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 Conservation (ADEC), Commercial Passenger Vessel

Environmental Compliance Program proposes to issue the Large Commercial Passenger Vessel 

Wastewater Discharge General Permit (the General Permit), number 2007DB0002 for discharges 

of treated sewage, graywater, and other wastewater. In addition the draft General Permit 

includes requirements regarding the on-board availability of solid and hazardous waste 

management and disposal plans (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 waste 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 and 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 all 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 tentative conditions in the draft permit will become 

final, and the permit will become effective upon issuance. If substantive 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 sheet, and other information can also be located 

on the Departments public notice website http://www.dec.state.ak.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 ADEC’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 legislation, large cruise ships may discharge treated sewage 

(blackwater) and graywater in Alaska while underway. The state set standards and sampling 

requirements for the underway discharge of blackwater in Alaska that was identical to the 

blackwater standards in the federal law. Because fecal coliform was detected in graywater 

during 2000 sampling, the state law also set graywater standards. During an underway 

discharge, treated sewage effluent must contain no more than 200 fecal coliform per 100 ml and 

no more than 150 mg/l total suspended solids. There are currently no federal effluent standards 

for underway graywater discharges. 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 discharge of treated sewage and graywater that meet 

more stringent standards. Ship owner/operators have installed advanced wastewater treatment 

systems on their vessels to meet the more stringent 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 consecutive days that meets the more 

stringent requirements. The USCG and ADEC evaluate the data submitted. If the conditions are 

met, the USCG issues a continuous discharge approval letter, which allows 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 their wastewater twice per month to maintain this 

approval. 

In December of 1999, ADEC invited the U.S .Coast Guard, The US Environmental Protection 

Agency, and members from the Southeast Conference 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 Committee 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 Compliance Program now leads the efforts to 

oversee the sampling and testing of wastewater 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 Environmental 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 accompany this law. The regulations that were drafted by the 

Committee were taken through the formal rulemaking process that included a period for public 

comment. The public comment period was completed, and the regulations became effective 

November 15, 2002. 
Permit No.: 2007DB0002 

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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 regulations to reflect the 

statue change to allow for best management plans and the requirements of those plans. The 

ADEC also proposed changes enabling online registration, clarification 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 ballot measure that affected ADEC’s CPVEC 

Program. One of the results of passage of this measure was statutory changes that took affect in 

December 2006. A portion of the statutory change required that ADEC develop a wastewater 

discharge permit for the large cruise ships that ply the marine wasters of the state. This draft 

General Permit was developed in response to this new requirement. 

The Cruise Industry in Alaska 

Cruise vacations continue to be among the strongest markets in tourism. Most cruise lines are 

expanding; adding more ships and seeking new regions 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: Northwest 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, Juneau, 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 classification system based on discharge location. 

 

 If the vessel discharges treated sewage, 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 treated sewage, graywater, or other 

wastewater into marine waters of the state. May have discharges of 

wastewater that is not co-mingled with sewage or graywater. 

The department considered if vessels that do not discharge treated sewage, graywater, or other 

wastewater into waters of the state should be required to apply for and obtain authorization under 

the draft General Permit. The department evaluated 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 registration. All vessels that operate in the marine 

waters of the state shall register 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 nor detailed information on the total volume of 

available holding tanks. 

The Notice of Intent in the draft General Permit requires that for vessels that will not discharge 

into marine waters of the state, the applicant shall provide the following information: 

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

 a copy of the holding tank operations and maintenance plan; and 

 a copy of the overboard discharge 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 for coverage under the draft General Permit, the 

department will be able to require that vessel 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 marine waters of the state. In addition to the 

holding tank and valve control plans, this information 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 vessels 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 provision was a required by the 2006 ballot measure. 

The department considered using the volume of discharged treated sewage (cubic meters per 

day) into waters of the state as a criterion for vessel classification, 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 commercial passengers and the volume of 

wastewater discharged, the department is reasonably confident that the risk to the environment 

resulting from any untreated wastewater discharge (upset, accidental or deliberate) increases with 

increasing passenger loads. Therefore the department has developed a vessel classification 

system based upon discharge location and commercial passenger loading. 

