### 1 | Page December 3 0 , 2010

VIA FEDERAL RULEMAKING PORTAL: http:/www.regulations.gov

Attn: Docket ID No. EPA

- HQ

- OW

- 2010

- 0126

Water Docket US Environmental Protection Agency

EPA Docket Center
EPA West, Room 3334

1301 Constitution Avenue, NW Washington, DC 20004

Re.: Docket ID No. EPA

- HQ

- OW

- 2010

- 0 126 : Clean Water Act Section 312(b): Notice Seeking Stakeholder Input on Petition and Other Request to Revise the Performance Standards for Marine

Sanitation Devices

SUPPLEMENTAL INFO RMATION SUBMITTED ON CHAMBER OF

SHIPPING OF AMERICA INDUSTRY SURVEY ON VESSEL SEWAGE

MAANGEMENT PRACTICES AND MSD PERFORMANCE AND PRACTICES

Dear Sir or Madam.

The Chamber of Shipping of America (Chamber) represents 3 4 U.S. based companies that own, opera te or charter oceangoing tankers, container ships, and other merchant vessels engaged in both the domestic and international trades. The Chamber also represents other entities that maintain a commercial interest in the operation of such oceangoing vessels

. All of our members which own, operate or charter oceangoing vessels currently manage their sewage discharges through compliant MSDs as required under both international and domestic laws and regulations.

The Chamber appreciates the opportunity to provi de supplemental

information relevant to the a bove referenced notice seeking stakeholder input on the petition to revise the performance standards for M arine Sanitation Devices (MSDs) as promised in our November 9, 2010 timely

submission to the docket. To preclude the need for retrieval of this

### 2 | Page document, the relevant text in our submitted comments is as follows in

bolded text:

CHAMBER OF SHIPPING OF AMERICA MARINE SANITATION DEVICE

SURVEY

Shortly after this request for comments was published, the Chamber created a reasonably simple survey which was sent to our 34 member companies and our international colleague trade associations with a request that this survey be widely distributed and

solicit input from ship owners, operators and charterers worldwide

. A copy of this survey is attached at annex

. As indicated, the Chamber requested that comments be submitted by October 15, 2010 to provide time for the qualitative and quanti tative analysis of the submitted data which will provide answers to many of the

spe cific questions posed by EPA in this notice.

To date, the Chamber has received 621 surveys. Unfortunately, over

250 of these surveys were received by the Chamber during the week of November 1, 2010 after a reminder notice was sent out in early

October. As a result of these late submissions and considering that these late submissions represent nearly 50% of the surveys received, we have not been able to conduct the quantitative analysis appropriate to provide detailed responses to the specific questions posed by EPA.

Chamber staff conducted a cursory analysis of the data as it was being received and we provide below qualitative responses to the specific questions posed. We will provide to EPA a full quantitative analysis of the data by December 31, 201 0 which we hope EPA will consider as support for the qualitative answers provided below. ”

EXPLANATION OF SURVEY PARAMETERS AND DATA ANALYSIS

PROTOCOLS

A copy of the survey as sent to the industry is attached as A nnex I to this document. As shown, CSA pr ovided introductory information as to why the information was being requested as well as the current requirements and definitions under both US and IMO requirements. The survey requested pertinent vessel characteristics as well as both qualitative and qua ntitative responses relative to current onboard operations regarding management of sewage aboard vessels, including characteristics of the sewage management system, operational histories, inspection and recordkeeping practices, maintenance procedures, samp ling protocols and contingency plans should any component of the system fail to operate properly. Attached as Annex II to this document is a description of the most relevant survey data parameters and analysis protocols as contained in the attached Excel spreadsheet which includes one line item for each of the 634 surveys

received. Finally, we are including the Excel spreadsheet as a separate file to

to the email which includes this document.

### 3 | Page PRELIMINARY INDICATIONS OF SURVEY RESULTS

In our original and timely submission to the docket, CSA responded to the specific questions posed based on a qualitative analysis of the survey responses that had been received at that time. Based on our more detailed analysis of all of the survey responses, we provide add itional information as indicated below. The section of our original submission to the docket is reproduced in full below, with our original responses noted in BLUE text. New responses and/or changes to the original responses are now added in

RED text.

