequency of boiler blowdown is
dependent on the needs of the particular boiler system.  Therefore, this
discharge can occur whenever and wherever necessary to maintain the
boiler system. In their comment, CLIA stated that, on cruise ships,
boiler blowdowns occur as needed to maintain performance, which is
typically on a weekly or monthly basis.  However, they indicated that
this discharge is nearly always done while underway and as far from land
as practicable.

Discharge Rates, Concentrations, and Constituents

The constituents of boiler blowdown discharge will be dependent on the
type(s) of anti-scaling and anti-corrosion treatment originally added to
the feedwater.  Numerous constituents found in boiler blowdown
discharges from Armed Forces vessels were defined as priority pollutants
by the EPA: antimony, arsenic, cadmium, copper, chromium, lead, nickel,
selenium, thallium, zinc, and bis(2-ethylhexyl) phthalate.  Other
detected constituents are listed in Table 3 of the UNDS report (EPA,
1999c).

Thermal modeling using Armed Forces vessel specifications and described
in the UNDS report showed that the high temperatures of the boiler
blowdown discharge did not exceed the thermal mixing zone criteria of
Virginia and Washington State, the only two U.S. states with such
standards.

Cathodic Protection

The information on cathodic protection was obtained from EPA (1999d) and
from three comments on EPA’s ANPRM.

Discharge Summary

According to the UNDS report on this discharge, nearly all Armed Forces
vessels use cathodic protection systems (usually in conjunction with
corrosion-resistant coatings) to prevent steel hull or metal underwater
structure corrosion.  Vessels with hulls made of fiberglass, wood,
aluminum, or other non-ferrous material do not require cathodic
protection systems.  Two types of cathodic protection are most common on
Armed Forces vessels: sacrificial anodes and Impressed Current Cathodic
Protection (ICCP)-based systems.  Sacrificial anodes are physically
connected to an underwater vessel structure or component (which acts as
the cathode).  The anode is preferentially corroded (or
‘sacrificed’) which, via the electrolytic properties of seawater,
produces a flow of electrons to the cathode, thereby preventing the
cathode from corroding.  Sacrificial anodes are used on most Armed
Forces vessels, particularly those with mandatory dry-dock inspection or
overhaul intervals of less than three years.  When immersed, the anodes
continue to corrode and have to be maintained and routinely replaced;
zinc anodes need to be replaced at least every six years.  Anodes can
also be constructed of aluminum.  The ICCP-based mechanism of protection
is identical to sacrificial anodes, except ICCP systems use direct
current (DC) from a source within the vessel in lieu of current supplied
from anodes.

According to comments submitted in response to EPA’s ANPRM, cathodic
protection system discharge can originate from civilian vessels.  CLIA,
the WSC, and CMC all cited cathode protection discharge as relevant to
the types of vessels they represent in their ANPRM comments.

When and Where Discharge Occurs

For vessels equipped with sacrificial anodes, the discharge occurs
continuously whenever the vessel’s hull is submerged.  The comment
submitted by CLIA also stated that this discharge occurs continuously

Discharge Rates, Concentrations, and Constituents

Ionized zinc or aluminum can be released into the surrounding water
column as sacrificial anodes are consumed by corrosion.  At the cathode,
the water is reduced, forming hydroxyl ions which can form zinc or
aluminum hydroxide if enough oxygen is present in the water.  ICCP
systems can generate chlorine-produced oxidants (CPOs), but the specific
types will vary according to the specific chemistry or the surrounding
water.  These oxidants can include hypochlorous and hypobromous acids,
hypochlorite and hypobromite, chloro- and bromo-organics, chloride,
bromide, chloramines, and bromamines.  Utilizing a tidal prism modeling
approach, the receiving water concentrations of zinc and CPOs were
estimated and none of the concentrations were found to exceed the most
stringent state water quality standards.

Chain Locker Effluent

The information on chain locker effluent was obtained from EPA (1999e)
and from four comments on EPA’s ANPRM.

Discharge Summary

Armed Forces vessels, along with other civilian vessels, store their
anchor chain(s) in a below deck compartment (chain locker) when not in
use.  In the locker, the chain rests on a grate below which is a sump
that collects liquids and materials that enter the chain locker via rain
and green water.  Most large surface vessels have at least one chain
locker (EPA, 2003a).  Chain locker effluent is generated during anchor
retrieval (which, according to CLIA’s comment, occurs weekly) or
during storm events, when water may wash over the deck of a vessel.  The
sump in the chain locker is emptied either directly overboard (with
assistance from firemain water) or is drained into the bilge tank for
later disposal.

LMC, CMC, WSC, and CLIA all cited chain locker effluent as a discharge
relevant to their types of vessels.  CLIA further states that this is a
discharge on all the vessels they represent.

When and Where Discharge Occurs

Navy vessels do not directly discharge chain locker effluent within 12
nmi of shore.  Civilian vessels may have different self-imposed
restrictions for direct chain locker effluent discharge.