ADEC used passenger information provided in the 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 Silver Shadow) to 2,900 (the Norwegian Star). 

The annual registration form includes eight (8) classes of large commercial passenger vessel size 
Permit No.: 2007DB0002 

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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 based upon 2006 registration information. 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. Class 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 registered passenger loading from 1,266 (the Ryndam) to 1,440 (the 

Zaandam). Class 3 includes all vessels with more than 1,501 passengers. This includes 17 

vessels according to the 2006 registration and includes 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 discharge treated sewage, graywater, or 

other wastewater into marine waters of the state but may have other minor discharges of 

untreated wastewater (i.e., deck drainage). CD includes vessels that continuously discharge 

treated sewage, graywater, or other 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 wastewater into marine waters of the state. SD

includes vessels that discharge treated sewage, graywater, or other wastewater but may have 

other discharges of untreated wastewater into marine waters of the state only when the vessel is 

more than one nautical mile offshore and traveling at six knots or greater. 

Class 1-CD: Provides overnight accommodations 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 marine waters of the state. 

Class 1-ND: Provides overnight accommodations 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. No 

discharge of treated sewage, graywater, or other wastewater but may 

have other discharges of untreated wastewater (i.e., deck drainage) 

into marine waters of the state. 

Class 1-SD Provides overnight accommodations 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 the state when vessel is at least one 

nautical mile offshore and is traveling at least six knots. 

Class 2–CD: Provides overnight accommodations 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 marine waters of the state. 

Class 2-ND: Provides overnight accommodations for more than five hundred (500) 

and less than one thousand five hundred (1,500) passengers for hire 
Permit No.: 2007DB0002 

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and less determined with reference to the number of lower berths. No 

discharge of treated sewage, graywater, or other wastewater but may 

have other discharges of untreated wastewater (i.e., deck drainage) 

into marine waters of the state. 

Class 2-SD: Provides overnight accommodations 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 accommodations for more than one thousand five 

hundred (1,500) passengers for hire determined with reference to the 

number of lower berths. Continuously discharges into marine waters 

of the state. 

Class 3-ND: Provides overnight accommodations for more than one thousand five 

hundred (1,500) passengers for hire determined with reference to the 

number of lower berths. No discharge of treated sewage, graywater, 

or other wastewater but may have other discharges of untreated 

wastewater (i.e., deck drainage) into marine waters of the state. 

Class 3-SD: Provides overnight accommodations for more than one thousand five 

hundred (1,500) passengers for hire 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. 

This draft General Permit authorizes the discharge 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 department. 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 Alaska, 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 habitat Area” defined in 50 CFR 226.202, whichever 

is greater, without written permission from the Regional Director of the National Marine 

Fisheries Services. 
Permit No.: 2007DB0002 

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5. Any waterbody included in the ADEC CWA Section 305(b) report or effective CWA 

Section 303(d) list of waters which are “impaired” 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 discharge regulated by the Environmental Protection Agency at the 

time was treated sewage from the marine sanitation devices (MSDs). In Alaska graywater is 

regulated as sewage. 

Treated sewage, (from toilets) and graywater (from 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 standard and that graywater could have elevated 

fecal coliform levels. Following the initial sampling 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 fecal coliform per 100 milliliters. 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 MSDs was in compliance with both the fecal 

coliform and total suspended 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 analyzed for a suite of chemicals, called priority 

pollutants that would indicate if there was improper disposal of hazardous chemicals. Priority 

pollutants include metals and man-made organic compounds, including those used in industrial 

products or processes. A few priority pollutants were present at levels above water quality 

standards; however, there was not enough information to determine if exceedence had occurred. 

By the end of the 2005 cruise ship season, monitoring 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 

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http://www.dec.state.ak.us/water/cruise_ships/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 wastewater (prior to discharge) is 

called effluent. Effluent is defined in the definitions section of the draft General Permit as the 

segment of a treated sewage, graywater, or other wastewater stream that precedes discharge of 

the wastewater stream to the receiving environment. 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 municipal population & discharge 

volume from two small municipalities in southeast Alaska. 