R ESPONSES TO SPECIFIC QUESTIONS IN THE FEDERAL REGISTER

REQUEST FOR COMMENTS

Responses to the questions below are based on qualitative assessment of data collected in the Chamber MSD survey and will be further supported by a

later submission to this docket . It is important to note that our survey responders are owners, operators or charterers of oceangoing non

- passenger vessels of all types and relative sizes.

Category 1

– What existing public or private data sources are available for use in identifying, categorizing, and describing:

A. The numbers, types, and service of foreign

- flagged and domestic vessels currently operating in US navigable waters that have toilets

installed onboard?

The Chamber does not have data on all vessels, regardless of flag,

that currently operate in US navigable waters. It is recommended that
EPA consult with the US Coast Guard, the Maritime Administration and the Army Corps of Engineers each of which collect data on vessels trading in US navigable waters, although we do not bel ieve these databases would have explicit information on which vessels do or do not have toilets installed onboard, particularly recreational vessels. We would note that commercial vessels, regardless of size, have one

or more toilets installed on these ve ssels. No additional information gained from survey responses which encompass vessels which may or may not be trading to US ports. Our survey was focused on getting a sense of the state of the art in the global maritime fleet.

B. Of the domestic

- flagged ve ssels described in response to inquiry (1A) above, how many have one (or more) of the following sewage

treatment devices installed onboard? CSA Note: Of the 634 survey

responses, 18 % were attributable to US flag vessels.

**•** Type I MSD? No (0) survey respon ses note Type I MSDs installed. Survey analysis supports this statement that no US flag vessels responding to the survey have Type I MSDs.

### 4 | Page **•** Type II MSD? All survey responses note Type II MSDs installed. All (100%) of US flag vessels responding to the su rvey reported Type II MSDs installed supporting this statement.

**•** Type III MSD? A vast majority of survey responses indicates that Type II MSDs are installed with some holding capacity available (Type III), although the holding capacity varies widely from vessel to vessel. No US flag vessels reported having only a Type III system (holding tank only with no MSD). Survey results likewise support this statement nothing that the majority of US vessels reporting have both a Type II MSD installed AND holding ta nks (Type III).

**•** Actual survey responses indicated that 29% of US flag vessels reporting have a Type II system, while 71% of US flag vessels reporting have a combination Type II/III system.

C. Of the foreign

- flagged vessels described in response to inquir y (1A) above, how many have one (or more) of the following sewage

treatment devices installed onboard: CSA Note: Of the 634 survey

responses, 82% were attributable to non US flag vessels.

**•** Type II MSD (or) Sewage Comminuting and Disinfecting System? All survey responses note Type II MSDs installed. 35% of non US flag vessels responding indicate installation of a Type II only system.

**•** Type III MSD (or) Sewage Holding Tank? A vast majority of survey responses indicates that Type II MSDs are installed wit h some holding capacity (Type III) available, although the holding capacity varies widely from vessel to vessel. Only 1% of non US flag vessels responding indicate use of a Type III only system while a vast majority of non US flag vessels responding have a combination Type II/III system.

**•** Actual survey responses indicated that 35% of non US flag vessels responding indicate us of a Type II only system , 1% have a Type III only system, and 64% have a combination Type II/III system.

**•** Sewage Treatment Plant (ST P)? No (0) survey responses indicate that

STPs are installed. Final survey responses show 0 responses indicating installation of a sewage treatment plant per se; however a number of responses suggest installation of biologically based treatment systems w hich meet the old

MARPOL standard and in some cases meet the new standard. Further investigation would need to be done to determine if

some or all of these installations meet the definition of “sewage treatment plant”.

### 5 | Page D. Of those foreign

- flagged vessels wi th STPs described in response to inquiry (1C) above, how many have devices that are:

**•** Certified to meet the MARPOL Annex IV effluent standards and performance tests adopted in Resolution MEPC.2(VI)?

**•** Certified to meet the MARPOL Annex IV effluent standards and performance tests adopted in Resolution MEPC.159(55)?

Although no (0) survey responses indicate installation of STPs, a vast majority of the Type II/III hybrid installations comply with Resolution MEPC.2(VI). No responses indicate compliance with ME PC.159(55) which is quite understandable since this standard was finalized in January 2010 and vessels currently in operation, even the newest, would not have had time to integrate a sewage management system compliant with this more stringent standard, in to vessel design. It is important to note here that US flag vessels may have received a Certificate of Alternative Compliance by the USCG however, no US flag vessels included in our survey responses carry International Sewage

Pollution Prevention Certific ates since the US cannot issue these Annex IV based certifications due to the fact that the US is not a party to the

Annex.

