EPA842-R-07-005



# Cruise Ship Discharge Assessment Report

U.S. Environmental Protection Agency

Oceans and Coastal Protection Division Office of Wetlands, Oceans, and Watersheds

Office of Water 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

December 29, 2008ACKNOWLEDGMENTS AND DISCLAIMER

Today's Cruise Ship Discharge Assessment Report (Assessment Report) does not substitute for any statute or regulation, nor is it a regulation itself. The document assesses five primary cruise ship waste streams: sewage, graywater, oily bilg e water, solid waste, and hazardous waste. For each waste stream, the Assessment Report discusse s the nature and volume of the waste stream generated; existing federal regulations appl icable to the waste stream; environmental management, including treatment, of the waste st ream; potential adverse environmental impacts of the waste stream; on-going actions by the fede ral government to address the waste stream; and a wide range of options and alte rnatives to address the waste stream from cruise ships in the future. Discussion of existing regulations in this Assessment Report does not represent the consummation of the Agency's decision-making on the matters discussed. By its terms, the Assessment Report itself does not impose binding requirements on any party. The regulations themselves, not the Assessment Report, govern parties’ lega l obligations.

The primary contact regarding questions or comments on this document is:

Laura S. Johnson U.S. Environmental Protection Agency Oceans and Coastal Protection Division, OWOW (4504T) 1200 Pennsylvania Avenue, NW Washington, DC 20460

(202) 566-1273 (telephone) (202) 566-1546 (fax) johnson.laura-s@epa.govTABLE OF CONTENTS

Section 1: Introduction

1.1 Overview ................................................................................................................. ...1-1 1.2 Other EPA Cruise Ship Efforts ..................................................................................1-2 1.3 Applicable International Conventions a nd Related U.S. Laws and Regulations .......1-4

1.4 Federal Environmental Enforcement History Regarding Cruise Ships ......................1-6

1.5 Cruise Lines Interna tional Association’s Commitm ent to Reduce Potential Environmental Impacts ...............................................................................................1-7 1.6 Possible Options and Alternatives to Ge nerally Address Cruise Ship Discharges.....1-8

References .................................................................................................................... .....1-11

Section 2: Sewage 2.1 What is sewage from vessels and how much is generated on cruise ships?...............2-1 2.2 What federal laws apply to sewage from cruise ships? .............................................2-2 2.3 What technologies are available to treat sewage from cruise ships? .........................2-7 2.4 What are the potential environmental impacts asso ciated with sewage from cruise ships? ..................................................................................................... .2-23 2.5 What action is the federal government taking to address sewage from cruise ships?.................................................................................................................. .........2-41 2.6 Possible Options and Alternatives to Address Sewage from Cruise Ships ................2-43

References .................................................................................................................... .....2-46

Section 3: Graywater 3.1 What is graywater and how much is generated on cruise ships? ...............................3-1 3.2 What federal laws apply to gr aywater from cruise ships? .........................................3-4 3.3 Characterization of Untreated Graywater ...................................................................3-5 3.4 What are the potential environmental impacts asso ciated with untreated graywater from cruise ships? .....................................................................................3-19 3.5 What action is the federal governmen t taking to address graywater waste streams from cruise ships? .........................................................................................3-30 3.6 Possible Options and Alternatives to Address Graywater from Cruise Ships............3-32

References .................................................................................................................... .....3-34

Section 4: Oily Bilge Water 4.1 What is bilge water and how much is generated on cruise ships? .............................4-1 4.2 What federal laws apply to bi lge water from cruise ships? .......................................4-3 4.3 What technologies are available to manage oily bilge water from cruise ships? .......................................................................................................... .....4-7 4.4 What are the potential environmental impacts associ ated with inadequately treated bilge water from cruise ships? .......................................................................4-11 4.5 What action is the federal government ta king to address oily bilge water from cruise ships? .......................................................................................................... .....4-144.6 Possible Options and Alternatives to Address Oily Bilge Water from Cruise Ships ............................................................................................................ ....4-16

References .................................................................................................................... .....4-19

Section 5: Solid Waste

5.1 What is solid waste and how much is generated on cruise ships? .............................5-1 5.2 What federal laws apply to so lid waste from cruise ships? .......................................5-3 5.3 What practices are available to manage solid wastes generated on cruise ships? .....5-8 5.4 What are the potential environmental impacts associ ated with solid waste from cruise ships? ..................................................................................................... .5-10 5.5 What action is the federal governmen t taking to address solid waste from cruise ships? .......................................................................................................... .....5-12 5.6 Possible Options and Alternatives to A ddress Solid Waste from Cruise Ships .........5-14

References .................................................................................................................... .....5-17

Section 6: Hazardous Waste

6.1 What is RCRA hazardous waste and how much is landed by cruise ships to

the United States? ..................................................................................................... .6-1 6.2 What federal laws apply to ha zardous waste on crui se ships? ...................................6-4 6.3 What practices are available to manage hazardous wastes generated on cruise ships? .......................................................................................................... .....6-9 6.4 What are the potential environmental impacts asso ciated with hazardous waste from cruise ships? ............................................................................................6-1 0 6.5 What action is the federal governm ent taking to address hazardous waste from cruise ships? ..................................................................................................... .6-11

6.6 Possible Options and Alternatives to Address Hazardous Waste from Cruise Ships ............................................................................................................ ....6-12

References .................................................................................................................... .....6-15LIST OF FIGURES, TABLES, AND APPENDICES

Figure 2-1. Per Capita Sewage Generati on as Reported in EPA’s 2004 Cruise Ship Survey ................................................................................................................... ....2-2 Figure 2-2. Sewage Generation by Persons Onboard as Reported in EPA’s 2004 Cruise Ship Survey ..................................................................................................2-2 Figure 2-3. Simplified Schematic of Trad itional Type II Marine Sanitation Device Using Biological Treatment and Chlorine Disinfection .......................................2-8 Table 2-1. Comparison of Traditional Type II MSD Effluent Concentrations

to Untreated Domestic Wastewater -- Conventiona l Pollutants and Other Common Analytes ............................................................................................................2-9 Table 2-2. Traditional Type II MSD Effl uent Concentrations -- Metals ..............................2-10 Table 2-3. Traditional Type II MSD Efflue nt Concentrations -- Volatile and Semivolatile Organics .......................................................................................................2-11 Table 2-4. Comparison of Traditional Type II MSD Effluent Concentrations

to Untreated Domestic Wa stewater -- Ammonia ..............................................................2-11

Table 2-5. AWT Effluent Concentrations and Removals -- Pathogen Indicators ................2-15

Table 2-6. AWT Effluent Concentrations and Removals -- Conventional Pollutants

and Other Common Analytes ............................................................................................2-16

Table 2-7. AWT Effluent Concentrat ions and Removals -- Metals .....................................2-18

Table 2-8. AWT Effluent Concentrations a nd Removals -- Volatile and Semivolatile Organics ...................................................................................................................... ......2-19

Table 2-9. AWT Effluent Concentrations and Removals -- Nutrients .................................2-20

Table 2-10. AWT Waste Biomass Concentr ations for Selected Analytes ............................2-22 Table 2-11. Comparison of AWT and Trad itional Type II MSD Effluent to Wastewater Discharge Standards ......................................................................................2-24 Table 2-12. National Recommended Water Qu ality Criteria for Bacteria ...........................2-27

Table 2-13. Narrative National Recomme nded Water Quality Criteria for

Conventional Pollutants and Other Common Analytes ....................................................2-28 Table 2-14. Seasonal Coastal Water Temperatur es in °C Across the United States ............2-30 Table 2-15. Comparison of Traditional T ype II MSD and AWT Effluent to Numeric National Recommended Water Qual ity Criteria for Total Residual

Chlorine ...................................................................................................................... .......2-31 Table 2-16. Comparison of AWT Efflue nt to National Recommended Water Quality Criteria for Metals ................................................................................................2-3 2 Table 2-17. Comparison of Traditional T ype II MSD Effluent to National Recommended Water Quality Criteria for Semivolatile and Volatile Organics ...............2-32 Table 2-18. Comparison of AWT Efflue nt to National Recommended Water Quality Criteria for Semivolatil e and Volatile Organics ..................................................2-33

Table 2-19. Ammonia Concentration in Traditional Type II MSD and AWT

Effluent ...................................................................................................................... .......2-34

Table 2-20. Calculated Amm onia NRWQC for Some Cruise Ship Ports of Call

in the United States .......................................................................................................... .2-34

Table 2-21. Hawaii Nutrient Criteria Valu es Which the Geometric Mean of Samples Is Not to Exceed .................................................................................................2-36Table 3-1. Graywater Definitions ..........................................................................................3-1

Table 3-2. Common Sources and Char acteristics of Graywater ...........................................3-2 Figure 3-1. Per Capita Graywater Generati on as Reported in EPA's 2004 Cruise Ship Survey ................................................................................................................... ....3-3 Figure 3-2. Graywater Generation by Pers ons Onboard as Reported in EPA's 2004 Cruise Ship Survey ..................................................................................................3-3 Table 3-3. Comparison of Untreated Gray water Concentrations to Untreated

Domestic Wastewater -- Pathogen Indicators ...................................................................3-7 Table 3-4. Comparison of Untreated Gray water Concentrations to Untreated

Domestic Wastewater -- Conventional Po llutants and Other Co mmon Analytes ............3-9 Table 3-5. Untreated Graywater Concentrations -- Metals ...................................................3-12 Table 3-6. Untreated Graywater Concentr ations -- Volatile and Semivolatile Organics ...................................................................................................................... ......3-16 Table 3-7. Comparison of Untreated Gray water Concentrations to Untreated

Domestic Wastewater -- Nutrients ....................................................................................3-18 Table 3-8. Comparison of Untreated Crui se Ship Graywater to Wastewater Discharge Standards ..........................................................................................................3 -19 Table 3-9. National Recommended Water Qu ality Criteria for Bacteria .............................3-21

Table 3-10. EPA and ACSI Untreated Cruise Ship Graywater Pathogen

Indicator Data................................................................................................................. ....3-22

Table 3-11. Narrative National Recomme nded Water Quality Criteria for

Conventional Pollutants and Other Common Analytes ....................................................3-22 Table 3-12. Seasonal Coastal Water Temper atures in °C Across the United

States ........................................................................................................................ .........3-24 Table 3-13. Comparison of Untreated Cruise Ship Graywater to Num eric National Recommended Water Quality Criter ia for Total Residual Chlorine ..................3-25 Table 3-14. Comparison of Untreated Cr uise Ship Graywater to National Recommended Water Quality Criteria for Metals ............................................................3-26 Table 3-15. Comparison of Untreated Cr uise Ship Graywater to National Recommended Water Quality Criteria for Se mivolatile and Volatile Organics ...............3-27

Table 3-16. Ammonia Concentratio n in Untreated Graywater .............................................3-28

Table 3-17. Calculated A mmonia NRWQC for Som e Cr uise Ship Ports of

Call in the United States ...................................................................................................3- 28

Table 4-1. Maxim um Daily Volume of Bilge Water Production .........................................4-3 Table 4-2. Oily Water Se parator Technologies ....................................................................4-9 Table 4-3. Description of Oil Types and the Interaction When Released into the Marine

Environment.................................................................................................................... ...4-12

Table 5-1. Some Types and Specific Examples /Descriptions of Solid Waste Generated on Cruise Ships ................................................................................................................ ..5-2 Table 5-2. Estimates of Solid Waste Generated Per Vessel per Week .................................5-2Table 5-3. Estimates of Solid Waste Generated per Person per Day on a Cruise Ship .......................................................................................................................... .........5-3 Table 5-4. Summary of Garbage Discha rge Restrictions for Vessels ..................................5-5 Table 5-5. Waste Management Practices as Reported by Royal Caribbean Cruises ............5-9

Table 6-1. Types of Potentially Hazar dous Waste Generated Aboard Cruise Ships ......................................................................................................................... .........6-2

Table 6-2. Estimates of Hazardous Waste Generated Per Week Onboard Cruise Ship Fleets.................................................................................................................... ......6-3

Table 6-3. Estimates of Hazardous Waste and Solid Waste Generated Onboard as Reported by Carnival Cruise Lines....................................................................................6-4 Table 6-4. Classification System and Accumulation Limits for Hazardous

Waste Generators .............................................................................................................. 6-7

Appendix A. List of Acronyms..............................................................................................7-1 Appendix B. State Efforts to Address Discharges from Cruise Ships...................................7-5December 29, 2008



### Section 1: Introduction

1.1 Overview

Cruise ships operate in every ocean worldwide, often in pristine coastal waters and sensitive marine ecosystems. Cruise ship operators provide amenities to their passengers that are similar to those of luxury resort hotels, including pools, hair salons, restau rants, and dry cleaners. As a result, cruise ships have the poten tial to generate wastes similar in volume and character to those generated by hotels.

The cruise industry is one of the world’s fastes t growing tourism sectors, with the number of cruise ship passengers growing n early twice as fast as any other travel sector over the last 10 years (CELB, 2003). In addition, average ship si ze has been increasing at the rate of roughly 90 feet every five years over the past two d ecades (Bell, 2007). Larger cruise ships can accommodate even more passengers, as well as the crew necessary to service the passengers and maintain the ships. According to Macleod (2007), the next generation of ships, the first of which will be ready in 2009, will carry mo re than 8000 passengers. As the cruise industry continues to expand, there is an increasing concern about th e impacts cruise ships may have on the marine environment, including water qualit y and other marine resources.

In March 2000, an environmental advocacy group called the Bluewater Network, representing 53 environmental organizations, submitted a petition to the U.S. Environmental Protection Agency (EPA) requesting that EPA identify and take regulatory action on measures to address pollution by cruise ships. Specifically, th e petition requested an in-depth assessment of the volumes and characteristics of cruise ship waste streams; an alysis of their potential impact on water quality, the marine environment, and human health; examination of existing federal regulations governing cruise ship waste streams; and fo rmulation of recommendations on how to better control and regulate these waste streams. The pe tition also included specific requests related to sewage, graywater, oily bilge water, solid wast es, and hazardous wastes, as well as monitoring, record-keeping, and reporting. In addition, the pe tition requested that EPA prepare a report of the requested assessment. In August 2000, the Bluewater Network submitted an addendum to the petition regarding air pollution from cruise ships. EPA subse quently denied this portion of the petition as unnecessary, in light of the Agen cy’s pending Clean Air Act actions for marine diesel engines.

This Cruise Ship Discharge Assessment Report (Assessment Report) concludes EPA’s response to the petition from Bluewater Network. This Assessment Report examines five primary cruise ship waste streams -- sewage, graywater, oily bilg e water, solid waste, and hazardous waste. For each waste stream, the Assessment Report discusses (1) what the waste stream is and how much is generated; (2) what laws apply to the waste stream; (3) how the waste stream is managed; (4) potential environmental impacts of the wast e stream; (5) on-going actions by the federal government to address the waste stream; and (6) a wide range of options and alternatives to address the waste stream from cruise ships in th e future. Though this report includes discussion of some proprietary treatment tec hnologies for the abatement of pollution from cruise ships, that

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discussion in no way constitutes an endorsement by EPA of any non-federal entity, its products,

or its services.

