Permit No.: 2007DB0002 

# Large Commercial Passenger Vessel Wastewater Discharge

General Permit Information Sheet

Alaska Department of Environmental Conservation Division of Water Commercial Passenger Vessel Environmental Compliance Program 410 Willoughby Avenue, Suite 303 PO Box 111800 Juneau, AK 99811-1800

The Alaska Department of Environmental Cons ervation (ADEC), Commer cial Passenger Vessel Environmental Compliance Program proposes to issue the Large Commercial Passenger Vessel Wastewater Discharge General Permit (the Ge neral Permit), number 2007DB0002 for discharges of treated sewage, graywater, and other wastewater. In ad dition the draft General Permit includes requirements regarding the on-board availability of solid and hazardous waste management and disposal plan s (18 AAC 69.035 and .040) The draft General Permit does not impose additional requirements on large cruise ships for solid and hazardous waste management. It does require that copies of all required wa ste management plans be available on-board for inspection.

In order to ensure protection of water quality and human health, the draft General Permit places limits on the types and amounts of pollutants that can be discharged from large commercial passenger vessels and places other conditions on such activity.

This information document includes:

 information on public comment, public hearing, and appeal procedures

 a description of the industry a nd the types of vessels covered

 a description of proposed permit conditions and basis for permit limits

Public Comment

The Department will hold a combined public information workshop and public hearing at Centennial Hall in Juneau Alaska on April 18, 2007. The public workshop will begin at 5:00 PM. The public hearing will begin at 6:00 PM. Interested members of the public can provide formal verbal testimony which will become part of the administrative record of this proposed action.Permit No.: 2007DB0002

2 Public Comment Start Date: April 10, 2007 Public Comment Expiration Date: May 10, 2007

Technical Contact: Chris Foley 907-465-5274 chris_foley@dec.state.ak.us

After the Public Notice period expires, and al l written comments and formal verbal testimony have been considered, the Department will make a final decision regarding permit issuance. If no substantive comments are received, the tenta tive conditions in the draft permit will become final, and the permit will become effective upon issuance. If s ubstantive comments are received, the Department will address the comments and issue the permit. The permit will become effective no less than 30 days after the issuance date.

Documents are Available for Review The draft general permit and related documents can be reviewed or obtained by visiting or contacting the Department between 8:00 a.m. and 4:30 p.m., Monday through Friday at the address below. The draft permits, information sh eet, and other information can also be located on the Departments public notice website http://www.dec.state.a k.us/public_notices.htm

Department of Environmental Conservation Division of Water Large Commercial Passenger Vessel Environmental Compliance Program 410 Willoughby Ave, Suite 303 PO Box 111800 Juneau, AK 99811-1800 (907) 465-5300

Department of Environmental Conservation Division of Water Large Commercial Passenger Vessel Environmental Compliance Program 555 Cordova Street Anchorage, AK 99501 (907) 269-6285

Appeal Procedures

Any member of the public who disagrees with AD EC’s final decision regarding issuance of the draft General Permit may request an adjudicatory hearing. 18 AAC 15.200. Request for an adjudicatory hearing specifies the procedures that must be complied with in order to request such a hearing.Permit No.: 2007DB0002

3 

### Background on Cruise Ship Regulation in Alaska

The U.S. Congress enacted Title XIV – Certain Alaskan Cruise Ship Operations on December 21, 2000. Under this federal legisl ation, large cruise ships ma y discharge treated sewage (blackwater) and graywater in Alaska while underway. The state set standards and sampling requirements for the underway discharge of blackw ater in Alaska that was identical to the blackwater standards in the federa l law. Because fecal coliform was detected in graywater during 2000 sampling, the state law also set gr aywater standards. During an underway discharge, treated sewage effluent must contai n no more than 200 fecal coliform per 100 ml and no more than 150 mg/l total suspended solids. Ther e are currently no federal effluent standards for underway graywater discharg es. Ships that discharge treated sewage in Alaska while underway must take at least two wastewater samples per cruise ship season to fulfill federal requirements. Alaska state law requires ships to take two samples of both treated sewage and graywater.

The federal law also allows continuous discharg e of treated sewage a nd graywater that meet more stringent standards. Ship owner/operators have installed advanced wastewater treatment systems on their vessels to meet the more stri ngent standards. A ship owner/operator must submit to the U.S. Coast Guard (USCG) and the Alaska Department of Environmental Conservation (ADEC) five sample results taken within 30 consecuti ve days that meets the more stringent requirements. The USCG and ADEC eval uate the data submitted. If the conditions are met, the USCG issues a continuous discharge ap proval letter, which allo ws ships to discharge continuously including times when the ship is at anchor. A ship approved by the U.S. Coast Guard to discharge continuously must sample thei r wastewater twice per m onth to maintain this approval.