Discharge Rates, Concentrations, and Constituents

Chain locker effluent has the potential to contain marine organisms,
which may have been introduced into the sump from the anchor and chain,
through the firemain system, or via green water.  However, the Navy
practice of washing down the anchor and chain as they are retrieved and
the 12 nmi discharge limit makes the introduction of invasive species
from chain locker effluent unlikely.  Similar practices by civilian
vessels will help prevent species introduction.  Other constituents can
include residue from materials used in the chain locker, such as rust,
paint chips, grease, and zinc, as well as residue from copper-nickel
alloy firemain pipes.  The actual materials used in the construction of
the chain locker or firemain pipes will vary for civilian vessels.

Discharge concentrations and annual mass loadings for chain locker
effluent were not calculated for the UNDS report due to the expected
minimal amount of discharge and the 12 nmi discharge limit followed by
Armed Forces vessels.

Clean Ballast

The information on clean ballast was obtained from EPA (1999f) and from
six comments on EPA’s ANPRM.

Discharge Summary

Clean ballast is water that is taken onboard to assist with vessel
draft, buoyancy, and stability and stored in dedicated ballast tanks
that have never contained anything but ballast water (as opposed to
Compensated Fuel Ballast and Dirty Ballast).  Clean ballast tanks
(sometimes called segregated ballast tanks [SBT]) can be filled from the
firemain or by ballast pumps that take in ambient water.  Large
commercial vessels (e.g., cargo, tankers, ro-ro, passenger) typically
have ballast tanks, although they may not have clean ballast tanks.
Under recent amendments to MARPOL 73/78 (Regulation 13G), all tankers
must now have SBT configurations or be double-hulled.  SBT arrangements
are associated with smaller volume oil spills because the oil is carried
in multiple tanks.  According to the National Academy of Sciences (NAS)
(2003), approximately two-thirds of the worldwide tanker fleet (crude
and product) uses SBT, although this number has likely increased since
that source’s publication.

Recreational boats typically do not have ballast water tanks. However,
boats used for wakeboarding are now being marketed with ballast tanks
(e.g., Centurion Boats, Correct Craft) or existing boats can be
retrofitted with expandable, portable ballast tanks (e.g., BoardStop).
Normally, these tanks are filled and emptied with the same source water.

Comments submitted in response to EPA’s ANPRM indicate that clean
ballast discharge is relevant to several different types of vessels.
LMC, WSC, and CMC all specifically cited clean ballast as their
discharge.  In their comment, American Waterway Operators stated that
their towing vessels are ballasted for stability and trim and that a
large number of their towing vessels are only ballasted with water from
municipal or commercial sources, except in emergencies.  They also
stated that tank barges are purposely ballasted for a variety of
reasons, including to maintain proper trim during loading and unloading
operations, to improve tow configurations, and to permit passage
underneath obstructions such as bridges.  However, tank barges taking up
ballast while at sea for trim purposes is very rare and, when this must
occur, the ballast taken onboard is kept to a minimum.  Because the crew
of a tank barge must transit from the tugboat to the barge to perform
ballasting or deballasting operations, operators will retain ballast
onboard whenever feasible.  If there is an emergency, the operator will
only release enough ballast to continue with safe operations.

PSPA cited ballast water as a relevant discharge for the vessels they
represent, but it was not specified that clean ballast tanks were used.

When and Where Discharge Occurs

Armed Forces vessels cannot discharge ballast water within 12 nmi of
shore and must perform at least two exchanges prior to entering the 12
nmi zone.

AWO commented that ballasting and deballasting operations on their
towing vessels are conducted during major shipyard maintenance and to
replace spent fuel (which is stored in separate tanks) to retain vessel
stability.  They also stated that coastal tugboats discharge their
ballast water outside the demarcation line whenever possible or retained
it onboard for disposal at a shore-side facility.  For their tank
vessels, AWO stated that ballast is frequently taken on and discharged
in the same location.

CLIA also cited ballast water as a relevant discharge for the vessels
they represent, although they do not specify whether the ballast tanks
are ‘clean’.  They stated that ballast water is discharged as needed
to ensure the safety of the ship, which, typically, is several times per
week.

Discharge Rates, Concentrations, and Constituents

Ballast water discharged from clean ballast tanks may contain marine
organisms as well as material from inside the tank, piping, or other
machinery.  Ballast tanks filled via the firemain may contain residue
from the firemain pipes.  The actual materials and contents used in
civilian ballast tanks will vary.  Some possible constituents may
include rust inhibitors, flocculant compounds, epoxy coating materials,
zinc or aluminum (from anodes), iron, nickel, copper, bronze, and
silver.  Accumulated sediments from the bottom of the tank may also be
discharged.