The most significant new analysis provided in th is Assessment Report relates to the generation and treatment of sewage and graywater onboard crui se ships. Pursuant to federal legislation entitled “Certain Alaskan Cruise Ship Operatio ns” (33 U.S.C. 1901 Note), EPA has carried out a multi-year project to determine whether revised or additional standards for sewage and graywater discharges from large cruise ships operating in Alaska are warranted u nder that legislation.

Much of the information and data collected for the Alaska effort are summarized in this Assessment Report.

There are a number of other wast e streams that may be generated onboard cruise ships, some of which may be considered incidental to the normal operation of a vessel (e. g., ballast water, deck runoff, hull coat leachate). This Assessment Re port does not present an assessment of any of these other waste streams. However, as pa rt of a separate effort, on December 19, 2008, EPA finalized a Vessel General Permit (VGP) under s ection 402 of the Clean Water Act (CWA) for discharges incidental to the normal operation of a vessel. On July 31, 2008, the President signed legislation (Pub. L. 110-299) that, except for ballast water, exempts commercial fishing vessels (of any length) and other commercial vessels shor ter than 79 feet from CWA permitting for such discharges for a period of two years (during whic h time EPA has been directed to conduct further study and analysis). Under a court decision, effective December 19, 2008, absent a statutory exclusion such as provided by Pub. L. 110-299, disc harges incidental to the normal operation of commercial vessels will no longer be excluded from CWA permitting requirements. Thus, the VGP will include discharges incidental to the norma l operation of cruise ships 79 feet or more in length, and such discharges will become subject to CWA permitting requirements as of December 19, 2008.

1.2 Other EPA Cruise Ship Efforts

In addition to developing this Assessment Repor t, EPA has engaged in a number of activities addressing the potential environmen tal impacts of cruise ships. These efforts are summarized

below.

Cruise Ship White Paper, August 2000 This White Paper provided preliminary informati on regarding cruise ship discharges and waste management practices in response to the peti tion submitted by the Bluewater Network on March 17, 2000. The White Paper can be accessed at: www.epa.gov/owow/oceans/cruise_ships/white_paper.pdf.

Cruise Ship Public Hearings, September 2000 As part of its effort to gather information on cruise ship discharges and waste management practices, EPA, together with the Coast Guard an d other federal agencies, solicited public input from industry officials, government agencies , environmental groups, and concerned citizens through three regional p ublic information hearings in Los Angeles, CA (September 6, 2000);

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Juneau, AK (September 8, 2000); and Miami, FL (September 12, 2000). Summaries and transcripts of these public hearings can be accessed at: www.epa.gov/owow/oceans/cruise_s hips/publichearings.html.

Cruise Ship Plume Tracking Survey, Summer 2001 EPA conducted a survey to study the dilution of disc harges from cruise ships in June 2001. This survey tracked plumes of water containi ng Rhodamine WT dye released through normal wastewater effluent discharge systems in ships operating off the Florida coast to provide information on dilution of cruise ship discharges in offshore waters. This survey also provided preliminary information on whether cruise ship treated sewage or graywater discharge plumes behave as predicted by a model developed for Al aska waters. The Crui se Ship Plume Tracking Survey Report can be accessed at: www.epa.gov/owow/oceans/cruise_shi ps/plum erpt2002/plumereport.pdf

. The Cruise Ship Plum e Tracking Survey Plan can be accessed at: www.epa.gov/owow/oceans/cruise_ships/surveyplan.pdf.

Cruise Ship Hazardous Waste Tracking System, December 2001 On December 4, 2001, EPA Headquarters requeste d that the Agency’s Regions assign a single tracking number for each cruise ship entering waters of multiple states for purposes of the Resource Conservation and Recovery Act (RCR A). RCRA imposes management requirements on generators, transporters, and other handlers of hazardous waste. Cruise ships regularly use chemicals for operations ranging from routine ma intenance to passenger services, such as dry cleaning, beauty parlors, and phot ography labs. Thus, cruise ship s are potentially subject to RCRA requirements to the extent those chemicals result in the generation of hazardous wastes. Under RCRA, each state assigns a hazardous waste tracking number to each cruise ship that enters its waters. However, assignment of tr acking numbers by multiple states can result in a single ship having several different tracking num bers for the same waste. Assigning a single tracking number for each cruise ship entering waters of multiple states for purposes of RCRA should result in improved tracking of hazardous wastes generated on cruise ships, increased compliance with RCRA requirements, as well as reduce paperwork for the cruise ships. The EPA memorandum of December 4, 2001, can be accessed at: www.epa.gov/owow/oceans/cruise _ships/haz_tracking.html.

Evaluation of Standards for Sewage and Graywa ter Discharges from Cruise Ships in Alaska On December 12, 2000, Congress passed HR 4577, “D epartments of Labor, Health and Human Services, and Education, and Related Agenci es Appropriations Act, 2001,” which contained Title XIV, a section called “ Certain Alaskan Cruise Ship Operations ” (33 U.S.C. 1901 Note) (Title XIV). Title XIV e stablished enforceable discharge standards for sewage and graywater from large cruise ships (those authorized to carry 500 or more passengers for hire) while operating in the Alexander Archipelago and the navi gable waters of the United States in the State of Alaska and within the Kachemak Bay Nati onal Estuarine Research Reserve. This law authorizes EPA to develop revise d and/or additional standards fo r these discharges in Alaska.

Pursuant to Title XIV, EPA has carried out a multi-year project to determine whether revised and/or additional standards for sewage and gr aywater discharges from large cruise ships operating in Alaska are warrant ed under that law. EPA sampled wastewater from four cruise

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ships that operated in Alaska during the summers of 2004 and 2005. The purpose of this sampling was to characterize graywater and se wage generated onboard and to evaluate the performance of various advanced sewage and gray water treatment systems. EPA also distributed a “Survey Questionnaire to Determine the Effect iveness, Costs, and Impacts of Sewage and Graywater Treatment Devices for Large Cruise Sh ips Operating in Alaska” to all cruise ships authorized to carry 500 or more passengers fo r hire that operated in Alaska in 2004. The information collected by the survey includes gene ral vessel information; sources of graywater and sewage; ship-board plumbing systems; data on the effectiveness of sewage and graywater treatment systems in removing pollutant s; and costs of these systems.

Using these sampling results, survey responses , and other relevant information, EPA is performing environmental, economic, and engineeri ng analyses to determin e whether revised or

additional standards in Alaska are warranted under Title XIV. EPA anticipates announcing its determination and making its analyses publicly av ailable in 2009. Much of the information and

data collected for EPA’s effort under Title XIV are summarized in this Assessment Report. Additionally, as part of this effort, EPA in conjunction with the Alaska Department of Environmental Conservation, conducted a scientif ic survey in July 2008 using EPA’s Ocean Survey Vessel Bold to (1) measure the d ilution of Advanced Wast ewater Treatment (AWT) discharges from stationary cruise ships, and (2 ) evaluate the potential environmental impact of nutrients in AWT discharges. EPA anticipates making the results of these studies publicly

available in 2009. More information, including EPA’ s 2004 and 2005 Alaska cruise ship sampling results, EPA’s Generic Sampling and Anal ysis Plan, and EPA’s cruise ship survey questionnaire, can be accessed at: www.epa.gov/ owow/oceans/cruise_ships/sewage_gray.html.

1.3 Applicable International Conventions and Related U.S. Laws and Regulations

Because of the international natu re of maritime commerce, many of the customs, practices, rules, and regulations associated with vessel ope rations including manni ng, construction, design, equipment, safety, and pollution prevention are developed through uniform international agreements and conventions. A majority of crui se ships operating in United States waters are flagged in foreign nations, and application of domestic laws proceeds from an international agreement to which the United States is a pa rty. In 1948, the United Na tions established the predecessor to the Intern ational Maritime Organization, which entered into full force in 1958, to promote cooperation among governments and the sh ipping industry, to improve maritime safety, and to prevent marine pollution.

One of the major international agreements relevant to cruise ship pollution is the International

Convention for the Prevention of Pollution from Sh ips, as modified by the Protocol of 1978, also

known as MARPOL 73/78 , or simply MARPOL. Six Annexes of the Convention cover various sources of pollution from ships and provide a fr am ework for international objectives. However, these Annexes are only in force when ratified and implemented by the flag state. The vast majority of cruise lines operati ng in United States ports are fore ign flag vessels. Cruise ships flagged under countries that ar e signatories to MARPOL are subject to its requirements, regardless of where they sail, and member natio ns are responsible for vessels registered under their respective nationalities.

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The Act to Prevent Pollution from Ships (APPS; 33 U.S.C. § 1901 et seq.) is the federal law implementing those provisions of MARPOL that have been ratified by the United States. APPS applies to all U.S. flagged ships anywhere in th e world, and to all foreign flagged vessels while operating in the navigable waters of the United St ates or while at a port or terminal under the jurisdiction of the United States. Additionall y, MARPOL Annex V requirements are applicable

in the exclusive economic zone. The Coast Guar d generally has the prim ary responsibility to prescribe and enforce the regulations necessary to implement APPS in the United States.

This report provides detail regarding relevant MARPOL provisions in subsequent chapters; MARPOL includes annexes addressing, among other things, oil pollution, sewage, and garbage. MARPOL is implemented domestically through APPS (33 U.SC. 1901 et seq.), and the regulations found at 33 CFR Subchapter O -- Pollution. Additionally, the International Convention for the Safety of Life at Sea (SOLAS), which addresses maritime safety with a wide range of m easures to improve vessel safety including design, construction, and equipment standards, includes provisions fo r a vessel to have a pollution pr evention policy as part of its Safety Management System (SMS).

A vessel operating internationally under the flag of a country that is a party to SOLAS must develop and maintain onboard an SMS. SMS doc uments are developed consistent with the International Safety Management (ISM) Code. The functional requiremen ts of the SMS include, among other things, procedures for internal a udits on the operation of the SMS, as well as procedures and processes for management revi ew of company internal audit reports and correction of non-conformities that are reported by these or other reports (33 CFR 96.240(f) and (g)). The SMS also documents the responsible person’s safety and pollution prevention policy (33 CFR 96.220(a)(1)). Domestica lly, large passenger vessels that operate internationally are required to develop and retain such SMS doc uments onboard (46 U.S.C. §§ 3203-05 and 33 CFR Part 96). If the vessel does not have a Safety Management Certificate or copy of the Document of Compliance (DOC), the vessel is subject to detention, civil pena lty, and if tryi ng to enter the port, denial of port entry (33 CFR 96.380(b) and (c) and 96.390). In addition, the Coast Guard can board a vessel to ensure that crew and pers onnel are following the procedures of the SMS while a vessel is operating in U.S. waters ( 33 CFR 96.380(a)(2)). If a vessel’s crew or shorebased personnel do not follow the SMS plan, a vesse l may be detained in port or, in some cases, denied entry (46 U.S.C. § 3205(d); 33 CFR 96.380-.390). Substantial non-compliance of a ship’s SMS to the requirements of the ISM Code is indicative of a ma jor non-conformity (ISM Code 1.1.10). By definition, a major non-conformity is a deviation from SMS requirements that poses a serious threat to personnel or ship safet y, or a serious risk to the environment; it requires immediate corrective action. For U.S. vessels, the SMS and DOC certifi cates are subject to revocation for non-compliance (33 U.S.C. § 32 05(c)). Though failure to maintain SMS documents onboard a vessel is subject to a civil penalty, United States Co de does not provide for administrative, civil, or criminal penalties, or injunctive remedies, for failure to follow the SMS plan. Several cruise ships with robust environm ental standards as part of their SMS have been criminally prosecuted for deliberate substantiv e MARPOL and CWA violations, as well as for negligent violations.

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Each flag state is responsible for ensuring that vessels operating under its flag are in compliance with their SMS. Often, flag states establish cr iteria and procedures for third party organizations to act on their behalf to perform safety mana gement audits and certification functions that otherwise would be conducted by the flag stat e (as mentioned above, the Coast Guard has done this for U.S. flagged ships; see 33 CFR 96.400(a)). Cruise lines sometimes rely on third party verification companies (also known as classificati on societies) such as Det Norske Veritas, Lloyds Register, and the American Bureau of Sh ipping to certify that SMS documents conform with applicable requirements. If a foreign vess el (most cruise ships) has a major non-conformity under the ISM Code, the vessel is subject to detention and deni al of port entry (33 CFR 96.380).

1.4 Federal Environmental Enforcement History Regarding Cruise Ships

As part of a wide-ranging ve ssel pollution initiative begun in 1993, the U.S. Department of Justice, in conjunction with the Coast Guard an d Environmental Protection Agency’s Criminal Investigation Division, has worked on a vessel pollution enforcement initiative designed to detect, investigate, and prosecute illegal vessel discharges of oily wastes, plastics, and other

wastes that are in violation of U.S. en vironmental laws, including those implementing international treaties, as well as related crimin al violations. Relevant federal environmental statutes include CWA, APPS, RC RA, the Ports and Waterways Safety Act, and recent legislation addressing Certain Alaskan Cruise Ship Operations, several of whic h are discussed further in this Assessment Report. The federal enforcement effort has resulted in numerous criminal convictions of every segment of the maritime in dustry, including the cruise ship industry, for knowing violations of these environmental statutes.

All large cruise ships calling on U.S. ports ar e subject to the requirements of MARPOL and APPS, and are required to have an SMS addres sing pollution prevention. However, the lack of enforcement of these requirements by individual cr uise ships has resulted in criminal violations

of the law. Convictions for environmental pollution by cruise lines were obtained in 1995, 1998, 1999, 2000, 2001, 2002, 2004, and most recently in 2006.

The United States has obtained convictions for de liberate environmental crimes, false statements, and obstruction of justice by the la rgest cruise lines operating the largest cruise ships, as well as some smaller cruise lines operating smaller vessels . The most common violations consist of the knowing and willful making of materi ally false statements in a ship ’s Oil Record Books (a log in which all overboard discharges are required to be recorded) in order to conceal intentional discharges made in violation of MARPOL (see subsection 4.2.1). The cruise ship prosecutions

have involved as much as hundreds of thousands of gallons of oil-contaminated waste per ship per year, and in some cases have involved viol ations of multiple ships in a fleet. Other

convictions have involved the de liberate discharge of pollutant s without a permit within the navigable waters of the United States, including specifically, wa ste oil, plastics, sewage, and hazardous chemicals such as dry cleaning solv ents, printing solvents, and photochemicals discharged through graywater systems in violation of CWA.