In December of 1999, ADEC invited the U.S .Coa st Guard, The US Environmental Protection Agency, and members from the Southeast Conferen ce to join industry representatives and local concerned citizens in a public discussion. This forum became known as the Alaska Cruise Ship Initiative (ACSI). An Executive Steering Co mmittee convened in January 2000 to direct the ACSI work groups. The Alaska Cruise Ship Initiative was dissolved in November 2001. The Commercial Passenger Vessel Environmental Co mpliance Program now leads the efforts to oversee the sampling and testing of wa stewater and air opacity monitoring.

More information on the background of the ACSI is available on the Alaska Department of Environmental Conservation website at: http://www.dec.state.ak.us/water/cruise_ships/cruiseinitiative.htm The Commercial Passenger Vessel Envir onmental Compliance (CPVEC) Program was established in July 2001 by AS 46.03.460 - AS 46.03.490. The Alaska Department of Environmental Conservation (ADEC) worked with a facilitator and a Negotiated Regulations Committee to draft regulations to accompa ny this law. The regulations that were drafted by the Committee were taken through the formal rulemaki ng process that included a period for public comment. The public comment pe riod was completed, and the regulations became effective November 15, 2002.Permit No.: 2007DB0002

4 On July 8, 2004 the state law AS 46.03.460-46.06.490 was changed based on Chapter 153, SLA 04 which was passed by the Alaska Legislature. The ADEC drafted regula tions to reflect the statue change to allow for best management plans and the requirements of those plans. The ADEC also proposed changes enabli ng online registration, clarifica tion of discharge information reported in a vessel's specific sampling plan, and to make other changes necessary to improve the regulations. The newly amended regulations became final and effective May 18, 2006.

Alaskan voters in August 2006 approved a ball ot measure that affected ADEC’s CPVEC Program. One of the results of passage of this m easure was statutory changes that took affect in December 2006. A portion of the statutory chan ge required that ADEC develop a wastewater discharge permit for the large cruise ships that pl y the marine wasters of the state. This draft General Permit was developed in re sponse to this new requirement.



### The Cruise Industry in Alaska Cruise vacations continue to be among the strong est markets in tourism. Most cruise lines are expanding; adding more ships and seeking new regi ons to cruise. Alaska continues to be a popular market. The economic impact of the cruise ship industry continues to be significant.

. In Alaska, recent studies cite more than $700 million (US) in annual economic benefits directly tied to the industry. (Source: Northwes t Cruise Ship Association 2007)

Alaskan ports of call for cruiseships include but may not be limited to Anchorage, College Fjord, Dutch Harbor, Glacier Bay, Haines , Homer, Hubbard Glacier, J uneau, Ketchikan, Kodiak, Point Sophia (Hoonah), Seward, Sitka, Skagway, Tracy Arm, Whittier, and Wrangell. (Source: Northwest Cruise Ship Association 2007)



### Vessel Classification for this General Permit In developing the vessel classification system in the draft General Permit ADEC initially considered a very simple classificatio n system based on discharge location.

 If the vessel discharges treated sewa ge, graywater, or other wastewater into marine waters of the state more than one nautical mile offshore and traveling at six knots or greater;

 If the vessel discharges treated sewage , graywater, or other wastewater but continuously with a US Coast Guard approved wastewater treatment system; or

 If the vessel does not discharge trea ted sewage, graywater, or other wastewater into marine waters of the state. May have discharges of wastewater that is not co-mingl ed with sewage or graywater.

The department considered if vessels that do no t discharge treated sewage, graywater, or other wastewater into waters of the state should be re quired to apply for and obtain authorization under the draft General Permit. The department evalua ted two primary factors in deciding to require these vessels to seek coverage under the draft General Permit. The first factor was the level and type of information required in the annual regist ration. All vessels that operate in the marine waters of the state shall re gister with the state (AS 46.03.461). The concern with non-Permit No.: 2007DB0002

5 discharging vessels is that the registration form does not require any estimate of daily sewage, graywater, or other wastewater production no r detailed information on the total volume of available holding tanks.

The Notice of Intent in the draft General Permit re quires that for vessels th at will not discharge into marine waters of the state, the app licant shall provide the following information:

 the storage capacity (cubic mete rs) of all onboard holding tank(s);

 a copy of the holding tank operati ons and maintenance plan; and

 a copy of the overboard disc harge control valve plan.

 Average graywater generation per day in cubic meters for the following

sources:

 accommodations

 galley

 laundry

 Maximum graywater generation per day in cubic meters for the following

sources:

 accommodations

 galley

 laundry

By requiring that non-discharging vessels apply fo r coverage under the draft General Permit, the department will be able to require that vesse l owner/operators provide adequate information which will allow the department, and the public, to determine that the vessel is physically capable of holding wastewater until outside the mari ne waters of the state. In addition to the holding tank and valve control plans, this info rmation will provide assurance that adequate measures are in effect to minimize the risk of an accidental discharge to the marine environment.