**•** Again regardless of a system’s designation as an “MSD” or “STP” in the survey response, 20 of the 634 responses (3%)

indicate com pliance with the new Annex IV standard contained in MEPC.159 (55) . 14 of those responses are associated with non US flag vessels while the remaining 6 are associated with US flag vessels.

Category 2

– What existing product information or performance data

is available for:

A. MSDs certified to meet the performance standards and testing requirements described at 33 CFR Part 159? (Please Note: EPA is seeking input on information that is not currently contained in the Coast Guard’s certification files.) A n umber of survey responses included product information and performance data on installed MSD systems. The Chamber will include a listing of this data in its later

submission to the docket. CSA received a number of survey responses which provided system c haracteristics e.g. manufacturer, model, type, technology employed (maceration, disinfection, biological treatment, combination, other), and rated capacity. In addition, a number of survey responses also included information relating to onboard procedures in the event of a unit malfunction, routine testing and inspection protocols and onboard recordkeeping procedures. All of this type of information suggests that vessel operating procedures integrate the operation, maintenance, inspection and

### 6 | Page recordkeeping aspects of sewage management systems into

the vessel engineering and operating systems utilized onboard to monitor and maintain integral pieces of vessel equipment.

Due to the volume of this information and the variation in its
submission format, this wa s not suitable for integration into the Excel spreadsheet, although CSA will be pleased to work further with EPA to put this information in some usable format.

B. STPs that have been tested and received Certificates of Type Approval certifying that the devic e meets the MARPOL Annex IV effluent standards and performance tests in either Resolution MEPC.2(VI) or Resolution MEPC.159(55)? Not applicable as no (0) surveys indicated

installation of STPs. 100% of the responses indicated onboard

installations were i n compliance with either MEPC.2(VI) or MEPC.159(55) as evidenced by issuance of either an ISPPC issued by a nation party to Annex IV or in the case of US flag vessels, a SOVC issued by the US government.

Category 3

– Are you aware of any existing informat ion about other countries’ domestic laws that establish standards or discharge limitations for vessel sewage? The only laws/regulations in place in other countries of which we are aware, are those implementing the provisions of MARPOL Annex IV into nati onal legislation/regulation and those areas which are currently designated special areas for the purposes of discharges of sewage from vessels. No new information provided by

survey responses.

Category 4

– Given existing international and Federal limitat ions and controls regulating discharges of sewage from vessels, and in light of

the numerous CWA section 312 State

- established NDZs, should EPA consider revisions to the performance standards for MSDs, and what

should be the basis for such a decision. EPA should NOT, at this time, revise the current performance standards for MSDs. As noted in our submission to the docket last week re: the EPA proposed rule to establish a no discharge zone throughout the waters of the State of California (Docket ID

No. EPA

- R09

- OW

- 2010

- 0438: Marine Sanitation Devices (MSDs): Proposed Regulation to Establish a No Discharge Zone (NDZ) for California State Marine Waters), more than simple anecdotal evidence detailing water quality impairment is necessary to justify revisions t o the current regulations which we believe are sufficient robust to protect the waters of the United States. Specifically included in our comments is the following text which we believe is equally important in this proceeding.

“Further, in its discussion of vessel sewage generated from large oceangoing vessels at 75 FR 53920, EPA notes again that “as with large passenger vessels, EPA does not have data for determining how much of this sewage is discharged in State marine waters, however it is likely to be a significant portion”.

### 7 | Page It is difficult to comprehend how causation can be established between water quality and a particular discharge type when not even the volume of the discharge in question has been determined, much less the spatial and temporal dis tribution of these discharges and their relative contribution to observed water quality impacts in any location. Absent this information, statements suggesting that sewage discharges are “likely to be a significant portion” or “could be causing

or contrib uting to violations” are simply a guess as they are devoid of any scientific basis to support these questionable conclusions.