In most cases, environmental violations, includi ng cruise ships with falsified logs and use of equipment and procedures to bypass treatment syst ems, were not previously discovered during

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prior, numerous inspections by port states, the vessel’ s flag state, or classification society. These prosecutions are widely credited with helping to raise awareness within the cruise ship industry of the importance of environmental compliance, and have led to the installation of new equipment on many ships. Convicted companie s were placed on probation and required to develop and implement enhanced environmental compliance measures, including additional

outside audits.

1.5 Cruise Lines International Association’s Commitment to Reduce Potential Environmental Impacts

The Cruise Lines International Association (CLIA) is a trade association formed in 1975 to promote the benefits of cruising. According to CLIA, it is now the world's largest cruise association, comprising 24 major cruise lines se rving North America an d representing 97% of the cruise capacity marketed from North America. CLIA reports that member companies have agreed to adopt voluntary CLIA e nvironmental standards for their cruise ships. According to CLIA, these environmental standards exceed the requirements of U.S. and international laws (CLIA, 2003). CLIA reports th at the standards address, am ong others, the following waste streams: graywater and blackwater (sewage) discharges; bilge and oily water residues; incinerator ash; hazardous ch emical waste such as photo pr ocessing fluid and dry-cleaning chemicals; unused and outdated pharmaceutical s; used batteries; burned out fluorescent and mercury vapor lamps; and glass, cardboard, and aluminum and steel cans. The CLIA standards entitled, “Cruise Industry Waste Ma nagement Practices and Procedur es,” include an attachment reflecting a 2006 revision (CLIA, 2006). Implemen tation of the CLIA membership commitment

to address these waste streams is intended to o ccur via incorporation of the CLIA environmental protection policies into responsible persons’ SMS documents.

CLIA has acknowledged violations of environmental laws by cruise lines, a nd believes that these violations have served as an important warning fo r the industry. As a result of the violations and associated penalties, CLIA member lines have strengthened their environmental policies and procedures. CLIA reports, for example, that its members have committed to the following principles:

 Designing, constructing, and ope rating vessels to minimi ze their impact on the environment;

 Developing improved technologies to exceed cu rrent requirements for protection of the environment;

 Implementing a policy goal of zero discharge of MARPOL Annex V solid waste products (garbage) by use of more comprehensive wa ste minimization procedures to significantly reduce shipboard-generated waste;

 Expanding waste reduction strategies to in clude reuse and recycling to the maximum extent possible, to depo sit smaller quantities of waste products ashore;

 Improving processes and procedures for collectio n and transfer of hazardous waste; and

 Strengthening comprehensive programs for monitoring and auditing of onboard environmental practices and procedures, in accordance with the ISM Code for the Safe Operation of Ships and for Pollution Prevention.

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The CLIA environmental standards are designed to increase compliance with regulatory regimes, and in some cases incorporat e voluntary standards and pro cedures that go beyond what is required by law or regulation. CLIA does not describe the manner in which the voluntary standards are to be implemented into a company’s SMS, or impose consequences for failing to incorporate the standards into a member line ve ssel’s SMS, or comply with the standards once incorporated. Further, the standards do not provide for a CLIA-sponsored inspection or verification mechanism. All cruise ships that were criminally convicted had incorporated

environmental standards into their SMS. Although CLIA standards are discussed in the subsequent sections of this report, EPA does not have an independent basis to determine the nature and extent of compliance by CLIA member lines, which is not required by state or federal law. Nevertheless, EPA appreciates efforts by th e cruise ship industry and regulated community to improve the environmental compliance by CL IA member lines, and hopes that the waste management measures undertaken by the cruise line industry will benefi t the environment and will set an example for cruise ship operators that are not members of CLIA.

1.6 Possible Options and Alternatives to Ge nerally Address Cruise Ship Discharges

Based on the public comments receiv ed on the draft of this report as well as other information gathered, listed below are a wide range of options and alternatives that address cruise ship waste streams generally, rather than any particular waste stream (i.e., sewage, gray water, oily bilge water, solid waste, or hazardous waste) specifically. Identifica tion of any particular option does not imply any EPA recommendation or preference fo r future action, or that EPA has determined that any of these options are necessary or feasib le, or that EPA believes a change to the status quo is warranted, or that EPA or a ny other entity has the legal author ity to implement that option.

Research

 Establish a detailed nationwide sampling, tes ting, and monitoring program to gather data on the volume of discharges, concentration of pollutants or effluent, and locations of most frequent discharges in term s of volume and/or toxicity.

 Conduct a programmatic environmental review of the cruise industr y under the National Environmental Policy Act to assess the full breadth of environmental and cumulative impacts from cruise ships on the marine environment and human health.

 Increase studies on the detriment to human h ealth and the effect on the nation’s coastal zones and marine protected areas, including an alysis of cumulative impacts, from cruise ships.

 Continue research and development on pr omising treatment technologies for the management of cruise ship waste steams.

 Engage the cruise ship industry to conduct more research directed at cruise ship discharges.

 Direct research to geographi c areas that may be impacted by cruise ship discharges.

 Require additional analyses to further understand ship discharge impacts on the beachgoing public.

 Direct future assessments of cruise ship discharges to the potential cumulative impacts from multiple cruise ships, the impacts of discharges from stationary cruise ships, and the

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impacts of discharges on en closed and low-flushing envir onments, such as bays and

harbors.

 Design cruise ships to be “environmentally friendly.”

Enforcement and Compliance

 Improve monitoring and inspections.

 Strengthen established enforcement mechanisms.

 Reward passengers who aid in the detection of illegal activ ities by alerting authorities.

 Provide instruction regarding duties, res ponsibilities, and operation of the various equipment and waste management systems to those directly responsible for processing wastes. Actions to train employees and increase passenger awareness should include:

o announcements over the public address system and notices in ship newsletters that caution against throwing any waste overboard;

o signage and posters placed in crew and passenger areas that encourage environmental awareness and protection;

o placing safety and environmental informa tion booklets in crew cabins and crew lounges; and

o regular meetings of ship safety and environmental committees consisting of officers and crew from all departme nts to review methods of improving performance, including better and more effective environmental practices.

 Charge a passenger fee to put a marine engine er onboard cruise ships, especially when sailing in pristine waters, to observe sh ip waste treatment practices, verify logbook entries, examines discharges, and ensure that the ships are maintaining their waste water

treatment systems.

 Allow for state personnel to inspect cruise sh ip pollution control equipment, in addition to Coast Guard inspections.

 Encourage a uniform national approach for envi ronmental regulations pertaining to cruise ship discharges to reduce conflicting regulati ons as cruise ships travel from port to port.

 Encourage discussions with the Coast Guard and industry to ensure that proposals for new regulations are operationally feasible and will not compromise vessel safety.

 Require cruise ships to immedi ately report discharges (both intentional and accidental) of wastes into state waters or into waters immediately adjacent to state waters.

Industry Standards Development for Cruise Lines

 Work with CLIA and/or other cruise ship trad e associations or indi vidual cruise lines to further develop waste management practices and procedures to be incorporated into Safety Management System plans. Enhan ced practice and procedures could include:

o establishing discharge standards st ricter than presently required;

o setting voluntary standards wh ere none exist now; and

o regular sharing of infor mation with th e public on environmental performance.

 Encourage cruise line trade associations to develop verification mech anisms that assure industry standards, practices, and procedur es for pollution abatement are implemented faithfully, as well as specify and enfor ce adverse consequences for inadequate implementation of those standards.

 Offer public recognition to cruise ships that implement environmentally-friendly practices beyond what is cu rrently required. The volunt ary program could include:

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o discharge standards stricter than required (for sewage , gray water, oily bilge water, and others);

o setting voluntary standard s where none exist now;

o requirements for the use of low-sulfur fuel and emission control technologies;

o an agreement to prohibit the discharg e of any solid waste to the marine environment;

o collection and sharing of da ta on characteristics and vol umes of discharges and environmental impacts;

o independent third-party ve rification of implementation of waste management practices; and

o a Code of Conduct or incentives prog ram to encourage pollution prevention

conduct.

Other

 Encourage verifiable “beyond compliance” agreements between states and individual cruise lines pertaining to cruise ship discharges into state waters.

 Encourage verifiable “beyond compliance” agreements between individual port

authorities and individual cruise lines pertaining to cr uise ship discharges into waters near

ports.

 Facilitate cooperative efforts to increase the availability of port reception facilities for all

waste types.

 Establish an interagency Cruise Ship Po llution Prevention and Enforcement Program:

o assign a lead agency to implement the program, including on-board inspections;

o work within existing regulatory and enforcement programs through cross-media coordination; and

o assess a regulatory fee to fund the program.

 Charter and convene a cruise ship Federa l Advisory Committee Act committee (perhaps consisting of EPA, Coast Guard, industry, public interest groups , states, and other appropriate shareholders) to develop impr oved environmental performance by cruise ships.

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1-11 References

Bell, Tom. 2007 (September 28). Experts: Mega-berth needed for cruise ships. Portland Press

Herald . ( www.pressherald.mainetoday.c om /story_pf.php?id=137059&ac=PHnws )

Center for E nvironmental Lead ership in Business (CELB). 2003. A Shifting Tide: Environmental Challenges and Cruise Industry Responses. Washington, DC. ( www.celb.org/ImageCache/CELB/content/travel _2dleisure/cruise_5finterim _5fsummary _2epdf/v1/cruise_5finterim_5fsummary.pdf )

Cruise Lines Internationa l Association (CLIA). 2003. ICCL Media Statement on Pending Californ ia Legislation . ICCL News Release Arch ives. Arlington, Virginia. (http://www.cruising.org/pres s/press-kits/news/CLIAICCL_archivesArticle.c fm?type=a&pressID=14)

Cruise Lines Internationa l Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry Waste Management Practices and Procedures . Fort Lauderdale, FL. ( www.cruising.org/industry/PDF/CLIA W asteManagementAttachment.pdf and www.cruising.org/industry/PDF/ CLIAW asteManagement.pdf )

Macleod, A ndrew. 2007. Cruise on down to our dumping ground

. ( http://www.straight.com/article-86 446/cruise-on-down-to-our-dum ping-ground )December 29, 2008



### Section 2: Sewage

Sewage from vessels, also known as “black water,” generally means human body wastes and the

wastes from toilets and other receptacles intended to receive or retain body wastes . On most cruise ships, sewage is treated using a marine sanitation device that biologically treats and disinfects the waste prior to discha rge. Some cruise ships, especi ally many of those traveling to Alaska, have installed Advanced Wastewater Tr eatment systems (AWTs) to treat sewage and often graywater. These AWTs provide higher levels of biological treatmen t, solids removal, and disinfection as compared to tradit ional marine sanitation devices.

This section discusses the curren t state of information about ve ssel sewage, the laws regulating sewage discharges from vessels, the types of equipment used to treat sewage generated on cruise ships and how well they remove various pollutants, the potential environmental impacts of cruise ship sewage discharges, and federal actions take n to address sewage from cruise ships. The conclusion of this section lists a wide range of opt ions and alternatives that could be considered when addressing sewage from cruise ships.

2.1 What is sewage from vessels and how much is generated on cruise ships?

Sewage from vessels, also known as “black water,” generally means human body wastes and the

wastes from toilets and other receptacles intended to receive or retain body wastes . On some ships, m edical sink and medical floor drain wastewater is commingled with sewage for

treatment.

Cruise ship sewage systems generally use fres h water to reduce corros ion, and vacuum flushing and conveyance to reduce water use. According to responses to EPA’s survey of 29 cruise ships operating in Alaska in 2004, the average amount of water needed per toilet flush is 0.3 gallons. Only one of the ships surveyed uses seawater in their sewage system; this gravity system uses 1 gallon of seawater per toilet flush. For comp arison, the latest water-saving, high-efficiency domestic toilets for land-based use ty pically use about 1.3 gallons per flush.

Estimated sewage generation rates reported in response to EPA’s 2004 survey ranged from 1,000 to 74,000 gallons/day/vessel or 1.1 to 27 gallons/day/person. Sewa ge generation rates generally are not measured, and EPA is not able to indepe ndently confirm the accuracy of these estimated rates. It is not clear why re ported rates would vary to this degree. Average reported sewage generation rates were 21,000 gallons/day/vessel and 8.4 gallons/day/person (see Figure 2-1). There appears to be no relationship between per capita sewage generation rates and number of persons onboard (see Figure 2-2).

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0 2 4 6 8 10 12

<5 5-10 10-15 15-20 20-25 25-30

Per Capita Sewage Generation (gal/day/pers) 8.6 ± 1.1 gal/day/pers (mean ± SE)

n = 29

0 5 10 15 20 25 30

0 1,000 2,000 3,000 4,000 5,000

Persons Onboard (passengers + crew)

Figure 2-1. Per Capita Sewage Generation

as Reported in EPA’s 2004 Cruise Ship Survey Figure 2-2. Sewage Generation by Persons Onboard as Reported in EPA’s 2004 Cruise Ship Survey

During EPA’s 2004 sampling of four ships with AWTs, sewage generation was measured on one ship at 17 gallons/day/person (EPA, 2006a). On other ships, measurements were made of sewage plus graywater sources treated by the AWT (see Section 3 for more information on graywater).

Treated sewage discharge rates are nearly equiva lent to sewage generation rates. Differences

between these two rates are attri buted to the volume of biomass, if any, that is removed during wastewater treatment (see subsection 2.3.3 below).

Cruise ship capacity to hold untreated (or treate d) sewage varies significantly. According to responses to EPA’s 2004 cruise ship survey, se wage holding capacity ranges from 0.5 to 170 hours, with an average hold ing capacity of 62 hours.

2.2 What federal laws apply to sewage from cruise ships?

2.2.1 Clean Water Act Section 312

Section 312 of the Clean Water Act (C WA; 33 U.S.C. § 1322) requires that vessels with installed toilet facilities be equipp ed with an operable marine sanitation device (MSD), certified by the Coast Guard to meet EPA performance standards, in order to operate on the navigable waters of the United States (which extend seaward 3 nautic al miles from shore for the purpose of this statute). CWA section 312 also establishes procedures for the designation of no-discharge zones (NDZs) for vessel sewage. Section 312 of th e CWA is i mplemented jointly by EPA and the Coast Guard. EPA is responsible for developi ng performance standards for MSDs and working

with states to establish NDZs. EPA establis hed performance standards for MSDs in the mid 1970s; EPA and states continue to establish NDZ s on an on-going basis. The Coast Guard is

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responsible for certification of MSDs prior to sale, introduction or delivery into interstate commerce, or import into the United States for sale or resale. States ma y not adopt or enforce any statute or regulation of th e state or a political subdivision with respect to the design, manufacture, installation or use of MSDs (e xcept on houseboats), but may establish sewage NDZs in conjunction with EPA under certain circ umstances (see below). The Coast Guard and

states are vested with authority to enforce the requiremen ts of CWA section 312. Persons who tamper with certified MSDs or sell non-certified MSDs, or who operate vessels required to have MSDs but do not, are subject to statutory civil penalties of up to $5,000 and $2,000, respectively, for each violation. While CWA section 312 provides for such civil penalties, it does not provide

for either administrative or criminal enforcement.