The draft General Permit requires that vesse ls report hourly vessel location via Global Positioning System (GPS) technology which can be used to verify locations of discharging and non-discharging vessels. This tracking provisi on was a required by th e 2006 ballot measure.

The department considered usi ng the volume of discharged trea ted sewage (cubic meters per day) into waters of the stat e as a criterion for vessel cla ssification, but there is no clear correlation between the number of commercial passengers and the discharge volume. While there is a weak correlation between the number of commercia l passengers and the volume of wastewater discharged, th e department is reasonably confident that the risk to the environment resulting from any untreated wastewater discharge (upset, accidental or de liberate) increases with increasing passenger loads. Therefore the depa rtment has developed a vessel classification system based upon discharge location a nd commercial passenger loading. ADEC used passenger information provided in th e 2006 vessel registrations from vessels that offer overnight accommodations for two hundred fifty (250) or more passengers for hire, determined with reference to the number of lower berths. There were 24 vessels that registered for 2006 operations that meet the passenger criteria for coverage under the draft general permit. The number of passengers ranged from 435 (the S ilver Shadow) to 2,900 (the Norwegian Star). The annual registration form includes eight (8) cla sses of large commercial passenger vessel sizePermit No.: 2007DB0002

6 based upon the number of overnight accommodations based upon the number of lower berths. The draft General Permit compresses this to three (3) classes.

Class 1 includes passenger loading between 250 and 500 passengers. There was only one vessel that falls into this class ba sed upon 2006 registration informati on. US Coast Guard regulations apply to vessels with more than 500 passengers (33 CFR 159.303) so the department needed to create a class for this sized vessel. Cla ss 2 includes those vessels with passenger loading between 501 and 1,500 passengers. This includes six (6) vessels based upon 2006 registration and includes actual register ed passenger loading from 1,266 (the Ryndam) to 1,440 (the Zaandam). Class 3 includes all vessels with mo re than 1,501 passengers. This includes 17 vessels according to the 2006 registration and in cludes a range of populations from 1,596 (the Regal Princess) to 2,900 (the Norwegian Star)

The discharge class ND includes all vessels that do not disc harge treated sewage, graywater, or other wastewater into marine waters of the state but may ha ve other minor discharges of untreated wastewater (i.e., deck drainage). CD includes vessels that continuously discharge treated sewage, graywater, or ot her wastewater in marine waters of the state or United States after obtaining a US Coast Guard approval of the vessel’s advanced wastewater treatment system but may have other discharges of untreated wast ewater into marine wa ters of the state. SD includes vessels that discharge treated sewage, graywater, or other wastewater but may have other discharges of untreated wast ewater into marine waters of th e state only when the vessel is more than one nautical mile offshore and traveling at six knots or greater.

Class 1-CD: Provides overnight accommodati ons for more than two hundred fifty (250) and less than five hundred (500) passengers for hire and less determined with reference to the number of lower berths. Continuously discharges into ma rine waters of the state. Class 1-ND: Provides overnight accommodati ons for more than two hundred fifty (250) and less than five hundred (500) passengers for hire and less determined with reference to th e number of lower berths. No discharge of treated sewage, graywa ter, or other wa stewater but may have other discharges of untreated wastewater (i.e., deck drainage) into marine waters of the state. Class 1-SD Provides overnight accommoda tions for more than two hundred fifty (250) and less than five hundred (500) passengers for hire and less determined with reference to the number of lower berths. Only discharges into marine waters of th e state when vessel is at least one nautical mile offshore and is traveling at least six knots. Class 2–CD: Provides overnight accommodati ons for more than five hundred (500) and less than one thousand five hundred (1,500) passengers for hire and less determined with reference to the number of lower berths. Continuously discharges into ma rine waters of the state. Class 2-ND: Provides overnight accommodati ons for more than five hundred (500) and less than one thousand five hundred (1,500) passengers for hirePermit No.: 2007DB0002

7 and less determined with reference to the number of lower berths. No discharge of treated sewage, graywa ter, or other wa stewater but may have other discharges of untreated wastewater (i.e., deck drainage) into marine waters of the state. Class 2-SD: Provides overnight accommodati ons for more than five hundred (500) and less than one thousand five hundred (1,500) passengers for hire and less determined with reference to the number of lower berths. Only discharges into marine waters of the state when vessel is at least one nautical mile offshore and is traveling at least six knots. Class 3-CD: Provides overnight accommodati ons for more than one thousand five hundred (1,500) passengers for hire de termined with reference to the number of lower berths. Continuously discharges into marine waters of the state. Class 3-ND: Provides overnight accommodati ons for more than one thousand five hundred (1,500) passengers for hire de termined with reference to the number of lower berths. No discha rge of treated sewage, graywater, or other wastewater but may have other discharges of untreated wastewater (i.e., deck drainage) in to marine waters of the state. Class 3-SD: Provides overnight accommodati ons for more than one thousand five hundred (1,500) passengers for hire de termined with reference to the number of lower berths. Only disc harges into marine waters of the state when vessel is at least one naut ical mile offshore and is traveling at least six knots.