 

Table 1: Comparison of Cruise Ship Discharges 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 Final Report (Activities through June 1, 2000)) 

Cruise ships have been working to improve the performance of their traditional marine sanitation 

devices (MSD) or replace them with new advanced wastewater treatment technologies. A 

discussion of the common wastewater treatment technology employed by the cruse ship industry 

in Alaska follows below. 

1. Wastewater Treatment Systems 

Although different in scale, cruise ship’s wastewater systems can be compared to municipal 

treatment systems that serve small Alaskan cities. Cruise ships are excluded from having to 

obtain permits under the Clean Water Act (CWA). However, their marine sanitation devices 

(MSDs) must meet the effluent standards established in Section 312 of the CWA. This section 

set the Type II MSD effluent standards for treated 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) clarification & filtration; and 

(3) final chemical disinfecting. All sludge is re-circulated to the activated sludge aeration section.

The raw sewage passes through a screen, which removes 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 waste in the sewage. The chamber contains air 

diffusers that provide oxygen to keep the aerobic bacteria healthy. 
Permit No.: 2007DB0002 

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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 contact 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 stream without dilution from graywater or storm 

water. Biological systems thrive on a constant, even flow of nutrients 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 treatment systems found on large commercial 

passenger vessels was taken from a report titled “Assessment of Cruise Ship and Ferry 

Wastewater Impacts in Alaska”, Alaska Department of Environmental Conservation Commercial 

Passenger Vessel Environmental Compliance Program, February 9, 2004 

A. Reverse Osmosis Filtration 

Osmotic theory implies pure water will move across 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 will flow in the reverse direction from the 

wastewater into the pure water. This phenomenon, known as reverse osmosis (RO), can separate 

pure water from contaminated matrices. ROCHEM treatment systems employing this process 

were installed on two ships that operated in Alaska during the 2001 season (Celebrity Mercury

sewage and Carnival Spirit graywater). Analysis of the effluent from the fully operational 

ROCHEM units indicated that suspended solids or fecal coliform 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 discharge anywhere in Alaska waters (except for 

blanket exclusion areas) including in port. Both systems use ultraviolet (UV) disinfection after 

the RO unit and were approved by the U.S. Coast Guard for stationary discharge during 2003. 

The sample points are both ships are less than 50 feet from the overboard 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 4 
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B. Bio-reactor/filtration 

These units employ an integrated system of enhanced aerobic digestion and low-pressure 

membrane filtration to treat blackwater and graywater. Currently, sixteen large cruise ships 

operating in Alaska have installed this process using Zenon, Scanship, or Hamworthy systems. 

After only a brief holding period in the bio-reactor, the Zenon system passes the influent through 

membrane filtration modules that have very large surface area and an extremely small pore size 

(0.035 micron or 0.035 X 10-6 meters). Wastewater then passes 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. This 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, samples 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 Standard of 7.5 ug/l. Princess has installed UV on 

two of their ships with the Hamworthy system and is considering substituting UV for chlorine 
Permit No.: 2007DB0002 

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disinfection on all ships in the future. Samples of this system were taken on the discharge line 

near the overboard port. Some samples 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 contamination 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 samples 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 and to conduct scientific analysis. Large vessels 

that discharged in Alaska took at least two compliance 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 established a Quality Assurance/Quality Control (QAQC) plan that 

ensures that the sample results are reliable. 
Permit No.: 2007DB0002 

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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 cruise ship regulations 

require third party sampling. ADEC regulations are consistent with other state wastewater 

programs and allow industry to collect samples using 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 wastewater samples. Small ship operators are not 

bound by the federal law but also chose 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 each ship is configured 

differently and follows unique wastewater management practices, the state also requires the 

owner/operator to submit a vessel specific sampling plan (VSSP). The VSSP plan, approved by 

ADEC before sampling begins, must demonstrate that the sample will be representative of the 

wastewater discharged from 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 Effluent Limits. The second method is Water 

Quality Based Effluent Limits (WQBEL). Technology-based limits are set according 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 standards applicable to a waterbody are being met and 

may be more stringent than technology-based effluent limits. 