Marine Sanitation Devices The term “marine sanitation device” (MSD) means equipment for installation onboard a vessel which is designed to receive, re tain, treat, or discharge sewage , and any process to treat such

sewage. CWA section 312(a)(6) defines sewage as hum an body waste and the wastes from toilets and other receptacl es intended to receive or retain body waste. There are three types of MSDs recog nized by the Coast Guard:

 Type I MSDs are flow-through treatment de vices that commonly use maceration and

disinfection for treatment of th e sewage. Type I devices may be used only on vessels less than or equal to 65 feet in length. EPA’s pe rformance standard for Type I MSDs is an

effluent with a fecal coliform count not to exceed 1000 per 100 milliliters of water, with no visible floating solids.

 Type II MSDs also are flow-through treatm ent devices, generally employing biological treatment and disinfection. Some Type II MS Ds use maceration and disinfection. Type II MSDs may be used on vessels of any size. EPA’s performance standard for Type II

MSDs is an effluent with a fecal coliform count not to exceed 200 per 100 milliliters of water and total suspended solids no greater than 150 milligrams per liter of water.

 Type III MSDs are holding tanks, where sewa ge is stored until it can be properly disposed of at a shore-side pum pout facility or out at sea (b eyond three miles from shore). Type III MSDs also may be used on vessels of any size. EPA is not aware of any cruise vessels that use Type III MSDs exclusivel y. However, a Type II MSD may be equipped with installed holding tanks which can be us ed to store treated sewage until reaching a pumpout facility or discharged overboard wh en the vessel is beyond three nautical miles

from land.

The Coast Guard is responsible for certification of MSDs based on EPA’s performance standards (listed above). The Coast Guard can certify a product line of MSDs for vessel installation and use if that product line complies with Coast Guard design and testing crit eria (33 CFR Part 159), as confirmed by testing conducted at a qualifie d independent laborator y. After Coast Guard review and approval, each MSD model is desi gnated an approval numbe r (“certification”), typically valid for five years. MSDs manufactured before the certification expiration date are

deemed to have met Coast Guard standards and ma y be installed on vessel s; MSDs manufactured after the expiration date do not meet Coast Guard approval. U nder Coast Guard policy, foreignflagged vessels may use MSDs that have receiv ed a compliance test cer tificate under Annex IV of MARPOL (discussed below). During routine inspections, Coast Guard inspectors examine the MSD to ensure its operati on and condition meet all requireme nts of 33 CFR Part 159. The

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Coast Guard inspector verifies that the MSD is in good and serv iceable condition – that the MSD is properly approved, installed, and performing as intended. If the Coast Guard inspector suspects or finds clear grounds that the MSD is not in good and serv iceable condition, the inspector may require that the vessel owner have the MSD effluent tested by a qualified wastewater laboratory, with resu lts reported to the Coast Guard.

No-Discharge Zones CWA section 312(f) authorizes the establishment of no-discharge zones (NDZs), areas in which discharges from vessels of any sewage, whethe r treated or not, are prohibited. States may establish an NDZ for some or all of their waters if EPA determines that adequate facilities for the safe and sanitary removal and treatment of the se wage are reasonably available. States also may request that EPA establish NDZs by rulemaking (1) if EPA determ ines that the protection and enhancement of the quality of the waters requ ire such a prohibition, or (2) to prohibit the discharge of vessel sewage into a drinking wate r intake zone. There are currently 67 NDZs in the United States covering 115 waterbodies; 64 of these NDZs were established by states.

2.2.2 The International Convention for the Prevention of Pollution from Ships

The principal international convention addressi ng discharge standards for vessel sewage is

Annex IV to the International Convention for the Prevention of Pollution from Ships (known as MARPOL 73/78, or simply MARPOL). Alt hough Annex IV was adopted in 1973, it did not come into effect until September 2003, after ratif ication by the requisite number of states (and corresponding shipping fleet tonnage ). Subsequent amendments en tered into force on August 1, 2005. Annex IV applies to countries that are a party to the Annex, and all vessels operating under their flags.

MARPOL Annex IV contains regulations regarding the discharge of sewage into the sea, ships' equipment and systems for the control of sewage di scharge, a provision for fa cilities at ports and terminals for the reception of sewage, and requirem ents for survey and ce rtification. Annex IV defines sewage as drainage and ot her wastes from any form of toile ts and urinals; drainage from medical premises (dispensary, sick bay, etc.) via wash basins, wash tubs and scuppers located in such premises; drainage from spaces containing living animals; or other waste waters when mixed with the drainages defined above.

MARPOL Annex IV generally requ ires ships to be equipped with either a sewage treatment plant, a sewage comminuting and disinfecti ng system, or a sewage holding tank. More specifically, the discharge of se wage into the sea is prohibite d except when the ship has in operation an approved sewage trea tment plant or is dischargin g comminuted and disinfected sewage using an approved system at a distance of more than three nautical miles (nm) from the nearest land; or is discharging sewage which is not comminuted or disinfected at a distance of more than 12 nm from the nearest land. There is a standard for the maximum rate of discharge of untreated sewage from holding tanks when at a distance equal or greater than 12 nm from the

nearest land. Annex IV also establishes cer tain sewage reception facility standards and responsibilities for ports. Vessels that comply w ith Annex IV are issued an International Sewage Pollution Prevention Certificate (ISPPC).

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The United States is not a pa rty to MARPOL Annex IV. U nder existing Coast Guard policy, vessels registered in the United States that engage in internat ional voyages with installed and operational Coast Guard certified Type II MSDs are deemed equivalent to MARPOL Annex IV using effluent standards in MEPC.2(VI) and thus e ligible to receive a Coas t Guard certificate of equivalency. This certificate ta kes the place of the I SPPC and is issued to only U.S. vessels. Similarly, under a separate Coast Guard policy, any vessel flagged or registered outside the

United States that holds a valid endorsed Cert ificate of Type Test issued by their flag

administration in accordance with MARPOL Annex IV indicating the installed sewage treatment plant complies with Annex IV as amended by resolution MEPC.2(VI) will be accepted by the Coast Guard as being in compliance with U.S. re gulations in 33 CFR Part 159 while operating in waters subject to the jurisdiction of the United St ates. Both Coast Guard policies are currently in the process of being updated to reflect the recen t changes to MARPOL Annex IV. In any case, the Coast Guard is responsible for verifying that a vessel is in substant ial compliance with the conventions, a determination made if the sewage system is in good and serviceable condition.

2.2.3 Certain Alaskan Cruise Ship Operations

On December 12, 2000, Congress enacted an omnibus appropriation that included new statutory requirements for certain cruise ship discharges occurring in Al aska (Departments of Labor, Health and Human Services, and Education, an d Related Agencies Appropriations Act, 2001, Pub. L. No. 106-554, 114 Stat. 2763, enacting into law Title XIV of Division B of H.R. 5666, 114 Stat. 2763A-315, and codified at 33 U.S.C. § 1901 Note). Title XIV set discharge standards for sewage and graywater from certain cruise ships (those authorized to carry 500 or more passengers for hire) while operating in the Alexander Archipelago and the navigable waters of the United States in the State of Alaska and within the Kachemak Bay National Estuarine Research Reserve (referred to here as “Alaskan wa ters”). This federal law, referred to here as “Title XIV,” also authorized EPA to develop revised or additional standards for discharges of sewage and graywater from cruise ships opera ting in Alaskan waters, if appropriate. In developing revised or additional standards, EP A must take into account the best available scientific information on the environmental effects of the regulated discharges and the availability of new technologies fo r wastewater treatment, and ensure that the standards are, at a minimum, consistent with all relevant St ate of Alaska water quality standards.

Before this law was passed, there was consider able concern about cruise ships discharging untreated sewage and graywater in to areas within the Alexander Ar chipelago (a chain of islands in Southeast Alaska), but beyond three miles fr om any shore. In these areas, known as doughnut holes, the discharge of sewage was unregulated. Title XIV prohibited discharges of untreated sewage from cruise vessels and set requirements for discharges of treated sewage and graywater

from cruise vessels into Alaskan wa ters, including the doughnut holes.

Specifically, Title XIV requires that discharges within one nautical mile of shore or discharges in any Alaskan waters when the ship is traveling un der six knots meet stringent standards for fecal coliform (geometric mean of samples taken dur ing any 30-day period doe s not exceed 20 fecal

coliform/100 ml and not more than 10% of th e samples exceed 40 fecal coliforms/100 ml) and chlorine (total chlorine residual does not exceed 10.0 micrograms/liter), and meet secondary treatment standards for biochemical oxygen dema nd, suspended solids, and pH (found at 40 CFR

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133.102). Title XIV requires that discharges of treat ed sewage outside of one nautical mile from shore from vessels traveling at least six knots meet EPA’s CWA section 312 performance standards for Type II MSDs (no more than 200 f ecal coliforms per 100 ml and no more than 150 milligrams total suspended solids per liter).

Title XIV requires the Coast Guard to incorporate an inspection regime into the commercial vessel examination program sufficient to verify compliance with the Act, authorizes the Coast Guard to conduct unannounced inspections and to require logbooks of all sewage and graywater discharges, and provides EPA and the Coast Guard w ith authority to gather information to verify compliance with the Act. Title XIV provides a range of enforcement response authorities, including administrative orders, civil and criminal penalties, injunctive relief, and in rem liability. Title XIV also authorizes Alaska to petition EPA to establish NDZs for sewage and graywater from cruise ships.

Pursuant to Title XIV, EPA has carried out a mu lti-year project to determine whether revised or additional standards for sewage and graywater di scharges from large cruise ships operating in

Alaska are warranted under that le gislation. EPA sampled wastewater from four cruise ships that operated in Alaska during the summer of 2004. The purpose of this sampling was to characterize graywater and sewage generated onboard and to evaluate the pe rformance of various advanced sewage and graywater treatment systems. EPA also distributed a “Survey Questionnaire to Determine the Effectiveness, Costs, and Impact s of Sewage and Graywater Treatment Devices for Large Cruise Ships Operating in Alaska” to a ll cruise ships authorized to carry 500 or more passengers for hire that operate d to Alaska in 2004. Using these sampling results, survey responses, and other relevant information, EPA is performing environmental, economic, and engineering analyses to determine whether re vised or additional sta ndards in Alaska are warranted. EPA anticipates announcing its dete rmination and making its analyses publicly

available in 2009. Much of the information and data collected for EPA’s effort under Title XIV are summarized in this Assessment Report.

Though not a federal law, a law was passed by the State of Alaska in 2001 (AS 46.03.460 - AS 46.03.490) that set standards and sampling requir ements for the discharge of sewage and graywater from large (250+ passengers) and sma ll (50-249 passengers) passe nger vessels. This law also addresses off-loading and/or disposal of non-hazardous solid wastes and hazardous wastes in Alaska. In August 2006, Alaskan voter s approved a ballot m easure that added new requirements for cruise ships. The owners/operators of large commercial passenger vessels must now obtain a wastewater discharg e permit in order to discharge any treated sewage, graywater,

or other wastewater into marine waters of the state. Please see Appendix B for more information on state cruise ship efforts.

2.2.4 National Marine Sanctuaries Act

The National Marine Sanctuaries Act (NMSA; 16 U.S.C. § 1431 et seq.), as amended, established a national program to designate certain areas of marine environments as areas of special national significance that warrant heightened care. The primary purpose of the law is to protect marine resources and ecosystems, such as coral reefs, sunken histor ical vessels, or unique

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habitats, from degradation while facilitating public or private us es compatible with resource protection.

NMSA authorizes the National Oceanic and At mospheric Administrati on (NOAA) to designate

as National Marine Sanctuaries areas of the marine environment that have special aesthetic, ecological, historical, or recreat ional qualities, and to provide comprehensive and coordinated conservation management for such areas. The National Marine Sanctuary Program manages 13

sanctuaries and the Papah ā naum oku ā kea Marine National Monument (tog ether referred to as “sites”). Designated sites are managed according to site-specific management plans developed by NOAA that typically prohibit by regulation the discharge or deposit of most material. Discharges of graywater and treated vessel sewage, however, are sometimes allowed provided they are authorized under the Clean Water Act. In some sanctuaries the discharge of sewage is prohibited in special zones to protect fragile habita t, such as coral. NMSA also provides for civil penalties for violations of its requiremen ts or the permits issued under it.

2.3 What technologies are available to treat sewage from cruise ships?

As discussed above, any ship greater than 65 feet in length must use either a Type II (flow through treatment device) or Type III (holding tank) MSD. An increasing number of cruise ships are using more effective and expensive Type II MSDs, referred to as “Advanced Wastewater Treatment systems” (AWTs), to treat both sewage and graywater (generally wastewater from sinks, baths, showers, laundry, and galleys; see S ection 3 for more information on graywater).

One recent estim ate by the cruise industry is th at roughly 40% of the International Council of Cruise Lines (ICCL) members’ 130 ships (which ma ke up two-thirds of the world fleet) have installed AWTs, with 10 to 15 more systems added each year (Choi, 2007). (ICCL merged with

the Cruise Lines International Association (CLIA) in 2006; see Section 1.5 for more information.) In 2006, 23 of 28 large cruise ship s that operated in Alaskan waters had AWTs in order to meet the more stringent discharge requirements in effect there (see subsection 2.2.3 above).

This subsection provides information on the types of MSDs most often used by cruise ships: traditional Type II MSDs (2.3.1) and AWTs (2.3.2) . Specifically, it discusses how these systems work and how well they remove various pollu tants from the waste stream. Subsection 2.4 (below) discusses potential environmental impacts of sewage from cruise ships.

2.3.1 Traditional Type II Marine Sanitation Devices

How it works

On most cruise ships with traditional Type II MS Ds, sewage is treated using biological treatment and chlorination. Some cruise ships do not tr eat their sewage biologi cally, but instead use

maceration and chlorination. Of th e nine large cruise ships with traditional Type II MSDs that operated in Alaskan waters in 2004, six used bi ological treatment and chlorination, and three

used maceration and chlorination.

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Biological-chlorination MSDs opera te similarly to land-based bi ological treatment systems for municipal wastewater treatment. The treatm ent system typically in cludes aerobic biological treatment to remove biochemical oxygen demand and some nutrients, clarification and filtration to remove solids, and final chlo rine disinfection to destroy pa thogens (see Figure 2-3). The system also may include screening to remove grit and debris. Cruise ships typically install up to four systems, allowing one or two to be placed off-line for maintenance at any one time (ADEC, 2000b).