While EPA does describe the number and location of impaired water bodies that have potentially been impacted by sewage discharg es, it does so without addressing the nexus between these impairments and vessel discharges sought to be prohibited and in fact, lists a number of water bodies in which large commercial ships cannot or do not travel due to draft constraints and/or configur ation of port/berth locations in California ports. This lack of nexus was noted in the CEQ comments

found in document JP 37 in the docket where it noted that there was a need to address this nexus between water quality impairment and vessel discharges “in order to justify inclusion of this data in the

determination”.”

Category 5

– What existing information is available on the current practices, protocols or regulatory approaches to testing, monitoring and/or reporting sewage discharges from vessels, and w hat, if any are the practical limitations or burdens associated with these practices? A number of survey responses included information on how the operation and periodic maintenance of MSDs are integrated into the vessel operating procedures, including pe riodic testing and onboard recordkeeping. The Chamber will include a listing of this data in its later submission to the

docket. Again as indicated in our response to Category 2.A. above, a number of responses provided information on onboard procedures

f or testing, monitoring and recordkeeping/reporting which were not amenable for input into the Excel spreadsheet. Per above, CSA would be pleased to work further with EPA in providing this information in a

useful format.

CONCLUSION

The Chamber very much appreciates the logical and rational approach which EPA is taking to assess the current state of affairs relative to marine sanitation devices. Real impacts and real capabilities are the key to determining the response to the petition file d by the Friends of the Earth. While CSA is not a “big” organization relative to staffing or analytical abilities, we are hopeful that the results of this survey will provide a significant insight into the “real world” processes and procedures which govern the management of sewage by vessels. Unlike what we believe to be the general perception that these discharges go relatively unregulated, we believe that the responses contained in these surveys taken in conjunction with the detailed legal requirements placed on these systems and discharges show

### 8 | Page that today’s merchant vessels have installed not only compliant systems to manage sewage generated aboard these vessels but have also integrated comprehensive inspection, maintenance, monitoring and recordkeeping programs into v essel operations to ensure their continued performance to the legally required standards.

We a re hopeful that the qualitative information provided in our prior

submission taken in conjunction with the quantitative analysis which we provide here will infor m the EPA decision to NOT revise the current MSD regulations.

We t hank you again for the opportunity to comment on this proposed rule

and would be pleased to answer any questions or provide further information

as EPA sees fit.

Sincerely,

Kathy J. Met calf
Director, Maritime Affairs Chamber of Shipping of America
1730 M Street, NW

Suite 407 Washington, DC 20036

202.775.4399 kmetcalf@knowships.org

### 9 | Page ANNEX I

CSA SURVEY FOR VESSEL MSD AND ONBOARD SEWAGE MANG EMENT

SYSTEMS

The Chamber of Shipping of America seeks information to help prevent unwanted changes regarding Marine Sanitation Device regulations. Last April, Friends of the Earth submitted the “Petition for Rulemaking to Update the Regulation of Sewage Discharges from Large Vessels” to the Honorable Lisa
P. Jackson, Administrator of the United States Environmental Protection Agency. EPA has now requested comments as a direct result of this petition which requests EPA to revise its regulations for MSD pe rformance standards and to establish periodic monitoring, recordkeeping and reporting requirements for this equipment. This, process, as permitted under the US Clean Water Act, may sound vaguely familiar as it was the first step in the process that ultima tely led to the litigation and unfavorable decision that placed vessel discharges under the purview of the NPDES system.

This petition contained information, from the FOE perspective, explaining why the sewage discharges from large vessels are harming the environment and why the regulations need to become stricter. There is no information on the record at this point to argue that the existing regulations are sufficient in scope and stringency.

It is critical that the maritime industry provide real time operational data regarding the performance and management of vessel sewage management systems. Failure to provide such data to EPA will most likely result in the proposal of more stringent regulations for sewage in the US with no guarantee that what is pr oposed will align with existing IMO requirements. In order to provide relevant data to EPA on the current status of onboard sewage treatment and hopefully mitigate the impact of new more stringent, costly and arguably unjustified requirements, we need to collect data on existing systems and how compliance with current sewage regulations is/is

not achieved.