The discharge rate and constituent concentrations of clean ballast water
from civilian vessels will vary by vessel type, ballast tank capacity,
and type of deballasting equipment.  According to a study published by
the Bluewater Network (Maddison, 2006), typical cruise ships have a
ballast capacity of approximately 1,000 metric tons and have a ballast
discharge rate of between 250-300 metric tons per hour.  The Prince
William Sound Regional Citizens’ Advisory Council estimates that oil
tankers can carry between

Compensated Fuel Ballast

The information on compensated fuel ballast was obtained from EPA
(1999g).

Discharge Summary

Some vessels have a series of connected ballast tanks that store fuel
and, as the fuel is consumed, water is introduced to the same tanks via
the firemain to ‘compensate’ for the lost weight of the spent fuel.
The water fills in the spaces vacated by the fuel.  Then, as the vessel
is refueled, the fuel, being denser, ‘pushes’ the ambient water back
through the tanks.  At the end is an overflow/ expansion tank with an
overboard discharge pipe; this expansion tank always contains ambient
water and prevents fuel from being accidentally discharged into open
waters if the fuel tanks are overfilled.  Compensated fuel ballast tanks
are only completely emptied during maintenance activities.

It is notable that none of the commentors that listed the relevant
discharges for their vessel types cited compensated fuel ballast.

When and Where Discharge Occurs

Discharge of compensated fuel ballast water may occur through the
overflow/expansion tank during refueling, which can occur while the
vessel is at port or at sea.  For Armed Forces vessels, at sea refueling
occurs only outside the 12 nmi limit.  Civilian vessels may have
different refueling policies.

Discharge Rates, Concentrations, and Constituents

Studies on Armed Forces vessels have detected oil in compensated fuel
ballast discharge in concentrations ranging from below detection level
to 370 milligrams per liter (mg/L).  Other research has tested
discharges for a suite of parameters and discovered copper, nickel,
silver, thallium, zinc, benzene, phenol, and toluene were present in
measurable amounts.  Mercury, total petroleum hydrocarbons (TPH), and
hexane extractable material (HEM) (which corresponds to the amount of
oil and grease present) were also detected.  Research conducted by EPA
and DoD determined that several constituents detected in compensated
fuel ballast exceeded the most stringent state water quality standards:
ammonia, nitrate/nitrite, HEM, total phosphorus, mercury, copper,
nickel, silver, thallium, zinc, 2-propenal, and benzene.  According to
EPA (1999g), invasive species are not likely to be introduced during
refueling operations.

For Armed Forces vessels, compensated fuel ballast is discharged at a
rate of up to 400 gallons per minute (gpm) per ballast tank group
(maximum of 2,400 gpm per vessel) during at port refueling operations,
which take place approximately twice a year.  Civilian vessels with
compensated ballast tanks will have a variety of discharge rates,
dependant on vessel size and type.

Controllable Pitch Propeller Hydraulic Fluid

The information on controllable pitch propeller hydraulic fluid was
obtained from EPA (1999h) and two comments on EPA’s ANPRM.

Discharge Summary

Controllable pitch propellers (CPPs) are variably-pitched propeller
blades that can change the speed or direction of a vessel without
requiring the vessel’s main propulsion system to change speed or
direction.  Hydraulic control oil is provided to each CPP hub, which is
surrounded by seals meant to keep the oil from coming into contact with
the surrounding water.  Many civilian ocean-going vessels may use CPP
technology.

Two commenter’s on EPA’s ANPRM cited controllable pitch propeller
hydraulic fluid as a relevant discharge for the vessels they represent.

When and Where Discharge Occurs

Hydraulic oil can leak past the CPP’s protective seals (if they are
worn or defective).  These leaks can occur at any time, while the vessel
is at port or underway in open water, although they are more likely
while the vessel is underway since the seals are under higher pressure.
Regular maintenance activities on the CPP system, which can occur
portside, can also cause oil discharge.

In their comment, CMC stated that controllable pitch propeller
maintenance activities on the vessels they represent is typically done
while the vessel is in dry-dock.  When dry-docking is not an option,
then maintenance will occur pierside.

Discharge Rates, Concentrations, and Constituents

Constituents of the hydraulic oil will vary by manufacturer.  Other
potential discharge constituents include copper, tin, aluminum, nickel,
and lead from the piping, hub, and propeller.

Oil leaks from around defective or worn seals are believed to be
negligible.  During maintenance activities, small amounts of oil may be
discharged.  EPA (1999h) estimates that approximately 20 ounces of oil
may be released for every CPP blade that is replaced (the Armed Forces
estimates there are about 30 blade replacements annually).  When the
blade replacement includes removal of the blade port cover (during about
seven of the 30 instances), a worst case scenario of five gallons of oil
may be discharged.

Deck Runoff

The information on deck runoff was obtained from EPA (1999i) and six
comments on EPA’s ANPRM.

Discharge Summary

The majority of vessel deck runoff is attributable to precipitation,