S

C

R

E

E

N Untreated

Sewage

Sludge Aerobic

Bacteria Digestion

Biosolid Return Clarification &

Filtration Chlorine Contact

Disinfection Treated

Effluent

Air & Heat

Figure 2-3. Simplified Schematic of Traditio nal Type II Marine Sanitation Device Using Biological Treatment and Chlorine Disinfection

Maceration -chlorination systems use screening to remove grit and debris, maceration for solids size reduction, and chlorine disinfection to oxidize and disinfect th e waste. Chlorine is either added (sodium hypochlorite) or generated by mixi ng the sewage with sea water and then passing

this solution between electrol ytic cells to produce hypochlorite.

How well it works in practice

Data Collection

The primary information available on discharges from tradition Type II MSDs is from a voluntary sampling effort in Alaska in 2000 by the Alaska Cruise Ship Initiative (ADEC, 2001). These data are no longer representa tive of cruise ships operating in Alaska, which have mostly installed AWTs, but they may be indicative of th e discharges from vessels with Type II MSDs operating in other waters. Twice during the 2000 cruise season, samples were collected from each sewage and graywater discharge port from each of the 21 large crui se ships operating in Alaska. (All except two of the sampled vessels treated sewage using traditional Type II MSDs. The other two vessels treated mixed sewage a nd graywater using prototype reverse osmosis AWTs. Data from all 21 vessels, including the two vessels with reverse osmosis systems, are included in this summary, because in most cases, it was not possible to identify results from the two vessels with reverse osmosis systems.)

The Alaska Cruise Ship Initiative (ACSI) samp ling was scheduled randomly at various ports of call on all major cruise routes in Alaska. Indi vidual discharge samples characterized different

2-8December 29, 2008

types of wastewater depending on ship-specific disc harge configurations. As a result, individual samples characterized one or more graywater so urces, treated sewage, or combined graywater and treated sewage. Analytes included to tal suspended solids, biochemical oxygen demand, chemical oxygen demand, pH, fecal coliform, total residual chlorine, free residual chlorine, and ammonia for all samples, and priority pollutant s (metals, hydrocarbons, organochlorines) for one sample per ship. Samples were not taken of the influent to the treatment systems; therefore, percent removals achieved by these systems cannot be determined.

The results of this ACSI sampling are discussed in more detail below, but in summary, 43% of the samples for fecal coliform met the MSD stan dard of 200 fecal coliform per 100 ml, 32% of the samples for total suspended solids met the MSD standard of 150 mg/l, and only 1 blackwater sample out of 70 samples met both the total su spended solids and fecal coliform standards (ADEC, 2001).

The Coast Guard inspected six of the cruise ship s with poor effluent samples and found that five out of the six were either operating the MSDs im properly or failing to maintain them (ADEC, 2000a).

Pathogen Indicators

Based on data collected by ACSI in 2000, the aver age fecal coliform concen tration in traditional Type II MSD effluent was 2,040,000 MPN/100 ml (t otal of 92 samples, calculation used detection limits for nondetected results). The ra nge was from nondetect (detection limit of 2) to 24,000,000 MPN/100 ml. Of the 92 samples, 51 we re greater than 200 MPN/100 ml, 35 were greater than 100,000, and 22 were greater than 1,000,000. This compares to typical fecal

coliform concentrations in untreated domestic wastewat er of 10,000 to 100,000 MPN/100 ml (Metcalf & Eddy, 1991). Fecal coliform is the onl y pathogen indicator analyzed by ACSI. As mentioned above, these data are primarily for trad itional Type II MSDs, but two of the 21 vessels sampled were using prototype reverse osmosis treatment systems.

Conventional Pollutants and Other Common Anal ytes

Table 2-1 shows ACSI sampling results for so me conventional pollutants and other common analytes in MSD effluent, as well as typical concentrations in untreated domestic wastewater. These key analytes are commonly used to assess wastewater strength.

Table 2-1. Comparison of Traditional Type II MSD Effluent Concentrations to Untreated

Domestic Wastewater -- Conventional Pollutants and Other Common Analytes

Analyte Average Conc. (± SE) of Cruise Ship Type II MSD Effluent 1 Concentration in Untreated

Domestic Wastewater 2

Total Suspended Solids (mg/l) 627 (±94.3) (21 detects out of 21 samples) 100 to 350

Biochemical Oxygen Demand (5- Day) (mg/l) 133 (±15.2) (21 detects out of 21 samples) 110 to 400

2-9December 29, 2008

C hemical Oxygen Demand (mg/l) 1,040 (±271) (3 detects out of 3 samples) 250 to 1,000

pH 90.5% of the pH samples are

between 6.0 and 9.0 (21 detects out of 21 samples) between

6.0 and 9.0

Total residual chlorine ( μ g/l) 1,070* (±499) (12 detects out of 18 samples) No data

1 Based on data collected by ACSI in 2000; of 21 vessels sampled, 19 had traditional Type II MSDs and 2 had

prototype reverse osmosis treatment systems.

2 Metcalf & Eddy, 1991. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Metals

ACSI sampled for 13 priority pollutant metal analyt es, of which 8 were detected in greater than 10% of the Type II MSD effluent samples (less fre quent detection of analytes is considered not representative of the waste stream ; in fact, of the metal analytes detected in any samples, none were detected in fewer than 10% of the samples) (see Table 2-2). Copper and zinc were detected in the greatest amounts.

Table 2-2. Traditional Type II MSD Effluent Concentrations -- Metals

Analyte Average Conc. (± SE) of Crui se Ship Type II MSD Effluent 1

Cadmium (Total) ( μ g/l) 0.0624* (±0.0205) (3 detects out of 24 samples)

Chromium (Total) ( μ g/l) 5.99* (±2.50) (8 detects out of 24 samples)

Copper (Total) ( μ g/l) 954* (±398) (19 detects out of 24 samples)

Lead (Total) ( μ g/l) 6.94* (±2.72) (7 detects out of 24 samples)

Mercury (Total) ( μ g/l) 0.206* (±0.0574) (8 detects out of 22 samples)

Nickel (Total) ( μ g/l) 15.8* (±7.34) (5 detects out of 22 samples)

Silver (Total) ( μ g/l) 0.527* (±0.166) (9 detects out of 22 samples)

Zinc (Total) ( μ g/l) 514* (±97.3) (19 detects out of 22 samples)

1 Based on data collected by ACSI in 2000; of 21 vessels sampled, 19 had traditional Type II MSDs and 2 had

prototype reverse osmosis treatment systems. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Volatile and Semivolatile Organics

ACSI sampled for almost 140 volatile and semivol atile organic analytes. Of these, 16 were

detected in at least 10% of efflue nt samples (less frequent detecti on of analytes is considered not representative of cruise ship e ffluent; analytes that were detect ed in fewer than 10% of samples were detected in only one or two samples). Table 2-3 presents the average volatile and semivolatile organic concentrations in Type II MSD effluent for these 16 analytes. Some of the analytes in this table with the highest concentra tions are chlorine byproduc ts, likely generated by sewage chlorination.

2-10December 29, 2008

Table 2-3. Traditional Type II MSD Effluent Concentrations -- Volatile and Semivolatile Organics

Analyte Average Conc. (± SE) of Crui se Ship Type II MSD Effluent 1

1,2-Dichloroethane ( μ g/l) 0.879* (±0.0666) (8 detects out of 21 samples)

1,4-Dichlorobenzene ( μ g/l) 17.4* (±16.6) (4 detects out of 21 samples)

Bis(2-ethylhexyl) phthalate ( μ g/l) 3.45* (±0.837) (16 detects out of 21 samples)

Bromodichloromethane ( μ g/l) 2 33.7* (±12.7) (14 detects out of 21 samples)

Bromoform ( μ g/l) 2 43.6* (±21.9) (13 detects out of 22 samples)

Carbon tetrachloride ( μ g/l) 1.96* (±1.12) (5 detects out of 24 samples)

Chloroform ( μ g/l) 2 111* (±63.3) (21 detects out of 24 samples)

Chloromethane ( μ g/l) 24.4* (±12.9) (5 detects out of 22 samples)

Dibromochloromethane ( μ g/l) 2 27.4* (±12.0) (11 detects out of 24 samples)

Diethyl phthalate ( μ g/l) 1.00* (±0.204) (5 detects out of 24 samples)

Di-n-butyl phthalate ( μ g/l) 2.65* (±0.445) (13 detects out of 24 samples)

Ethylbenzene ( μ g/l) 0.624* (±0.181) (5 detects out of 24 samples)

Methylene chloride ( μ g/l) 4.02* (±1.81) (3 detects out of 22 samples)

Phenol ( μ g/l) 26.5* (±13.5) (7 detects out of 22 samples)

Tetrachloroethylene ( μ g/l) 12.5* (±10.5) (3 detects out of 22 samples)

Toluene ( μ g/l) 0.620* (±0.0771) (5 detects out of 22 samples)

1 Based on data collected by ACSI in 2000; of 21 vessels sampled, 19 had traditional Type II MSDs and 2 had

prototype reverse osmosis treatment systems.

2 Trihalomethanes are water system disinfection byproducts. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Nutrients

Table 2-4 shows average ammonia concentration in effluent from traditional Type II MSDs, as well as typical concentrations in untreated domestic wastewater.

Table 2-4. Comparison of Traditional Type II MSD Effluent Concentrations to Untreated

Domestic Wastewater -- Ammonia

Analyte Average Conc. (± SE) of Cruise Ship Traditional Type II MSD Effluent 1 Concentration in Untreated

Domestic Wastewater 2

Ammonia as Nitrogen (mg/l) 145 (±36.7) (21 detects out of 21 samples) 12 to 50

1 Based on data collected by ACSI in 2000; of 21 vessels sampled, 19 had traditional Type II MSDs and 2 had

prototype reverse osmosis treatment systems.

2 Metcalf & Eddy, 1991.

2-11December 29, 2008

2.3.2 Advanced Wastewater Treatment Systems

How it works

On some cruise vessels, especially many of those traveling to Alas ka (see subsection 2.2.3 above), sewage and often graywa ter are treated using AWTs. AW Ts generally provide improved screening, biological treatment, solids separation (using filtration or flotation), and disinfection (using ultraviolet light) as compared to traditio nal Type II MSDs. The AWTs currently used by cruise ships operating in Alaskan waters are discussed in this subsection.

Hamworthy’s Membrane Bioreactor (MBR) system uses aerobic biologi cal treatment followed by ultrafiltration and ultraviolet (UV) disinfection. One example of this system is in operation

on the Princess Cruises vessel Island Princess. On this vessel, the Hamworthy MBR system

treats wastewater from accommodations and sewa ge. Wastewater is first treated in screen presses to remove paper and ot her coarse solids. Next, the wastewater enters a two-stage bioreactor, where bacteria digest the organic matter in the waste. Following biological treatment,

the wastewater is filtered thr ough tubular ultrafiltration membrane s to remove particulate matter and biological mass, which are retu rned to the bioreactors. In the final stage of treatment, the wastewater undergoes UV disinfect ion to reduce pathogens. See EPA, 2006c, for more detailed information on this system.

ROCHEM’s ROCHEM LPRO and ROCHEM Bio-Fi lt® system treats high concentration and

low concentration waste streams w ith different processes. One example of this system is in operation on the Holland America Line vessel Oost erdam. On this vessel, the ROCHEM LPRO part of the system treats wastewater from la undry and accommodations (low concentration waste streams) while the ROCHEM Bio-Filt® treats wa stewater from galley and sewage, as well as the membrane concentrate from the ROCHEM LPRO sy stem (high concentration waste streams). The ROCHEM LPRO system uses screens to remove fibers and hair, reverse osmosis membranes to remove particulates and disso lved solids, and UV di sinfection to reduce pathogens. The ROCHEM Bio-Filt® system uses vibratory screen s to remove coarse solids, bioreactors to biologically oxidize the waste, ul trafiltration membranes to remove particulate matter and biological mass (which ar e returned to the bioreactors), and UV disinfection to reduce pathogens. See EPA, 2006d, for more detailed information on this system.

The Zenon ZeeWeed® MBR system uses aerobic bi ological oxidation followed by ultrafiltration and UV disinfection. One example of this syst em is in operation on the Holland America Line vessel Veendam. On this vessel, graywater from the laundry, galley, accommodations, and food pulper combines with sewage and flows through tw o coarse screens into a collection tank. From the collection tank, the wastewater is pumped to an aerated bioreactor. After the bioreactor, the wastewater flows through the proprietary Z eeWeed® hollow-fiber ultrafiltration membrane system under a vacuum. In the final stage of treatment, the combined wastewater from the membranes undergoes UV disinfection to redu ce pathogens. The Zenon system is the only system that EPA sampled that treats all gray water and sewage sources. See EPA, 2006a, for more detailed information on this system.

2-12December 29, 2008

The Scanship treatment system uses aerobic biological oxidation fo llowed by dissolved air

flotation and UV disinfection. One example of the Scanship system is in operation on the Norwegian Cruise Line vessel St ar. On this vessel, sewage and graywater from the galley, accommodations, and laundry combine in one graywater and sewage holding tank. The combined wastewater is pumped through a coar se drum filter and then through two separate

aerated bioreactors. Each biorea ctor contains free-floating pl astic beads to support biological growth, eliminating the need for recycled biological mass. After aeration, the wastewater is pumped to two dissolved air flotation (DAF) units to separate solids. From the DAF units, the wastewater is pumped to polishing screen filters. In the final st age of treatment, the wastewater undergoes UV disinfection to reduce pathogens. See EPA, 2006b, for more detailed information on this system.

The Hydroxyl CleanSea® system uses aerobic biological oxidation follo wed by dissolved air

flotation and UV disinfection. Sewage and graywater are combined and pumped to a fine wedgewire screen for coarse solids removal. Next, the wastewater enters the ACTIVECELLTM biological reactors where free-floating plastic beads support bi ological growth without the need for recycled biological mass. The wastewater then enters the ACTIVEFLOATTM dissolved air flotation units for solids separation. Final tr eatment steps include polishing filters and UV disinfection to reduce pathogens (Hydroxyl Systems, 2007). None of the ships that EPA sampled in 2004 and 2005 used the Hydroxyl CleanSea® system. Through 2007, EPA is not aware of any ships using the Hydroxyl system that have been approved for continuous discharge in Alaskan waters; in 2008, one ship using th e Hydroxyl system was approved for continuous discharge in Alaska.

How well it works in practice

In 2004 and 2005, EPA sampled wastewater from four cruise ships that operated in Alaska to characterize graywater and sewage generated onboard and to eval uate the performance of the Zenon, Hamworthy, Scanship, and ROCHEM AW Ts (see EPA, 2006 a-e). EPA also has evaluated cruise ship complian ce monitoring data for AWT effluent provided by the Alaska Department of Environmental Conservation (ADEC) and the Coast Guard for 2003 through 2005, and self-monitoring data for AWT effluent s ubmitted by the cruise industry in response to EPA’s 2004 cruise ship survey.