This draft General Permit authorizes the discha rge of treated sewage, graywater, and other wastewater to all marine waters of the state from large commercial passenger vessels that have a current vessel registration on file with the depa rtment. Only for those classes or location of waters specifically listed in Section 1.4 and 1.5 of the draft General Permit are discharges prohibited. These prohibited areas include:

1. Legislatively designated special area, (State Game Refuges, Critical Habitat Areas and State Game Sanctuaries). 2. Areas within 100 meters horizontally of mean lower low water tidal datum of the tidally affected portion of waters identified under 11 AAC 195.010(a) as important for the spawning, rearing, or migration of anadromous fish; 3. Within 100 meters of known herring spawning areas from March 1 through June 15 of each calendar year, within waters that are of a depth of 20 meters vertically of mean lower low water tidal datum, and that are identified in the department's set of maps entitled, Herring Spawning Areas in Alas ka, dated November 2005 and adopted by reference. 4. Within one (1) nautical mile of any major Steller sea lion haulout or rookery site or within any Steller sea lion “Critical hab itat Area” defined in 50 CFR 226.202, whichever is greater, without written pe rmission from the Regional Dire ctor of the National Marine Fisheries Services.Permit No.: 2007DB0002

8 5. Any waterbody included in the ADEC CWA Se ction 305(b) report or effective CWA Section 303(d) list of waters which are “impai red” or “water quality-limited” for any of the authorized pollutant parameters.



### Discharge Characterization

During 2000, wastewater samples were taken from 21 large cruise ships visiting Juneau. The only cruise ship wastewater di scharge regulated by the Environm ental Protection Agency at the time was treated sewage from the marine sanita tion devices (MSDs). In Alaska graywater is regulated as sewage.

Treated sewage, (from toilets) and graywater (fro m showers, sinks, galleys, and laundry) were tested in the same manner as land based sewage treatment plants. Some results showed that treated sewage exceeded the federal treatment sta ndard and that graywater could have elevated fecal coliform levels. Following the initial sa mpling results, the Coast Guard focused on how marine sanitation devices were operated and maintained by conducting follow-up inspections.

Some of the findings of the 2000 sampling are summarized below:

 43% of the samples for fecal coliform were in compliance with the federal marine sanitation device (MSD) standard of 200 f ecal coliform per 100 m illiliters. Fecal coliform indicates the possible presence of human waste.

 32% of the samples for total suspended solids were in compliance with the MSD standard.

 Only one of the samples of conventional MS Ds was in compliance with both the fecal coliform and total suspe nded solids standards.

 Five of the six samples of combined gray and blackwater treated by reverse osmosis systems were in compliance with both the fecal coliform and total suspended solids standards.

 75% of the samples of graywater tested had over five times the fecal coliform standard for MSDs of 200 FC/100ml.

Each ship's 2000 discharges was additionally analy zed for a suite of chemicals, called priority pollutants that would indicate if there was improp er disposal of hazardous chemicals. Priority pollutants include metals and man-made organi c compounds, including thos e used in industrial products or processes. A few priority pollutants were pres ent at levels above water quality standards; however, there was not enough inform ation to determine if exceedence had occurred.

By the end of the 2005 cruise ship season, monito ring required by the U.S. Coast Guard was able to document substantial improvements in effluent discharge quality from properly operated and maintained MSDs. ( 2005 Large Ship Wastewater Continued Compliance Samples for Continuous Discharge Certification by the United States Coast Guard,Permit No.: 2007DB0002

9 http://www.dec.state.ak.us/water/cruise_s hips/pdfs/05_large_ship_continued_compliancefinal2.pdf ).

The cruise ship discharges that are the subject of this draft general permit are treated sewage, gray water, and other wastewater. Collectively, the treated wastew ater (prior to discharge) is called effluent. Effluent is defi ned in the definitions section of the draft General Permit as the segment of a treated sewage, graywater, or othe r wastewater stream that precedes discharge of the wastewater stream to the receiving environm ent. Cruise ship discharge volume of treated wastewater varies from vessel to vessel across the fleet but ranged from 60,760 gallons per day to 289,270 gallons per day (2006 ADEC data). For purposes of comparison, Table 1 below contrasts cruise ship population & discharge volume with municipa l population & discharge volume from two small municipa lities in southeast Alaska.

Table 1: Comparison of Cruise Ship Discharg es with that of Similarly Populated Southeast Alaska Municipalities

Cruise Ship A Cruise Ship B Municipality A Municipality B

Total population 3224 2760 3398 2,589 Wastewater production 211,300 gals/day (max load) 158,500 gals/day (max load) 614,000 gals/day (avg Jan-Mar, May 99) 375,000 gals/day (avg May-Aug 97)

( Alaska Cruise Ship Initiative: Part I Fina l Report (Activities through June 1, 2000))

Cruise ships have been working to improve the pe rformance of their traditional marine sanitation devices (MSD) or replace them with new adva nced wastewater treatment technologies. A discussion of the common wastewater treatmen t technology employed by the cruse ship industry in Alaska follows below.