Technology based limits for non-municipal dischargers are based upon Effluent Limitation 

Guidelines (ELGs). ELGs are national standards promulgated by the U.S. Environmental 

Protection Agency (EPA) that prescribe allowable discharges of pollutants from industrial point 

source categories corresponding to various levels of treatment or control technologies. Because 

large commercial passenger vessels 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 quality 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, exceptions to state-wide standards (18 AAC 70.200 

-.270), and Article 3, general provisions (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 Toxic 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.htm
Permit 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/L1 60 mg/L1 N/A Twice 

Monthly

Grab 

Settable Solids N/A 30 mg/L1 45 mg/L1 N/A Twice 

Monthly 

Grab 

Fecal Coliform 

Bacteria 

N/A 14 per 100 

mL1, 2 ,3 & 4

43 per 100 

mL1

N/A Twice 

Monthly 

Grab 

Total Residual 

Chlorine 

N/A N/A 0.0075 

mg/L1, 7

N/A Twice 

Monthly 

Field test 

Ammonia N/A N/A 20.06, 8 

mg/L 

N/A Twice 

Seasonally 

Grab 

Copper N/A N/A 0.0031 

mg/L5, 8

N/A Twice 

Seasonally 

Grab 

Lead N/A N/A 0.0081 

mg/L5, 8

N/A Twice 

Seasonally 

Grab 

Zinc N/A N/A 0.081 

mg/L5, 8

N/A Twice 

Seasonally 

Grab 

pH 6.5 S.U1 N/A 8.5 S.U1 N/A Twice 

Monthly 

Field test, 

grab, or 

continuous 

Total Suspended 

Solids 

N/A N/A 150 mg/L1 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 that 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 evaluation level for this parameter. Daily maximum concentrations 
Permit 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 contain 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 narrative 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 federal standard of 200 FC/100 ml. The draft 

General Permit proposes to incorporate the most restrictive standard, in this case the State of 

Alaska marine aquatic life water quality criterion 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 disinfect treated wastewater prior to discharge. The draft permit does 

not prohibit the discharge of chlorine 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, hypochlorous acid, or hypochlorite ions after the solution has reached a 

state of equilibrium. Combined residual chlorine is described as the portion 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 μg/L (acute criterion) and 7.5 μg/L (chronic criterion). The acute 

criterion is based upon a 24-hour average concentration. The chronic criterion 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 μg/L as the compliance 

evaluation level for this parameter. The permittee will be considered compliant with the total 

residual chlorine limitations if the average monthly and maximum daily chlorine concentrations 

are less than 100 μg/L. 

Ammonia 

Ammonia is present in two forms in saltwater: un-ionized ammonia (NH3) and the ammonium 

ion (NH4+). The un-ionized ammonia form has been demonstrated to be the more toxic form of 
Permit 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 Table IX in the Alaska Water Quality Criteria 

Manual for Toxics and Other Deleterious 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 μg/L dissolved copper in saltwater based on chronic 

effects to aquatic life and 4.8 μg/L for acute effects (Table IX in the Alaska Water Quality 

Criteria Manual for Toxics and Other Deleterious Organic and Inorganic Substances). The 

chronic criterion is based upon a four-day average. 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 saltwater based on chronic 

effects to aquatic life and 0.021 mg/L for acute effects (Table IX in the Alaska Water Quality 

Criteria Manual for Toxics and Other Deleterious Organic and Inorganic Substances). The 

chronic criterion is based upon a four-day average. 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 saltwater based on chronic 

effects to aquatic life and 0.090 mg/L for acute effects (Table IX in the Alaska Water Quality 

Criteria Manual for Toxics and Other Deleterious Organic and Inorganic Substances). The 

chronic criterion is based upon a four-day average. 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 natural conditions. This draft General Permit 

proposes to incorporate the most restrictive standard, in this case the State of Alaska criterion. 

Total Suspended Solids (TSS) 

The Alaska water Quality Standards does not contain 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 uniform monitoring requirement for all vessels to 

conduct monitoring twice monthly for all parameters with effluent limits. The draft General 

Permit proposes to maintain the twice seasonal requirements for those other parameters without 
Permit No.: 2007DB0002 

17

effluent limits that the CPVEC program previously required. This latter requirement mirrors the 

federal requirements for these parameters.