These sampling results, which are de scribed in greater detail below, indicate that AWTs are very effective in removing pathogens, oxygen demand ing substances, suspended solids, oil and grease, and particulate metals. AWTs remove some of the dissolved metals (37 to 50%). Most volatile and semi-volatile organics are removed to levels below detection limits, while others

show moderate removal. AWTs achieve mode rate nutrient removals, likely resulting from nutrient uptake by the microorganisms in the bioreactors.

Data Collection

EPA Sampling : In 2004 and 2005, EPA analyzed th e effluent from Zenon, Hamworthy, Scanship, and ROCHEM AWTs (see EPA, 2006 a- e) for over 400 analytes, including pathogen

2-13December 29, 2008

indicators, suspended and dissolved solids, biochemical oxygen demand, oil and grease, dissolved and total metals, organics, and nutrients.

ADEC/Coast Guard Sampling : AWT effluent data are collected through compliance monitoring required by state and federal law fo r all cruise ships that discha rge in Alaskan waters. Since 2001, Alaska state law requires a minimum of two discharge samples per year for large cruise ships. Both samples are analyzed for fecal coliform and other common pollutants, and one sample is also analyzed for priority polluta nts. This program is managed by the Alaska Department of Environmental Conservation ( ADEC). Additionally, the federal law entitled “Certain Alaska Cruise Ship Operations” requi res compliance monitoring of discharges from vessels approved for continuous discharge in Alaskan waters (see subsection 2.2.3 above). Sampling frequency and analytes are at the discre tion of the Captain of the Port (COTP). The COTP requires discharge sampling twice per month for fecal coliform and other common pollutants. Although AWT compliance monitoring data are available beginning in 2001, EPA is using data collected beginning in 2003 as repres entative of AWT discharges due to sampling constraints prior to 2003.

Data from EPA’s 2004 Cruise Ship Survey : EPA’s 2004 cruise ship survey asked cruise ships operating in Alaska in 2004 to submit any addition al monitoring data collected in Alaska that was not previously provided to EPA through ADE C or the Coast Guard. EPA received a small amount of additional AWT effluent monitoring data from six ships in response to this request. These data comprise less than 2% of the data summarized below.

To date, all available AWT effluent monitoring data are from four AWT systems: Hamworthy MBR; ROCHEM LPRO and ROCHEM Bio-Filt®; Zenon ZeeWeed® MBR; and Scanship. This is because these were the only AWT systems cer tified for continuous discharge in Alaska through 2005. All four of these AWTs treat sewage and at le ast some graywater sources. Therefore, these results apply to graywater treatment as well.

Pathogen Indicators

EPA analyzed both the influent a nd the effluent from AWTs (mixed graywater and sewage), as well as the influent to UV disinfection, for th e pathogen indicators fecal coliform, enterococci,

and E. coli . Fecal coliform were analyzed for compar ison to the MSD and Title XIV standards. EPA chose to sample for E. coli and enterococci because epidemiological studies suggest a positive relationship between high concentrations of E. coli and enterococci in ambient waters and incidents of gastrointest inal illnesses associated w ith swimming (EPA, 1984b, and EPA, 1983).

ADEC/Coast Guard analyzed for fecal coliform to assess compliance wi th the fecal coliform discharge standards. EPA also received some fecal coliform data in response to the survey.

Sampling data indicate that AWTs remove pathoge n indicators to levels below detection (>99% removal) (see Table 2-5). Over 96% of pathogen indicators were removed by the bioreactors and solids separation units; any remaining pathoge n indicators were ge nerally removed by UV

disinfection to levels below de tection (overall system efficien cy >99%). When detected, pathogen indicators were generally at le vels close to the detection limit.

2-14December 29, 2008

Responses to EPA’s 2004 cruise ship survey di d not provide sufficien t information on the UV dose used by these treatment systems to enable a determination regarding whether the systems

would inactivate viruses.

EPA did not conduct sampling to assess the pote ntial impact of holding on AWT effluent. Holding treated effluent in tanks for later disc harge potentially could result in re-growth of pathogens.

Table 2-5. AWT Effluent Concentrations and Removals -- Pathogen Indicators

Analyte Unit Average Concentration in Cruise Ship AWT

Influent 1 Average Concentration

after bioreactors but

before UV Disinfection 1 Average Concentration in Cruise Ship AWT

Effluent 2 Overall

AWT

Percent

Removal 1

CFU

/ 100

ml 103,000,000* (61 detects out of 62 samples) 25,500# (39 detects out of 56 samples) 14.5* (26 detects out of 285 samples) >99 Fecal

Coliform

MPN

/ 100

ml 10.1* (47 detects out of 320 samples)

E. coli MPN

/ 100

ml 12,700,000 (63 detects out of 63 samples) 727* (38 detects out of 55 samples) 1.98* (6 detects out of 59 samples) >99

Enterococci MPN

/ 100

ml 4,940,000* (63 detects out of 64 samples) 97.4# (33 detects out of 54 samples) 1.28* (9 detects out of 58 samples) >99

1 Based on data collected by EPA in 2004.

2 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004; and data

collected through EPA’s 200 4 cruise ship survey. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results. # Average includes at least one nondetect value (calculation uses detection limits for nondetected results) and at least one result flagged by the laboratory as not diluted sufficiently. The “>” symbol indicates a minimum level of removal.

Conventional Pollutants and Other Common Anal ytes

Table 2-6 presents AWT effluent sampling data for various comm on analytes including conventional pollutants (other than fecal coliform), chlorine, and temperature. Each of the three data sources (sampling by ADEC/Coast Guar d from 2003 to 2005; sampling by EPA in 2004; sampling data collected through EPA’s 2004 cruise sh ip survey) includes data for some of these analytes; however, not all sources analyzed for all of them. At a minimum, all three data sources analyzed the key analytes commonly used to assess wastewater stre ngth: biochemical oxygen demand, chemical oxygen demand, and total suspended solids.

The AWTs remove almost all biochemical oxygen demand, chemical oxygen demand, and total organic carbon. The systems also remove settleable residue and tota l suspended solids to levels

at or near detection.

2-15December 29, 2008

Table 2-6. AWT Effluent Concentrations an d Removals -- Conventional Pollutants and Other Common Analytes

Analyte Unit Average Concentration in Cruise Ship AWT Influent 1 Average Conc. (± SE) in Cruise Ship AWT Effluent 2 Percent

Removal 1

Alkalinity mg/l

CaCO 325 (25 detects out of 25 samples) 178 (±9.61) (127 detects out of 127 samples) 32 to 78

Biochemical Oxygen Demand (5-day) mg/l 526 (24 detects out of 24 samples) 7.99* (±0.798) (358 detects out of 568 samples) >99

Chemical Oxygen

Demand mg/l 1,140 (50 detects out of 50 samples) 69.4* (±4.03) (139 detects out of 147 samples) >93 to 97

Chloride μ g/l 294 (25 detects out of 25 samples) 389 (±93.9) (20 detects out of 20 samples) NC to 16

Conductivity umhos/cm 1,450 (±268) (105 detects out of 105 samples)

Hardness mg/l 135 (25 detects out of 25 samples) 120 (±30.5) (20 detects out of 20 samples)

Hexane extractable material (HEM) mg/l 95.6 (25 detects out of 25 samples) 5.74* (±0.154) (13 detects out of 127 samples) >91 to >96

pH SU 99.5% of samples within range

of 6.0 to 9.0 (921 detects out of 921 samples)

Residual Chlorine, Free mg/l 0.249* (±0.0993) (22 detects out of 511 samples)

Residual Chlorine, Total mg/l 0.338* (±0.129) (41 detects out of 547 samples)

Salinity ppt 1.93* (±0.606) (76 detects out of 77 samples)

Silica Gel Treated

Hexane Extractable Material (SGT-HEM) mg/l 22.1* (17 detects out of 25 samples) ND (0 detects out of 20 samples) NC to >92

Temperature °C 31.3 (±0.198) (403 detects out of 403 samples)

Total Dissolved Solids mg/l 776 (25 detects out of 25 samples) 819 (±169) (20 detects out of 20 samples) NC to 34

Total Organic Carbon mg/l 169 (25 detects out of 25 samples) 19.0* (±1.20) (123 detects out of 127 samples) 86 to 94

Total Settleable Solids ml/l 33.5* (23 detects out of 24 samples) 0.141* (±0.0385) (3 detects out of 83 samples) >99

Total Suspended Solids mg/l 545 (50 detects out of 50 samples) 4.49* (±0.193) (73 detects out of 587 samples) >99

2-16December 29, 2008

Average Conc. (± SE) in Average Concentration in Percent Analyte Unit Cruise Ship AWT Influent 1 Cruise Ship AWT Effluent 2 Removal 1

Turbidity NTU 2.31* (±0.894) (62 detects out of 76 samples)

1 Based on data collected by EPA in 2004 and 2005.

2 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004 and 2005; and

data collected through EPA’s 2004 cruise ship survey. “NC” indicates that percent removal was not calculated b ecause the effluent concentration was greater than the

influent concentration or the analyte was not detected in the influent samples from one or more sampled ships.

“ND” indicates not detected. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results. The “>” symbol indicates a minimum level of removal.

Metals

EPA sampled for 54 total and dissolved metal analytes. ADEC/Coast Guard analyzed for priority pollutant metal analyt es (total and dissolved). Su rvey respondents provided some priority pollutant metals data.

Table 2-7 presents AWT effluent sa mpling data for priority pollutant metals that were detected in greater than 10% of influent a nd/or effluent samples (less freq uent detection of analytes is considered not representative of the waste stream). Copper, nick el, and zinc, which showed the highest concentrations, are comm on components of ship piping.

Metals are present in both particulate and disso lved forms in the influents to the treatment systems. Metals in the effluent are predominantl y in the dissolved form. This suggests that the treatment systems are very efficient in removing particulate metals, as would be expected for membrane and dissolved air flotation solids separation systems (and as supported by nearly complete removal of settleable solids and total suspended solids). Sampling results indicate that AWTs remove 37 to 50% of dissolved metals on average.

2-17December 29, 2008

Table 2-7. AWT Effluent Concentrations and Removals -- Metals

Analyte 1 Unit Average Concentration in Cruise Ship AWT Influent 2 Average Conc. (± SE) in Cruise Ship AWT Effluent 3 Percent

Removal 2

Antimony, Total μ g/l ND 2.38* (±0.219) (15 detects out of 71 samples)

Antimony, Dissolved μ g/l 4.0* (1 detect out of 25 samples) 2.38* (±0.219) (11 detects out of 71 samples)

Arsenic, Total μ g/l 2.2* (3 detects out of 25 samples) 2.51* (±0.203) (22 detects out of 71 samples) NC to >3.8

Arsenic, Dissolved μ g/l ND 2.28* (±0.166) (19 detects out of 71 samples) NC

Cadmium, Total μ g/l 0.45* (13 detects out of 25 samples) 0.824* (±0.147) (2 detects out of 71 samples) >0.6 to 78

Chromium, Total μ g/l 6.64* (24 detects out of 25 samples) 4.29* (±0.992) (27 detects out of 71 samples) >44 to 95

Chromium, Dissolved μ g/l 1.51* (15 detects out of 25 samples) 3.71* (±0.786) (28 detects out of 71 samples) 49 to 67

Copper, Total μ g/l 519 (25 detects out of 25 samples) 16.6* (±2.74) (69 detects out of 71 samples) 96 to 98

Copper, Dissolved μ g/l 81.5 (25 detects out of 25 samples) 13.7* (±2.40) (65 detects out of 71 samples) 62 to 94

Lead, Total μ g/l 9.25* (22 detects out of 25 samples) 1.50* (±0.135) (27 detects out of 71 samples) 42 to >84

Lead, Dissolved μ g/l 2.36* (13 detects out of 25 samples) 1.35* (±0.138) (20 detects out of 71 samples) NC to >30

Mercury, Total 4 μ g/l 0.310* (21 detects out of 25 samples) 0.165* (±0.00895) (10 detects out of 70 samples) 60 to 92

Mercury, Dissolved 4 μ g/l 0.120* (10 detects out of 25 samples) 0.176* (±0.00941) (10 detects out of 68 samples) NC to 32

Nickel, Total μ g/l 22.4 (25 detects out of 25 samples) 13.6* (±2.01) (70 detects out of 71 samples) NC to 48

Nickel, Dissolved μ g/l 17.1 (25 detects out of 25 samples) 13.3* (±1.96) (69 detects out of 71 samples) NC to 32

Selenium, Total μ g/l 9.68* (13 detects out of 25 samples) 5.86* (±1.20) (33 detects out of 71 samples) 12 to 38

Selenium, Dissolved μ g/l 8.39* (10 detects out of 25 samples) 6.14* (±1.48) (29 detects out of 71 samples) NC to 24

Silver, Total μ g/l 1.70* (14 detects out of 25 samples) 1.15* (±0.109) (17 detects out of 71 samples) >0.5 to >74

Silver, Dissolved μ g/l ND 1.00* (±0.0844) (10 detects out of 71 samples) NC

Thallium, Total μ g/l 0.860* (2 detects out of 25 samples) 1.02* (±0.194) (11 detects out of 71 samples) NC to 3.2

Zinc, Total μ g/l 986 (25 detects out of 25 samples) 198* (±22.7) (69 detects out of 71 samples) NC to 86

Zinc, Dissolved μ g/l 209 (25 detects out of 25 samples) 185* (±21.4) (70 detects out of 71 samples) NC

2-18December 29, 2008

1 Priority pollutant metal analytes detected in at least 10% of AWT influent and/or effluent samples.

2 Based on data collected by EPA in 2004.

3 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004; and data

collected through EPA’s 200 4 cruise ship survey.

4 Because it was not possible to incorporate “clean” sa mpling and analysis methodologies for mercury when

sampling onboard ships, there is no way for EPA to dete rmine whether mercury reported here is present in AWT influent and effluent or if the mercury was the result of contamination from nearby metal or sources of airborne

contamination. “NC” indicates that percent removal was not calculated b ecause the effluent concentration was greater than the

influent concentration or the analyte was not detected in the influent samples from one or more sampled ships.

“ND” indicates not detected. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Volatile and Semivolatile Organics

EPA’s volatile and semivolatile organics anal yte list includes 84 volatile and semivolatile organics and focuses primarily on priority pollutants. ADEC/Coast Guard’s volatile and semivolatile organic analytes include approxima tely 135 organics (including all 84 analytes on EPA’s list) and is nearly identical to that analyzed for during the 2000 voluntary sampling program. Survey respondents also provided some organics data.