1. Wastewater Treatment Systems

Although different in scale, cruise ship’s wast ewater systems can be compared to municipal treatment systems that serve small Alaskan citie s. Cruise ships are ex cluded from having to obtain permits under the Clean Water Act (CWA). However, their marine sanitation devices (MSDs) must meet the effluent standards establ ished in Section 312 of the CWA. This section set the Type II MSD effluent standards for tr eated sewage at 200 fecal coliform/100 ml and 150 mg/L total suspended solids (TSS).

Marine biological treatment systems are similar to land based municipal treatment systems. A marine biological treatment system has three steps: (1) aeration; (2) clarif ication & filtration; and (3) final chemical disinfecting. All sludge is re-circula ted to the activated sludge aeration section.

The raw sewage passes through a screen, which rem oves grit, then enters the marine sanitation device (MSD) aeration chamber. The raw sewage mixes with a large concentration of active aerobic bacteria that consume the organic wast e in the sewage. The chamber contains air diffusers that provide oxygen to k eep the aerobic b acteria healthy.Permit No.: 2007DB0002

10 The wastewater flows from the aeration chamber into the clarification and filtration chambers. The filter media removes larger pieces of organic waste not consumed by bacteria in the aeration chamber. The aerobic bacteria also consume the biomass on the filter. After clarification and filtration, wastewater flows into the chlorine co ntact chamber. The wastewater stays in this chamber until virtually all bacteria are killed. Unlike a land based biological system, marine systems process a concentrated blackwater stre am without dilution from graywater or storm water. Biological systems thrive on a constant, even flow of nu trients and constant pH. This constant flow is difficult to achieve since the demand on a ship’s treatment system is intermittent with periods of low or no flow. None of the commonly used treatment systems are designed to remove metals from treated effluent prior to discharge.

The following information on wastewater tr eatment systems found on large commercial passenger vessels was taken from a report tit led “Assessment of Cruise Ship and Ferry Wastewater Impacts in Alaska”, Alaska Departme nt of Environmental C onservation Commercial Passenger Vessel Environmental Compliance Program, February 9, 2004

A. Reverse Osmosis Filtration

Osmotic theory implies pure water will move acro ss semi- permeable membrane into wastewater until the contaminant concentrations of both liquids are equal. However, if external pressure is exerted on the "contaminant" solution, water wi ll flow in the reverse direction from the wastewater into the pure water. This phenomen on, known as reverse osmosis (RO), can separate pure water from contaminated matrices. ROCH EM treatment systems employing this process were installed on two ships that operat ed in Alaska during the 2001 season ( Celebrity Mercury sewage and Carnival Spirit graywater). Analysis of the effl uent from the fully operational ROCHEM units indicated that suspended solids or fecal colif orm were not present in the discharge water. The presence of some BOD and a slightly elevated pH required some buffering and a final run through activated charcoal canisters before discharge. In 2001, one ship using this system was approved by the Coast Guard for disc harge anywhere in Alaska waters (except for blanket exclusion areas) includi ng in port. Both systems use u ltraviolet (UV) disinfection after the RO unit and were approved by the U.S. Coas t Guard for stationary discharge during 2003. The sample points are both ships are less than 50 feet from the over board discharge point.

Samples Taken after RO/UV Treatment Unit (2003)

pH BOD5 TSS total chlorine residual free chlorine residual fecal coliform

Number of Samples = 21 mg/L mg/L Mg/L mg/L MPN/100 Minimum 6.6 0 0 0 0 0 Median 7.3 15 0 0 0 0 Maximum 9.1 27 0 0 0 4Permit No.: 2007DB0002

11 B. Bio-reactor/filtration

These units employ an integrated system of enhanced aerobic digestion and low-pressure membrane filtration to treat blackwater and gray water. Currently, sixteen large cruise ships operating in Alaska have installed this proce ss using Zenon, Scanship, or Hamworthy systems. After only a brief holding period in the bio-reactor, the Zenon sy stem passes the influent through membrane filtration modules that have very la rge surface area and an extremely small pore size (0.035 micron or 0.035 X 10 -6 meters). Wastewater then pass es through a UV disinfection unit. Samples are taken immediately after the UV unit. The distance from the UV unit to the discharge point varies from vessel to vessel.