Please complete the enclosed survey so we can provide EPA with the information relative to the current performance of MSD and onboard sewage management systems.

Please answer the questions on the survey for each MSD on each of your ships or each class of ships which have the same onboard sewage management systems. If you choose to answer for a group of ships which have the same types of systems, pleas e include the number and characteristics of the ships in this group.

Please return the completed questionnaire to kmetcalf@knowships.org by
October 15, 2010. Thank you for your help.

### 10 | Page For purposes of US reg ulations, three MSD Types are currently recognized:

Type I MSD : Flow through treatment device which may be installed only on vessels less than or equal to 65 feet in length; produce effluent with no visible floating solids and fecal coliform bacterial cou nt not greater than 1000 per 100 milliliters.

Type II MSD : Flow through treatment device which may be installed on vessels of any length; produce effluent with fecal coliform bacterial count not greater than 200 per 100 milliliters, no more than 150 mg total suspended solids per liter.

Type III MSD : Holding tanks which may be installed on vessels of any length used for storage until shore side or compliant at sea discharge is possible.

In addition, some vessels, most notably cruise vessels have instal led advanced wastewater treatment systems (AWTS) and information on these installations is also requested.

For purposes of IMO requirements, effluent standards for sewage treatment plants are as follows (as compared to US Clean Water Act Type II MSD stand ards 0f <200 per 100 ml (fecal coliform) and <150 total suspended solids):

Installation prior to 1/1/2010 Installation on/after

1/1/2010 (MEPC.2(VI)) (MEPC.159(55))

Coliform ≤250 per 100 ml GM ≤100 per 100 ml GM

Total ≤50 GM ≤35 GM Suspended

Solids

BOD5 ≤50 GM ≤25 GM

COD n/a ≤125

Residual As low as practicable ≤5

Chlorine

### 11 | Page MARINE SANITATION DEVICE SURVEY

Type of ship:

Flag of ship:

Size of vessel (length/gross tonnage):

Nature of service (transoceanic, coastal, inland):

Year built:

Crew size (actual and certified):

Does the vessel have a valid International Sewage Pollution Prevention Certificate (MARPOL Annex IV)?

If not, d oes the vessel still comply with provisions of Annex IV and US laws and regulations e.g. certificate of alternate compliance for US flag ships trading internationally?

For vessels compliant with MARPOL Annex IV, do units comply with old standard (MEPC.2(V I)) or new more stringent standard (MEPC.159(55))?

Number of MSDs or other sewage treatment systems onboard ship?

Unit(s) type (please list info for each unit):

manufacturer type (I, II, III, AWTS) rated capacity design e.g. maceration , disinfection, b iological treatment,
combination, other

Total onboard holding capacity:

Estimated volume of sewage waste generated (per day, week or month):

If there is only a single system, what is the operational procedure for unit failure or overcapacity? (i.e. reta in waste onboard for discharge
ashore, retain waste onboard until unit is fixed, retain waste onboard until legal discharge at sea etc.)

What types of operational failures or malfunctions have occurred in the past 2 years and what actions have been taken to ensure compliance with US regulations?

Are non

- operational units fixed by ships’ crew or are shore side technical experts required?

### 12 | Page Do operational procedures include periodic testing and sampling for proper operation of sewage treatment devices? If yes, please provide a copy of these procedures.

What recordkeeping requirements are in place for the documentation of proper operation of sewage treatment devices including testing and sampling provisions, upset conditions and corrective action programs?

Any other comments or information you can provide that might be valuable to this work particularly with regard to non

- routine scenarios where holding and/or treatment capacity may be exceeded, need for shoreside discharge where otherwise not required, una vailability or inadequacy of reception facilities (please note port).

Legal references for MSD regulations can be found in MARPOL Annex IV and

33 CFR Part 159

### 13 | Page ANNEX II

EXPLANATION OF EXCEL SPREADHEET SURVEY DATA PARAMETERS

AND ANALYSIS PROTOCOLS

1. 1 st column (Record Number). Each individual vessel reporting is assigned a record number in the Excel Spreadsheet. For reports which
included entire classes of vessels with similar information, the number

of vessels in that class was determined and individua l line entries were

created for each vessel.