Table 2-8 presents AWT effluent sampling data for priority pollutant volatile and semivolatile organics that were detected in gr eater than 10% of influent and/or effluent samples (less frequent detection of analytes is consid ered not representative of the wa ste stream). AWTs generally

remove volatile and semivolatile or ganics to below detection limits.

Table 2-8. AWT Effluent Concentrat ions and Removals -- Volatile and Semivolatile Organics

Analyte 1 Unit Average Concentration in Cruise Ship AWT Influent 2 Average Conc. (± SE) in Cruise Ship AWT Effluent 3 Percent

Removal 2

2,4-Dichlorophenol μ g/l ND 8.48* (±1.08) (8 detects out of 71 samples)

Bis(2-ethylhexyl) phthalate μ g/l 46.1* (21 detects out of 25 samples) 6.66* (±0.721) (2 detects out of 71 samples) >37 to >90

Chloroform μ g/l 10.1* (5 detects out of 25 samples) 3.74* (±0.351) (27 detects out of 71 samples) NC to >67

Diethyl phthalate μ g/l 13.1* (8 detects out of 25 samples) 8.57* (±1.06) (7 detects out of 71 samples) NC to >51

Di-n-butyl phthalate μ g/l ND 8.32* (±1.07) (8 detects out of 71 samples)

Phenol μ g/l 75.0* (24 detects out of 25 samples) 20.7* (±3.00) (25 detects out of 71 samples) 25 to 45

Tetrachloroethylene μ g/l 255* (8 detects out of 25 samples) 5.59* (±1.05) (10 detects out of 71 samples) >44 to 97

Toluene μ g/l 7.67* (5 detects out of 25 samples) 3.44* (±0.346) (10 detects out of 71 samples) >1.4 to >17

Trichloroethene μ g/l 15.1* (5 detects out of 25 samples) 3.54* (±0.337) (1 detects out of 71 samples) >75

2-19December 29, 2008

1 Priority pollutant volatile and semivolatile organics det ected in at least 10% of AWT influent and/or effluent

samples.

2 Based on data collected by EPA in 2004.

3 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004; and data

collected through EPA’s 200 4 cruise ship survey. “NC” indicates that percent removal was not calculated b ecause the effluent concentration was greater than the

influent concentration or the analyte was not detected in the influent samples from one or more sampled ships.

“ND” indicates not detected. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results. The “>” symbol indicates a minimum level of removal.

Nutrients

EPA sampled for nutrients in 2004 and found th at some of the 2004 results for nitrogen compounds were anomalous. Therefore, EPA performed additional nutrient sampling in 2005

onboard the same four cruise ve ssels. ADEC/Coast Guard also monitor nutrients, and survey respondents provided some nutrient data.

Table 2-9 presents AWT effluent sampling data for nutrients. AWTs reduce ammonia, total Kjeldahl nitrogen, and total phosphorus by moderate amounts. Nitrate/nitrite levels were low and remained relatively unchanged by treatment. Nitrogen and phosphorus are likely taken up by microorganisms in the bioreactor and removed from the system in the waste biomass. It is unlikely that ammonia is removed by nitrificatio n, as nitrification would have resulted in an increase in nitrate/nitrite concentration, but these levels remained relatively unchanged.

Table 2-9. AWT Effluent Concentrations and Removals -- Nutrients

Analyte Unit Average Concentration in Cruise Ship AWT Influent 1 Average Conc. (± SE) in Cruise Ship AWT Effluent 2 Percent

Removal 1

Ammonia As Nitrogen mg/l 78.6 (35 detects out of 35 samples) 36.6* (±5.50) (136 detects out of 138 samples) 58 to 74

Nitrate/Nitrite as Nitrogen mg/l 0.325* (26 detects out of 50 samples) 3.32* (±0.653) (66 detects out of 152 samples) NC

Total Kjeldahl Nitrogen mg/l 111 (50 detects out of 50 samples) 32.5* (±3.27) (169 detects out of 170 samples) 70 to 76

Total Phosphorus mg/l 18.1 (25 detects out of 25 samples) 5.05* (±0.460) (146 detects out of 154 samples) 41 to 98

1 Based on data collected by EPA in 2004 and 2005.

2 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004 and 2005; and

data collected through EPA’s 2004 cruise ship survey. “NC” indicates that percent removal not was calculated b ecause the effluent concentration was greater than the

influent concentration or the analyte was not detected in the influent samples from one or more sampled ships.

“ND” indicates not detected. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Pesticides

EPA analyzed for 121 organohalide and orga nophosphorus pesticides in AWT influent (pesticides were not analyzed fo r in AWT effluent). Simazine was the only pesticide detected (concentration of 0.96  g/l in one sample) . EPA lists simazine as a General Use Pesticide that has

2-20December 29, 2008

been used to control broa d-leaved weeds and annual grasses in fields, berry fruit, and vegetables. Simazine is classified by EPA to be slightly toxi c to practically non-toxic. In the past, simazine has been used to control algae in swimming pool s, hot tubs, and whirlpools. (Extoxnet, 1996).

ADEC also analyzed for organophosphorus pesticid es in AWT effluent in 2003. None were

detected.

2.3.3 Marine Sanitation Device Wastewater Residuals

Waste Biomass

In addition to the treated sewage discharge ge nerated by cruise ships, waste biomass (excess biological mass from the bioreactors) is genera ted in varying amounts by all vessels that use biological treatment, including tr aditional Type II MSDs and AW Ts. Waste biomass contains organic material, often with high concentrations of bacteria and viruses, unless treated further.

In biological treatment, microorganisms (e.g., b acteria) consume the biol ogical matter in sewage, which produces biological mass (e.g., more bacteria ). The biological mass is then separated from the treated effluent using a solids separation step such as clarificat ion and/or filtration. A portion or all of the biological mass is recycled to the bioreactors to treat additional sewage.

Of the six large cruise ships with traditional biol ogical Type II MSDs that operated in Alaskan waters in 2004, all recycle all of their separated biological mass to the bioreactors. This means that excess biological mass typically exits these systems entrained in the treated effluent. (Treated effluent is disinfected prior to discharge to reduce pathogens.) However, for three of the six systems, excess biological mass also accumu lates in the bioreactors to unacceptable levels over time. Once or twice per month, a portion of the biological mass is removed from the bioreactors of these systems. According to responses to EPA’s 2004 cruise ship survey, this waste biomass is discharged without treatment outside 12 nm from shore. EPA has no sampling data for waste biomass from traditional Type II MSDs.

In AWTs, improved biological treatment results in the generation of large amounts of biological mass, while improved solids separation does not a llow for the entrainment of biological mass in the treated effluent. Biological mass is recycled to the bioreactors; however, excess biological

mass is removed from the AWT bioreactors on a da ily or weekly basis. On all four ships sampled by EPA in 2004 and 2005, excess waste biom ass is pumped to a double-bottom holding tank for discharge without treatment outside 12 nm from shore. The volume of waste biomass discharged by these four ships ranged from 370 to 6,600 gallons/day.

EPA collected one-time grab sample s of waste biomass from three of the four vessels sampled in 2004 (see Table 2-10). Most of the analytes detected in the waste biomass also were detected in the influent to treatment. For many analytes, co ncentrations in the waste biomass exceeded those in the influent to treatment, suggesting that these analytes accumul ate in the system until removed in the waste biomass stream. In particular , there were elevated metals concentrations in the waste biomass. This is expected as the AW Ts are highly efficient in removing particulate

metals from the effluent and reta ining them in the bioreactors.

2-21December 29, 2008

Table 2-10. AWT Waste Biomass Concen trations for Selected Analytes

Analyte Unit Average Concentration in Cruise Ship AWT Influent 1 Average Concentration in Cruise Ship AWT Waste

Biomass 1 Average Concentration in Cruise Ship AWT Screening Solids 1

Conventional Pollutants

Biochemical Oxygen Demand (5-Day) mg/l 526 (24 detects out of 24 samples) 3,870 (1 detect out of 1 sample) 6,610 (1 detect out of 1 sample)

Chemical Oxygen

Demand mg/l 1,140 (50 detects out of 50 samples) 9,840 (3 detects out of 3 samples) 46,200 (3 detects out of 3 samples)

Metals

Chromium, Total μ g/l 6.64* (24 detects out of 25 samples) 200 (3 detects out of 3 samples) 565 (3 detects out of 3 samples)

Copper, Total μ g/l 519 (25 detects out of 25 samples) 10,800 (3 detects out of 3 samples) 22,700 (3 detects out of 3 samples)

Lead, Total μ g/l 9.25* (22 detects out of 25 samples) 177 (3 detects out of 3 samples) 49.9* (2 detects out of 3 samples)

Nickel, Total μ g/l 22.4 (25 detects out of 25 samples) 245 (3 detects out of 3 samples) 537 (3 detects out of 3 samples)

Zinc, Total μ g/l 986 (25 detects out of 25 samples) 19,400 (3 detects out of 3 samples) 33,600 (3 detects out of 3 samples)

Volatile and Semivolatile Organics

Bis (2-ethylhexyl) phthalate μ g/l 46.1* (21 detects out of 25 samples) 40.0 (2 detects out of 2 samples) 6,250* (2 detects out of 3 samples)

Phenol μ g/l 75.0* (24 detects out of 25 samples) 628 (2 detects out of 2 samples) 563* (2 detects out of 3 samples)

Tetrachloroethylene μ g/l 255* (8 detects out of 25 samples) 5.83* (2 detects out of 3 samples) 6.19* (2 detects out of 3 samples)

Trichloroethene μ g/l 15.1* (5 detects out of 25 samples) 3.74* (1 detect out of 3 samples) ND (0 detects out of 3 samples)

Nutrients

Ammonia as Nitrogen mg/l 78.6 (35 detects out of 35 samples) 58.2 (2 detects out of 2 samples) 170 (2 detects out of 2 samples)

Total Kjeldahl Nitrogen mg/l 111 (50 detects out of 50 samples) 1,030 (3 detects out of 3 samples) 740 (3 detects out of 3 samples)

Nitrate/Nitrite as Nitrogen mg/l 0.325* (26 detects out of 50 samples) 3.51* (2 detects out of 3 samples) 1.24* (2 detects out of 3 samples)

Total Phosphorus mg/l 18.1 (25 detects out of 25 samples) 173 (3 detects out of 3 samples) 341 (3 detects out of 3 samples)

1 Based on data collected by EPA in 2004. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

2-22December 29, 2008

Screening Solids

Most sewage treatment systems use coarse screen s or presses to remove paper and other coarse solids from sewage. Depending on the specific type of screening technology used, the resulting screening solids waste varies in water content. For the four ships that EPA sampled in 2004 and 2005, two generated relatively dry screening solids and incinerated them onboard. The other two ships generated relatively wet sc reening solids. One of these sh ips disposed of the solids on

shore. The other stored the solids in double-bottom holding tanks for discharge without treatment outside 12 nm from shore (50 gallons/d ay of screening solids). EPA collected onetime grab samples of screening solids from three of the four vessels sampled in 2004 (see Table 2-10).

2.3.4 What additional non-treatment measures ar e available to manage sewage from cruise ships?

For ships that do not have AWTs traveling regu larly on itineraries beyond territorial coastal waters, Cruise Lines International Association (C LIA) standards provide that discharge will take place only when the ship is more than four miles from shore and when the ship is traveling at a speed of not less than six knots (for vessels op erating under sail, or a combination of sail and motor propulsion, the speed shall not be less than four knots). For vessels whose itineraries are fully within U.S. territorial waters, CLIA sta ndards provide that discharge shall comply fully

with U.S. and individual state legislation and regulations.

2.4 What are the potential environmental impacts associated with sewage from cruise ships?

In order to evaluate the potential environmenta l impacts of sewage waste streams from cruise ships, EPA compared the effluent from traditional Type II MSDs and AWTs discussed in subsection 2.3 (above) to (1) curr ent wastewater discharge sta ndards for ships and land-based sewage treatment plants and (2) EPA’s Nationa l Recommended Water Quality Criteria. The mixing and dilution that occurs following disc harge, which is discussed in subsection 2.4.3 below, also is relevant to an evaluation of potential environmen tal impact. Information about potential treatment technologies is discussed in subsection 2.4.4 below.

2.4.1 Comparison to wastewater discharge standards

Table 2-11 shows the comparison of average effl uent analyte concentrations from traditional Type II MSDs and from AWTs to:

 EPA’s standards for discharges from Type II MSDs on vessels;

 EPA’s standards for secondary treatment of sewage from land-based sewage treatment plants; and

 Alaska cruise ship discharge standard s under “Certain Alaskan Cruise Ship Operations” (also referred to as “Title XIV”).

2-23December 29, 2008

Traditional Type II MSD effluent concentratio ns exceeded the EPA standards for discharges from Type II MSDs (see Table 2-11). In addition, traditional Type II MSD effluent

concentrations exceeded most wastewater disc harge standards under Title XIV for continuous discharge and for secondary treatment from land-based sewage treatment plants. (Traditional Type II MSD effluent concentrations are not requ ired to meet, nor are the devices designed to meet, the Title XIV continuous discharge standards or the secondary treatment discharge standards.)

In contrast to traditional Type II MSD effluent, the average effluent concentrations from AWTs

are lower than all of the discha rge standards presented in Table 2-11, with the ex ception of total

residual chlorine. Chlorination is used to disinfect potable water produced underway or bunkered in port. From 2003 through 2005, many cr uise vessels in Alaska converted from chlorine disinfection of treated sewage a nd graywater to UV disi nfection methods during treatment system upgrades from traditional T ype II MSDs to AWTs. The switch to UV

disinfection resulted in a decline in the fre quency and magnitude of detected total residual

chlorine in cruise effluent fr om AWTs. Based on the change in disinfection methods for AWTs, the likely source for occasional detection of tota l residual chlorine in AW T effluent is residual chlorine in potable water.

Another factor contributing to the exceedance of the total residual chlorine standard is the

difference between the total residual chlorine discharge standard of 10 μ g/l and the minimum detection limit reported by most analytical labs of 100 μ g/l. The average concentrations presented in Table 2-11 are calcul ated using the detection limit fo r samples where chlorine is not detected. Therefore, although total residual chlorine was detected in only 41 of 547 samples, the average is weighted higher due to the use of th e detection limit (which is high relative to the standard) for nondetect samples. ADEC uses the 100 μ g/l minimum detection level as the compliance evaluation level for total residual ch lorine. Therefore, cruise ships reporting

nondetect values with a detection limit of 100 μ g/l are considered in compliance with the Title XIV continuous discharge standard s. Based on this evaluation cr iterion, effluent concentrations

from AWT seldom exceed the minimum detection level.