Samples Taken after Zenon/UV Treatment (2003) 1

Number of Samples = 24 pH BOD5 TSS Total Chlorine Residual Free Chlorine Residual Fecal Coliform
Units S.U. Mg/L mg/L mg/L mg/L MPN/100

Minimum 7.2 0 0.0 0.00 0.00 0

Median 7.6 0 0.0 0.00 0.00 0

Maximum 8.4 5 0.0 0.00 0.00 0

1 Holland America Maasdam, Ryndam, Statendam, Veendam, Volendam , and Zaandam

The Scanship system relies more heavily on biological digestion. Th is unit enhances the capacity and effectiveness of the bio-reactor with plastic carrier elements (biofilm) suspended in the wastewater to increase reactor surface area with eventual polishing microfiltration and UV disinfection.86 At the beginning of the season, sa mples were taken after the UV. By mid-season, the samples were taken at the end of the discharge line before the overboard port.

Samples Taken after Scanship/UV Treatment (2003) 2

Number of Samples = 18 pH BOD5 TSS Total Chlorine Residual Free Chlorine Residual Fecal Coliform
Units S.U. mg/L mg/L mg/L mg/L MPN/100

Minimum 6.3 5 0.0 0.00 0.00 0

Median 6.9 11 7.0 0.00 0.00 0

Maximum 7.6 26 28.6 0.00 0.00 240

2 Norwegian Sky, Sun , and Wind

In a Hamworthy system, wastewater is passed through an aerobic biological treatment system and ultrafiltration units. It is then chlorinated to kill remaining bacteria. The chlorine levels in the effluent were occasionally over the 10 mg/l limit for continuous discharge allowed by the U.S. Coast Guard and the Alaska Water Quality Stan dard of 7.5 ug/l. Princess has installed UV on two of their ships with the Hamworthy system and is considering substituting UV for chlorinePermit No.: 2007DB0002

12 disinfection on all ships in the fu ture. Samples of this system were taken on the discharge line near the overboard port. Some sa mples indicated that there was fecal contamination within the discharge line.

Samples Taken after Hamworthy Treatment (2003) 3

Number of Samples = 58 pH BOD5 TSS Total Chlorine Residual Free Chlorine Residual Fecal Coliform
Units mg/L mg/L mg/L mg/L MPN/100

Minimum 6.6 0 0.0 0.00 0.00 0

Median 7.3 2 0.0 0.00 0.00 0

Maximum 8.1 86 19.1 55.00 50.00 220

3 Princess Dawn, Island, Pacific, Star and Sun; Radisson Seven Seas Mariner

All four of the treatment systems listed above regularly satisfies the requirements necessary to maintain U.S. Coast Guard continuous discharge certification.

2. Comparison of Advanced Treatment System Medians

pH BOD5 TSS Total Chlorine Residual Free Chlorine Residual Fecal Coliform
Units mg/L mg/L mg/L mg/L MPN/100 RO (21) 7.28 14.9 0.0 0.00 0.00 0 Zenon (24) 7.64 0.0 0.0 0.00 0.00 0 Scanship (18) 6.94 10.9 7.0 0.00 0.00 0 Hamworthy (58) 7.33 2.2 0.0 0.00 0.00 0

Sample data demonstrated that fecal coliform c ontamination of the effluent sometimes occurred in the discharge pipe. The probability of fecal contamination increased as the pipe length increased. ADEC therefore required that future sa mples be taken within 50 feet of the overboard discharge location in the future.

3. Data Reliability and Representative Nature

It is crucial that wastewater sample data is reliable and representative. This data is used to determine compliance with the cruise ship laws a nd to conduct scientific analysis. Large vessels that discharged in Alaska took at least two comp liance samples per cruise ship season to satisfy both state and federal cruise ship laws. ADEC, the U.S. Coast Guard, and the Northwest Cruiseship Association have es tablished a Quality Assurance/Qu ality Control (QAQC) plan that ensures that the sample results are reliable.Permit No.: 2007DB0002

13 The QAQC plan includes standard sampling and laboratory quality control elements with additional instructions tailored to a maritime facility. It lists all the pollutants to be tested and the EPA analytical methods to be used. The QAQC requirements include duplicate sampling, sampling audits, and a lab technical systems audit. The U.S. Coast Guard cr uise ship regulations require third party sampling. ADEC regulations ar e consistent with other state wastewater programs and allow industry to collect samples us ing their own staff. However, large cruise ships sample to satisfy the requirements of both the federal and state law. Therefore, a third party sampler took all required large vessel wastew ater samples. Small ship operators are not bound by the federal law but also chos e to use third party samplers.

ADEC also performs independent compliance sampling and analysis. ADEC tests for pollutants listed in the QAQC plan as well as other pollutants of concern. Because e ach ship is configured differently and follows unique wastewater manage ment practices, the state also requires the owner/operator to submit a vessel specific sa mpling plan (VSSP). The VSSP plan, approved by ADEC before sampling begins, must demonstrate that the sample will be representative of the wastewater discharged fr om the particular ship.