2. 2 nd column (Ship Type). Although its relevance was unknown at the time, CSA believed that collection of ship type information could be helpful in a more detailed analysis of the data, thus the column for ship type provides this detail. The vast majority of responses were

from v essels were divided into traditional subgroups which include

Tank vessels (wet bulk carriers of all sizes and types including crude oil, chemical and petroleum product tankers), Bulk car riers (dry bulk cargoes and combination oil/bulk carriers), Gas Carriers (GasC) which

include both Liquefied Natural Gas (LNG) and Liquefied Petroleum Gas (LPG) carriers, General Cargo vessels (GenC) which includes conventional parcel freight vessels as we ll as vessels which carry combinations of parcel freight and containers, Container vessels (Cont) which only carry containerized cargoes, Roll on/Roll off

vessels (RoRo) which carry “wheeled” cargoes including cars and
trucks, and Specialized Refrigerated Cargo vessels (reefer) which exclusively carry cargoes requiring refrigeration through the transit from load to discharge port. A small number of responses were from vessels in less traditional subgroups including Special Purpose

vessels (Sp Purp), Tugboa ts (Tug), Articulated Tug/Barge Units (ATB) and Integrated Tug/Barge Units (ITB).

3. 3 rd column (Flag). This data point represents the registry of the reporting vessel. In a few cases, this was not reported on the survey itself and is thus designated “not US” after confirmation with the reporting entity that the vessels were flagged in nations other than the US. Although generally self

- explanatory, some abbreviations were used for facilitating input into the spreadsheet including: MI (Marshall Islands), A nt/Barb (Antigua/Barbuda) Northern Antilles (NAnt), Netherlands (Neth), Singapore (Sing), and the Isle of Man (IofMan).

4. 4th column (Year Blt). This column represents the year in which the vessel was placed into commercial service. In a few instances, th is data was not provided and in this case this column is left blank for that particular record entry.

5. 5 th column (Service). This column reflects the nature of the trade in which the vessel was engaged at the time the survey information was submitted e.g. oceangoing/global (O) or coastwise (C). The vast

### 14 | Page majority of the entries are for oceangoing/global trading although a small number of entries reflect vessels engaged in coastwise trade. All of the entries reflecting coastwise trade are for US flag ves sels and thus represent vessels which are currently engage d in trade between US ports

, although some may be capable of engaging in international

voyages.

6. 6 th column (LOA (m)). Length overall of the reporting vessel in

meters.

7. 7 th column (GRT). Gross re gistered tonnage normally reported in

metric tons. This data point is relevant in determining whether the reporting vessel triggers the 400 gross ton application criteria

contained in MARPOL Annex IV. In a few cases, this data point was not reported and after additional inquiry of the responding entity, it was determined that all vessels which did not specifically report their gross registered tonnage were, in fact, in excess of 400 gross tons.

8. 8 th column (Crew). The original survey requested the respon der to provide both actual crew onboard and the number of crew/personnel for which the vessel was certified. Responses varied with some reporting the minimum crew permitted according to the Safe Manning document, the actual crew serving aboard the vessel and/or the maximum number of crew/personnel for which the vessel is certified based on required safety equipment. While the actual number on board reflects an important data point relative to actual daily volumes of generated sewage, the maximum crew/pers onnel for which the vessel is certified is equally important in estimating the maximum sewage volume which could be generated if the vessel carried personnel to the maximum legally permitted. It is this latter quantity

that serves as the basis for selecti on of MSDs at a rated capacity level sufficient to handle the potential maximum load. Due to the variation in responses and lack of clarity in which of these two data points were actually being reported, it was decided to report the higher of the two

repo rted numbers where two data points were reported. While the two data points do not usually vary considerably e.g. usually within 25% where an actual crew of 24 may be onboard a vessel with a 30 person rated maximum (certified), a few entries indicated lar ger variations. For example, record number 9 indicates a special purpose vessel which carries a normal crew of between 25 and 30, but may carry a maximum of 60 persons when activated to its full operational capacity. However, these large variations are few in number and thus it is assumed that the numbers provided in this column provide a realistic estimate (within 25%) of the total number of individuals carried aboard the vessel during normal operations.

