Phase II of the Regulatory Development
Process
 Phase II of
UNDS development focuses on promulgating MPCD performance standards
for those vessel discharges identified during Phase I as requiring
an MPCD.
In developing the standards, the UNDS legislation
requires the DoD and EPA to consider the following factors:
- Nature of Discharge;
- Environmental effects of the discharge;
- Practicability of using a MPCD;
- Operational impact of using an MPCD on a vessel;
- Applicable United States Law;
- Applicable international standards; and
- Costs of MPCD installation and use.
In Phase II, DoD and EPA are establishing discharge
performance standards for different classes, types, and sizes of
vessels. These standards are specific to existing vessels as well as
future (new design) vessels.
The Navy and EPA have agreed to promulgate Phase II
standards in batches. The batch rulemaking approach allows the Navy
and EPA to conduct technical analyses and develop discharge
standards in batches (approximately five discharges per batch)
rather than conducting analyses and developing standards for all 25
discharges at one time.
By expediting the rulemaking, via batch rulemaking,
the Navy and EPA will be able to solicit State, Tribal, and public
interest early, and accelerate the implementation of performance
standards, thus more quickly realizing the goals of UNDS.
The first group, Batch One, includes seven
discharges:
- Surface Vessel Bilgewater/Oil-Water Separator
- Underwater Ship Husbandry
- Hull Coating Leachate
- Weather Deck Runoff
- Chain Locker Effluent
- Elevator Pit Effluent
- Photographic Laboratory Drains
Four of the Batch One discharges—weather deck
runoff, hull coating leachate, surface vessel bilgewater/oil-water
separator discharge, and underwater ship husbandry—require complex
technical analyses to support standard development. The remaining
three discharges—chain locker effluent, elevator pit effluent, and
photographic laboratory drains—require relatively less complex
technical analysis.
The Navy and EPA completed the necessary
technical analyses for the Batch One discharges and have begun developing performance standards for those discharges. Technical work has begun on the Batch Two discharges.
Refer to the Current Status section for an update on Batch One.
UNDS Phase II Batch Two consists of four discharges, the technical analyses of which has been underway since mid 2004. The four Batch Two discharges are:
- Aqueous Film-Forming Foam;
- Compensated Fuel Ballast;
- Graywater; and
- Seawater Piping Biofouling Prevention Discharge.
Aqueous Film-Forming Foam – Aqueous film-forming foam (AFFF) is the primary firefighting agent for flammable liquid fires on Navy, U.S. Coast Guard (USCG), and Army vessels. AFFF is a particular type of synthetic firefighting foam whose performance is qualified by military specification, but it is similar to firefighting foams used at airports and other locations at high risk of flammable fuel spills in close proximity to human beings. AFFF controls and extinguishes flammable liquid fires by eliminating the oxygen supply to the fire and helps to prevent such fires (in the case of a spill) by spreading a vapor-sealing film over the flammable liquid. The exclusion of oxygen by the foam layer suppresses fire, while the high water content of the product cools the surface below the flash point.
On Armed Forces vessels, AFFF is applied either manually (i.e., from a portable extingisher or fire hose) or from fixed-sprinkler devices. The foam solution is formed when foam concentrate is mixed with seawater by an installed or portable proportioning device. Foam concentrate is stored in tanks, 55-gallon drums, and 5-gallon cans.
AFFF is never discharged from vessels in concentrated form. Only the diluted seawater foam solution is discharged. Incidental discharge of seawater foam solution occurs during maintenance and inspections when a vessel operates outside of 12 nautical miles (nm) from shore. Intentional discharge of the foam solution inside 12 nm of shore would be due to an actual shipboard emergency.
Compensated Fuel Ballast – Compensated fuel ballast systems are fuel systems used on board ship that have tanks that may contain fuel, seawater, or a mixture of fuel and seawater, however the tanks are full at all times. When a tank is refueled, the ballast water is expelled from the tank. Even though fuel and seawater are immiscible, some fuel can be entrained in the ballast water and discharged. Compensated fuel ballast systems are used only on a few classes of Navy vessels; most Armed Forces vessels are not equipped with these systems. Large combatant vessels, amphibious assault vessels, and submarines use compensated fuel ballast systems to maintain vessel stability. Most compensated fuel ballast systems are a series of fuel tanks that automatically draw in seawater to replace fuel as it is consumed. Keeping the fuel tanks full is generally essential to maintain the stability of a vessel between refueling operations.
Compensated fuel ballast is discharged from vessels during refueling operations that occur both at sea and in port. During typical refueling of compensated fuel ballast vessels (i.e., surface vessels), the fuel displaces seawater from the fuel tanks and compensated fuel ballast water is discharged directly overboard. Most refueling operations of surface ships occur at sea and the compensated fuel ballast is discharged greater than 12 nm from shore. Occasionally, however, surface vessels refuel in port. During refueling in port, most vessels discharge compensated fuel ballast directly to surface waters. However, in some ports, the discharge is collected and transferred to shore for processing. Submarines refuel only in port, and the compensated fuel ballast is always transferred to shore facilities for processing.
Graywater – Graywater on Armed Forces vessels is wastewater originating from galleys, laundries, lavatory sinks and showers, interior deck drains, and water fountains. All ships and some small boats of the Armed Forces generate graywater. The majority of graywater on ships comes from shower and lavatory sink, laundry, and galley and scullery sources. Small boats have more limited sources of graywater (e.g., a single sink and/or shower and a small galley) than large ships.
Graywater discharges occur both inside and outside 12 nm from shore. The majority of the discharge from surface vessels inside 12 nm occurs during transit to and from shore, with the most discharges occurring beyond 3 nm. While pierside, most Armed Forces surface vessels collect graywater and transfer it to shore treatment facilities. Some vessel types, however, have minimal or no graywater collection and holding capability and discharge graywater directly overboard while pierside. Submarines collect and discharge graywater to shore for treatment while pierside and discharge graywater overboard outside 3 nm.
Seawater Piping Biofouling Prevention Discharge – Seawater piping biofouling prevention discharge consists of seawater plus additives used to prevent the growth and attachment of biofouling organisms in dedicated seawater cooling systems on selected vessels. Biofouling control systems are necessary to control biofouling of surfaces within most seawater cooling systems. The exception is for cooling system piping that has inherent antifouling properties (e.g., titanium piping). Left unchecked, biofouling reduces seawater flow, heat transfer efficiency, increases energy consumption, and leads to premature equipment failures. The most common biofouling prevention systems use chlorination, chemical dosing, or anodic biofouling control systems. Chlorinators use electric current to generate chlorine and chlorine-produced oxidants from seawater. Chemical dosing uses an alcohol-based chemical dispersant that is intermittently injected into the seawater system. Anodic biofouling control systems use electric current to accelerate the dissolving of a copper anode to release metal ions into piping system. All of these systems act to prevent biofouling organisms from adhering and growing on interior piping and components. Typically, chlorinators operate a few hours daily, chemical dosing is performed for one hour every three days, and anodic systems operate continuously.
Seawater biofouling control systems continuously discharge both inside and outside 12 nm from shore when seawater cooling systems are in operation. Because there is greater demand for cooling water when a vessel is underway, correspondingly there is greater seawater piping biofouling prevention discharge. Since most large U.S. Armed Forces vessels (which produce the largest amount of seawater piping biofouling prevention discharge) spend minimal time transiting inside of 12 nm, most of the discharge occurs outside of 12 nm. Significant time is also spent pierside, but demand for cooling while pierside is reduced and mainly used for auxilary equipment such as generators and air conditioning/refrigeration plants.
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