### Effluent Limitations

There are two methods used to establish effluent limits in wastewater discharge permits. The first method is known as Technology Based Effl uent Limits. The second method is Water Quality Based Effluent Limits (WQBEL). Technol ogy-based limits are set ac cording to the level of treatment that is achievable using available technology. A water quality-based effluent limit is designed to ensure that the water quality standard s applicable to a waterbody are being met and may be more stringent than t echnology-based effluent limits.

Technology based limits for non-municipal disc hargers are based upon Effluent Limitation Guidelines (ELGs). ELGs are national sta ndards promulgated by the U.S. Environmental Protection Agency (EPA) that prescribe allowable discharges of pollutant s from industrial point source categories corresponding to various levels of treatment or control technologies. Because large commercial passenger vesse ls are not required to obtain a CWA discharge permit, EPA has not promulgated ELGs for large commercial passenger vessels. Therefore, effluent limits in the draft General Permit are based upon state water qual ity standards and a combination of state and federal requirements.

Alaska’s Water Quality Standards (18 AAC 70) include three articles: Article 1, statewide standards (18 AAC 70.005 -.050), Article 2, excep tions to state-wide standards (18 AAC 70.200 -.270), and Article 3, general pr ovisions (18 AAC 70.900 -.990). The standards also include the Alaska Water Quality Criteria Manual for Toxic and Deleterious Organic and Inorganic Substances. The Alaska Water Quality Criteria Manual for Toxi c and Deleterious Organic and Inorganic Substances have been adopted into 18 AAC 70.020(b). Numeric criterion for certain pollutants in this draft General Permit. (i.e., fecal coliform) are found in 18 AAC 70.020 (b).

The Alaska Water Quality Standards are found at: http://www.dec.state.ak.us/ water/wqsar/wqs/wqs.htmPermit No.: 2007DB0002

14 Effluent Limits in this General Permit

Effluent Characteristics Minimum Value Monthly Average Daily Maximum 7 Day Average Minimum Frequency Sample Type

Total Flow (cubic meters per day of effluent) N/A N/A Not to exceed design capacity

Report N/A Daily Metered or estimated

Biochemical Oxygen Demand (5-day) N/A 30 mg/L 1 60 mg/L 1 N/A Twice Monthly Grab

Settable Solids N/A 30 mg/L 1 45 mg/L 1 N/A Twice Monthly Grab

Fecal Coliform Bacteria N/A 14 per 100 mL 1, 2 ,3 & 4 43 per 100 mL 1 N/A Twice Monthly Grab

Total Residual Chlorine N/A N/A 0.0075 mg/L 1, 7 N/A Twice Monthly Field test

Ammonia N/A N/A 20.0 6, 8 mg/L N/A Twice Seasonally Grab

Copper N/A N/A 0.0031 mg/L 5, 8 N/A Twice Seasonally Grab

Lead N/A N/A 0.0081 mg/L 5, 8 N/A Twice Seasonally Grab

Zinc N/A N/A 0.081 mg/L 5, 8 N/A Twice Seasonally Grab

pH 6.5 S.U 1 N/A 8.5 S.U 1 N/A Twice Monthly Field test, grab, or continuous Total Suspended Solids N/A N/A 150 mg/L 1 N/A Twice Monthly Grab or Continuous

Footnotes: 1. Milligrams per liter (mg/L); milliliter (mL); Standard Units (S.U.) 2. All effluent fecal coliform average results must be reported as the geometric mean 3. Not more than 10% of the samples may exceed this value 4. 30 day average is the average of all samples taken during the calendar month. If only one sample was collected, the result of th at sample is the 30 day average. 5. Marine chronic values from Manual for Toxics and Other Deleterious Organic and Inorganic Substances. 6 Ammonia standards are based on temperature, pH and salinity. This standard is from Table IX in the Alaska Water Quality Criteria Manual for Toxics and Other Deleterious Organic and Inorganic Substances using a ph 7.8, salinity of 20 g/kg and temperature between 10-15 degrees Celsius. Large ships while stationary have a minimum dilution factor of 10. Ammonia results greater than 20 mg/L exceed water quality standards in the receiving water. 7. The Alaska Water Quality Standard, (see 18 AAC 70) , limit is 0.0075 mg/L for total residual chlorine in marine water. The Department will use 0.100 mg/L (the minimum level for EPA Method 330.3 and Method 330.4) as the compliance eval uation level for this parameter. Daily maximum concentrationsPermit No.: 2007DB0002

15 below 0.100 mg/l will be considered in compliance with the limitation. Testing for total residual chlorine is not required if chlorine is not used as disinfectant in the wastewater treatment works process. 8. See Section 1.11 of this permit.

A brief discussion of how effluent limits in this permit were determined follows below:

BOD (Biological Oxygen Demand) The Alaska water Quality Standards does not co ntain a numeric criterion for BOD. The draft General Permit uses the limit established in 40 CFR 133.102 Secondary Standard which has been in effect in the existing program.