9. 9th column (ISPPC?). This column reflects whethe r the reporting

vessel has a valid International Sewage Pollution Preventio n Certificate as issued by a party to MARPOL Annex IV. The vast majority of reporting vessels do possess this certification. Those that do not (US

### 15 | Page flag vessels) are addressed in t he explanation below for the 10 th

column.

10. 10 th column (US Cert). This column reflects whether the reporting vessel has a Statement of Voluntary Compliance (SOVC) as authorized by the USCG under USCG Navigation and Vessel Inspection Circular

No. 1

- 09 , “Vo luntary Compliance with International Sewage Regulations in Annex IV to MARPOL 73/78” . Because the US is not a party to MARPOL Annex IV, it may not issue an ISPPC under MARPOL Annex IV. However, US vessels engaged in international trade are still subject to the provisions of MARPOL Annex IV when trading to nations that are parties to Annex IV. The SOVC issued by the US government is thus evidence of compliance with the provisions of Annex IV by the vessel and is generally accepted by other nations as an equivalency to

the ISPPC. For non

- US vessels calling in US ports, the US recognizes the validity of the ISPPC as evidence of compliance with Annex IV. Thus the results of the survey contained in the matrix indicate that

either the vessel c arries a valid ISPPC or carries an SOVC (US flag vessels only). No vessels reported carrying both documents.

11. 11 th column (Old or New MARPOL). This data point indicates whether the reporting vessel complies with the provisions of IMO MEPC.2(VI) (the “old” MSD effluen t standard) or the “new” MSD effluent standard contained in MEPC.159(55). Both documents outline in great detail the performance standards for MSDs and include testing and certification provisions to be applied by nations certifying that the equipment mee ts the provisions of Annex IV. The most significant portion of MEPC.159(55) which was adopted in October 2006, is increased stringent in MSD performance standards which are to be applied to MSDs installed on or after January 1, 2010. Please see the

CSA s urvey at Annex I, for a comparison of the standards between the earlier MEPC.2(VI) and the new MEPC.159(55).

12. 12 th column (Tot Hld C). This data point indicates the total holding capacity in cubic meters for sewage reported by the responding vessel.

Ther e is a wide variation in reported capacities ranging from 0 to over

100 cubic meters. Two entries indicate “error” in that column due to

the incompatibility of the survey response to other reported values in the survey. Some entries indicate “Yes” in tha t column which reflects that the responding vessel noted holding capacity but did not provide the quantitative volume of that holding capacity. Finally, a few entries

are blank in this column which reflects the failure of that vessel to complete that ques tion in any manner.

13. 13 th column (Vol/Day). This data point reflects the daily volume in cubic meters of sewage generated as reported by the responding vessel. There is great variation in these values ranging from 0.1 to 12

cubic meters. Some of this va riation in the lower ranges can be attributed to vessel carrying smaller crew. Some of the variation in the higher ranges is likely attributable to systems which process both

### 16 | Page sewage and graywater through the MSD system. Variations may also

be attributabl e to the varying types of MSD technology employed on certain vessels which may result in reduced discharge volumes; however, this assumption can only be verified by more detailed comparison of the technology used and the volumes generated. One entry ind icates “error” due to incompatibility of the survey response to other reported values while a number of entries are left blank due to the failure of the reporting entity to provide this quantitative

information.

14. 14 th column (Days). This column represents the days of holding capacity which is derived by dividing column 12 by column 13 (total holding capacity/volume generated per day). Obviously for entities reporting zero holding capacity, this column also reflects zero days. Due to its relationship to the widely variable values contained in both columns 12 and 13, this column is equally variable with values ranging from zero (0) to 288 days. Higher values are likely associated with vessels that may utilize tankage not constructed for or typically

assoc iated with sewage and/or graywater retention. Responses which did not contain a response to column 13 are left blank.

15. 15 th column (Type). This column represents the type sewage management system in place on board the reporting vessel. A “2” in

this col umn indicates that the vessel has no holding capacity and utilizes a compliant MSD. A “3” in this column indicates that the vessel has no MSD and utilizes only holding tanks with discharge
ashore. A “2,3” in this column indicates that the vessel has both holding tank capacity and a compliant MSD.