Settable Solids The Alaska Water Quality Standard is a narr ative standard found under sediment. The draft General Permit uses the limit established in 40 CFR 133.102 Secondary Standard which has been in effect in the existing program.

Fecal Coliform The CPVEC program previously adopted the fe deral standard of 200 FC/100 ml. The draft General Permit proposes to incorporate the most re strictive standard, in this case the State of Alaska marine aquatic life water quality criterio n of 14 FC/100 ml for a monthly average and 43 FC/100 ml for a daily maximum.

Total Residual Chlorine Chlorine is often used to disi nfect treated wastewater prior to discharge. The draft permit does not prohibit the discharge of chlo rine as an alternative method of disinfection, in case the UV disinfection system should fail.

Free residual chlorine is described as the portion of the chlorine injected into water that remains as molecular chlorine, hypochlor ous acid, or hypochlorite ions af ter the solution has reached a state of equilibrium. Combined residual chlorine is described as the porti on of chlorine injected into water that remains combined with ammonia or nitrogenous compounds after the equilibrium has been reached. Both free and residual chlorine have a very short half- life in marine waters; therefore, it is difficult to assess the effects of chlorine on aquatic life. ADEC saltwater criterions for chlorine are 13 μ g/L (acute criterion) and 7.5 μ g/L (chronic criterion). The acute criterion is based upon a 24-hour average concentr ation. The chronic cr iterion is based upon a four-day average concentration.

The total residual chlorine effluent limits in effect are not quantifiable using EPA-approved analytical methods. ADEC will use the minimum level (ML) of 100 μ g/L as the compliance evaluation level for this parameter. The permitte e will be considered compliant with the total residual chlorine limitations if the average mont hly and maximum daily chlorine concentrations are less than 100 μ g/L.

Ammonia Ammonia is present in two forms in saltwater: un-ioni zed ammonia (NH 3 ) and the ammonium ion (NH 4 +). The un-ionized ammonia form has been de monstrated to be the more toxic form ofPermit No.: 2007DB0002

16 ammonia. Ammonia affects the life cycle as well as survival of some species. Receiving water quality affects the proportion of un-ionized ammonia.

Ammonia standards are based on temperature, pH and salinity. The proposed effluent limit of 20.0 mg/L in the draft General Permit is from Ta ble IX in the Alaska Water Quality Criteria Manual for Toxics and Other De leterious Organic and Inorganic Substances. ADEC derived a value of 20.0 mg/L by using a ph 7.8, salinity of 20 g/kg, a temperature between 10-15 degrees Celsius, and a minimum dilution factor of 10. Ammonia results greater than 20 mg/L exceed water quality standards in the receiving water.

Copper Alaska has a water quality standard of 3.1 μ g/L dissolved copper in saltwater based on chronic effects to aqua tic life and 4.8 μ g/L for acute effects (Table IX in the Alaska Water Quality Criteria Manual for Toxics and Other Deleteriou s Organic and Inorgani c Substances). The chronic criterion is based upon a four-day averag e. The acute criterion is based upon a 24-hour average. Copper is can be toxic in aquatic environments and bio- concentrates in many different organs in fish and mollusks.

Lead Alaska has a water quality standard of 0.0081 mg/L dissolved lead in saltw ater based on chronic effects to aquatic life and 0.021 mg/L for acute e ffects (Table IX in the Alaska Water Quality Criteria Manual for Toxics and Other Deleteriou s Organic and Inorgani c Substances). The chronic criterion is based upon a four-day averag e. The acute criterion is based upon a one-hour

average.

Zinc Alaska has a water quality standard of 0.081 mg/L dissolved zinc in salt water based on chronic effects to aquatic life and 0.090 mg/L for acute e ffects (Table IX in the Alaska Water Quality Criteria Manual for Toxics and Other Deleteriou s Organic and Inorgani c Substances). The chronic criterion is based upon a four-day averag e. The acute criterion is based upon a one-hour

average.

pH 40 CFR 133.102 Secondary Treatment establishes the federal criterion for pH at a value between 6 and 9. The most stringent state water quality criterion for pH (for aquaculture water supply and aquatic life) state that pH must be no less than 6.5 and no greater than 8.5 standard units, and may not vary more than 0.2 pH units from na tural conditions. This draft General Permit proposes to incorporate the most re strictive standard, in this case the State of Alaska criterion.

Total Suspended Solids (TSS) The Alaska water Quality Standards does not co ntain a numeric criterion for TSS. The draft General Permit uses the limit established in AS 46.03.463 (b) which is also the federal standard.

Monitoring Requirements The draft General Permit proposes to impose a unifo rm monitoring requirement for all vessels to conduct monitoring twice monthly for all paramete rs with effluent limits. The draft General Permit proposes to maintain the twice seasonal re quirements for those other parameters withoutPermit No.: 2007DB0002

17 effluent limits that the CPVEC program previously required. This latter requirement mirrors the federal requirements for these parameters.