Table 2-11. Comparison of AWT and Traditio nal Type II MSD Effluent to Wastewater Discharge Standards

Analyte Average

Concentration

in AWT

Effluent 1 Average

Concentration

in Traditional Type II MSD

Effluent 2 Performance

Standards for Type II

MSDs (33 CFR

Part 159 Subpart C) Secondary

Treatment Discharge

Standards forSewage from Landbased Sewage

Treatment Plants (40 CFR 133.102) Title XIV

Standard for

Continuous Discharge in

Alaskan waters

(33 CFR Part 159 Subpart E)

Fecal coliform (fecal coliform/ 100 ml) 14.5* 2,040,000*

MPN / 100 ml <200 <20 3

Total residual chlorine ( μ g/l) 338*^ 1,070* <10

2-24December 29, 2008

Secondary

Performance Title XIV Treatment

Analyte Average

Concentration

in AWT

Effluent 1 Average

Concentration

in Traditional Type II MSD

Effluent 2 Standards for Type II

MSDs (33 CFR

Part 159 Subpart C) Discharge Standard for

Standards for Continuous Sewage from Land- Discharge in based Sewage Alaskan waters

Treatment Plants (33 CFR Part (40 CFR 133.102) 159 Subpart E)

Biochemical oxygen demand (5-day) (mg/l) 7.99* 133 <45 4

<30 5 <45 4

<30 5

Total suspended solids (mg/l) 4.49* 627 <150 <45 4

<30 5 <45 4

<30 5

pH 99.5% of pH samples between

6.0 and 9.0 90.5% of pH samples between

6.0 and 9.0 between

6.0 and 9.0 between

6.0 and 9.0

1 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004; and data

collected through EPA’s 200 4 cruise ship survey.

2 Based on data collected by the Alaska Cruise Ship Initiative (ACSI) in 2000; of 21 vessels sampled, 19 had

traditional Type II MSDs and 2 had prototype reverse osmosis treatment systems.

3 The geometric mean of the samples from the discharge during any 30-day period does not exceed 20 fecal coliform

per 100 milliliters (ml) and not more than 10% of the samples exceed 40 coliform per 100 ml.

4 The 7-day average shall not exceed this value.

5 The 30-day average shall not exceed this value. In a ddition, the 30-day average per cent removal shall not be less

than 85%. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results. ^ The minimum detection limit reported for to tal residual chlorine was generally 100 μ g/l. Because chlorine was not

detected in most AWT effluent samples (total residual chlorine was detected in only 41 of 547 samples), the average presented here is weighted higher due to the use of the detection limit for nondetect samples. See section

2.4.1 for further discussion.

2.4.2 Comparison to EPA’s National Recommended Water Quality Criteria

EPA compared average effluent concentrations from traditional Type II MSDs and from AWTs (discussed in subsection 2.3 above) to EPA’s 2006 National Recommended Water Quality Criteria (NRWQC) for saltwater aquatic life and for human hea lth (for the consumption of organisms only), and for pathogen in dicators, compared these efflue nt concentrations to criteria for the protection of human health from incidental ingestion during re creational activities (e.g., swimming and surfing) and to criteria for consum ption of shellfish. Analytes that exceed the NRWQC are discussed in greater detail in this subsection.

EPA’s NRWQC are recommended concentrations of analytes in a waterbody that are intended to protect human health and aquatic organisms and their uses from unacceptable effects from exposures to these pollutants. The NRWQC are not directly comparable to analyte concentrations in a discharge for a number of reasons. First, NRWQC not only have a concentration component, but also a duration and frequency component. Second, it is not always necessary to meet all water quality criteria within the discharge pipe to protect the integrity of a waterbody (EPA, 1991). Sometimes it is appropriate to allow for ambient concentrations above

2-25December 29, 2008

the criteria in small areas near outfalls. These are called mixing zones. To ensure mixing zones do not impair the integrity of the waterbody, it sh ould be determined that the mixing zone will not cause lethality to passing organisms and, cons idering likely pathways of exposure, that there are not significant human health risks. Third, under EPA’s water quality permitting regulations (40 CFR 122.44(d)(1)(ii)), when determining wh ether a discharge causes, has the reasonable potential to cause, or contributes to an in-stream excursion above a narrative or numeric criteria within a state water quality standard, the permitting authority is directed to use procedures which account for, among other things, the dilution of the effluent in the receiving water, where appropriate.

Nevertheless, comparison of cruise ship wa stewater discharges to NRWQC provides a conservative screen of whether these discharges might cause, have the potential to cause, or

contribute to non-attainment of the water quality standards in a given receiving water. If the concentration of a given analyt e in cruise ship wastewater is less than the NRWQC, the wastewater should not cause, have the potential to cause, or cont ribute to non-attainment of a water quality standard based on th at criterion. If the concentra tion of a particular analyte in cruise ship wastewater is great er than the NRWQC, additional analysis would determine whether the discharge would cause, have the potential to cause, or contribute to non-attainment of a water quality standard in a given receiving water. Such an analysis may be more difficult for mobile sources such as vessels than for stationary sour ces, but in general, greater mixing and dilution would be expected for mobile sources.

Pathogen Indicators

Sewage may host many pathogens of c oncern to human health, including Salmonella, shigella

, hepatitis A and E, and gastro-intestinal viru ses (National Research Council, 1993). Sewage contamination in swimming areas and shellfish beds pose potential risks to human health and the environment by increasing the rate of water borne illnesses (Pruss, 1998; Rees, 1993; National Research Council, 1993). Shellfish feed by f iltering particles from th e water, concentrate bacteria and viruses from the water column, a nd pose the risk of disease in consumers when eaten raw (National Resear ch Council, 1993; Wu, 1999).

The NRWQC for pathogen indicators referenc es the bacteria standards in EPA’s 1986 Quality Criteria for Water , commonly known as the Gold Book. The Gold Book standard for bacteria is described in terms of three different waterbody use criteria: freshwater bathing, marine water bathing, and shellfish harvesting waters. The marine water bathing and shellfish harvesting waterbody use criteria, shown in Table 2-12, we re used for comparison with cruise ship discharge concentrations.

2-26December 29, 2008

Table 2-12. National Recommended Wat er Quality Criteria for Bacteria

Waterbody

Use Gold Book Standard for Bacteria

Marine

Water Bathing Based on a statistically sufficient number of samples (generally not less than 5 samples equally spaced over a 30-day period), the geometric mean of the enterococci densities should not exceed 35 per 100 ml; no sample should exceed a one-sided confidence limit (C.L.) using the following as guidance:

1) Designated bathing beach 75% C.L. 2) Moderate use for bathing 82% C.L. 3) Light use for bathing 90% C.L. 4) Infrequent use for bathing 95% C.L. based on a site-specific log standard deviation, or if site data are insufficient to establish a log standard deviation, then using 0.7 as the log standard deviation.

Shellfish Harvesting

Waters The median fecal coliform bacter ial concentration should not exceed 14 MPN per 100 ml with not more than 10% of samples exceeding 43 MPN per 100 ml for the taking of shellfish.

Enterococci data were unavailable for traditional Type II MSD effluent. Fecal coliform data for Type II MSD effluent consistently exceeded the NRWQC for shellfish harvesting waters. Fecal

coliform concentrations in tr aditional Type II MSD effluent averaged 2,040,000 MPN/100 ml (total of 92 samples, calculation used detection limits for nondetected results) and ranged from 0 to 24,000,000 MPN/100 ml. Over 50% of the co llected samples exceeded 43 MPN/100 ml. Given the consistent exceedance of the NRWQC for bacteria, traditional Type II MSD effluent may cause, have the potential to cause, or contri bute to non-attainment of water quality standards in a given receiving water. Effluent bacteria concentrations from AWTs are consistently below the pathogen standards in Table 2-12 and theref ore should not cause, have the potential to cause, or contribute to non-attainment of water qu ality standards in a given receiving water.

Conventional Pollutants and Other Common Anal ytes

Conventional pollutants and other common analytes that have a sa ltwater aquatic life or human health (for the consumption of organisms) na rrative NRWQC include oil and grease, settleable residue, total suspended solids (see Table 2-13), and temperature (s ee Tables 2-13 and 2-14). In addition, the NRWQC include a numer ic standard for total residua l chlorine (see Table 2-15).

2-27December 29, 2008

Table 2-13. Narrative National Recommended Water Quality Criteria for Conventional Pollutants and Other Common Analytes

Analyte Gold Book Standard

Oil and Grease For aquatic life : (1) 0.01 of the lowest continuous flow 96-hour LC50 to several important freshwater and marine species, each having a demonstrated high susceptibility to oils and petrochemicals.

(2) Levels of oils or petrochemicals in the sediment which cause deleterious effects to the

biota should not be allowed.

(3) Surface waters shall be virtually free from floating nonpetroleum o ils of vegetable or animal origin, as well as petroleum-derived oils.

Settleable and Suspended Solids Freshwater fish and other aquatic life : Settleable and suspended solids should not reduce the depth of the compensation point for photosynthetic activity by more than 10% from the seasonally established norm for aquatic

life.

Temperature Marine Aquatic Life : In order to assure protection of the characteristic indigenous marine community of a waterbody segment from adverse thermal effects, the maximum acceptable increase in the weekly average temperature re sulting from artificial sources is 1°C (1.8 °F) during all seasons of the year, providing the summer ma xima are not exceeded; and daily temperature cycles characteristic of the waterbody segment sh ould not be altered in either amplitude or frequency. Summer thermal maxima, which define the upper thermal limits for the communities of the discharge area, should be established on a site-specific basis.

Oil and Grease

Annual worldwide estimates of petroleum input to the sea exceed 1.3 million metric tonnes (about 380 million gallons) (National Research Council, 2003). Levels of oil and grease of any kind can cause a variety of environmental impact s including the drowning of waterfowl because of loss of buoyancy, preventing fish respiration by coating their gills, asphyxiating benthic organisms from surface debris settling on the bottom, and reducing the natural aesthetics of waterbodies (EPA, 1986).

EPA does not have information on traditional Type II MSD or AWT effluent that would allow us to directly evaluate the narrative NRWQC for oil and grease. Oil and grease data were unavailable for traditional Type II MSD efflue nt. Oil and grease (as measured by Hexane Extractable Material or HEM) was detected in about 10% of the samples from AWT effluent, with detected amounts ranging between 5.2 and 19 mg /l. EPA did not observe any floating oils in their effluent samples; therefore, it is unlikel y that there would be floa ting oils in the receiving water. (ADEC/Coast Guard did not provide a visu al description of their samples to indicate if floating oils were observed.) Based on the limited amount of in formation available, it seems unlikely that AWT effluent would cause, have the potential to cause, or contribute to nonattainment of water quality standa rds in a given re ceiving water.

2-28December 29, 2008

Settleable and Suspended Solids

Levels of solids, either settleable or suspended, in untreated or inadequa tely treated sewage may harm marine organisms by reducing water clar ity and available oxygen levels in the water column. In addition, solids can directly impact fish and other aquatic life by preventing the successful development of eggs and larva, blanketing benthic populations, and modifying the environment such that natural movements and migration patterns are altered (EPA, 1986).

EPA did not directly evaluate traditional Type II MSD or AW T effluent against the narrative NRWQC for settleable and suspended solids beca use the criterion is based on conditions in a specific waterbody. Total suspended solids were de tected in traditional Type II MSD effluent at levels ranging from 200 to 1,480 mg/l, with an av erage of 627 mg/l. The detected values are substantially higher than the di scharge standards for sewage fro m land-based sewage treatment plants (7-day average shall not exceed 45 mg/l). A site-specific evaluation would determine if these discharge concentrations would cause, have the potential to cause, or contribute to nonattainment of water quality standa rds in a given receiving water.

In contrast, the majority of ef fluent data from AWTs were nonde tect values for both settleable solids and total suspended solids. It is unlik ely that effluent from AWTs would cause or contribute to an exceedance of water quality standards in a given receiving water.

Temperature

Temperature changes can directly affect aquatic organisms by altering their metabolism, ability to survive, and ability to reproduc e effectively. Increases in temperature are frequently linked to acceleration in the biodegradati on of organic material in a waterbody, which increases the demand for dissolved oxygen and can stress local aquatic communities.

EPA did not directly evaluate traditional Type II MSD or AW T effluent against the narrative NRWQC for temperature because the criterion is based on conditions in a specific waterbody, such as flushing and the factor s that influence flushing. The average temperature from AWT effluent measured in Alaska was 31.3 °C (tempe rature data were not available for traditional Type II MSD effluent). Local waterbody temperat ures would be needed to determine if the temperature from AWT effluent would cause, have the potential to cause, or contribute to nonattainment of water quality standards in a gi ven receiving water. Ta ble 2-14 provides a few examples of the water temperatures observed in various coastal waters across the United States. The average temperature for AWT effluent is si milar to the summer temperatures at some of these locations, and exceeds the winter temperatures by around 10 to 30 °C. A site-specific

evaluation would determine if the cruise ship discharge volume is significant enough to alter the temperature of a given waterbody. However, cons idering the size of coas tal waterbodies where cruise ships operate, it is unlikely that cruise ship effluent temper atures would cause an increase in waterbody temperature that would exceed the NRWQC.

2-29December 29, 2008

Table 2-14. Seasonal Coastal Water Tempera tures in °C Across the United States

Location State Jan Feb March April May June July Aug Sept Oct Nov Dec

Boston Harbor MA 4.44 2.22 5.00 7.22 12.22 16.11 18.89 20.00 18.89 14.44 10.56 5.56

Baltimore MD 4.44 2.78 6.11 10.56 16.11 21.11 25.00 26.11 25.00 18.89 12.22 6.11

Miami Beach FL 21.67 22.78 23.89 25.56 26.67 28.89 30.00 30.00 28.89 28.33 24.44 22.78

Key West FL 20.56 21.11 23.89 26.11 27.78 30.00 30.56 30.56 30.00 28.33 24.44 22.22

Seattle WA 8.33 7.78 7.78 8.89 10.00 11.67 12.78 13.33 13.33 12.22 10.56 9.44

Los Angeles CA 14.44 14.44 15.56 15.56 16.11 16.67 18.33 20.00 19.44 18.89 17.78 15.56

Galveston TX 12.22 12.78 16.11 21.67 25.56 28.33 30.00 30.00 28.33 23.89 19.44 15.00

Juneau AK 2.22 2.22 2.78 4.44 7.78 10.56 11.11 10.56 9.44 6.67 4.44 3.33

Honolulu HI 24.44 24.44 24.44 24.44 25.56 26.11 26.67 26.67 27.22 27.22 26.11 25.00

Source: National Oceanographic Data Center Coast Wate r Temperature Guide (www.nodc .noaa.gov/dsdt/wtg12.html)

Total Residual Chlorine

Chlorine is extremely toxic to aquatic organi sms. Chlorine concentrations as low as 3 μ g/l can result in a high mortality rate for some species (E PA, 1984a). In fish, exposure to low levels of

total residual chlorine (<1,000 μ g/l) can cause avoidance behavi or, respiratory problems, and hemorrhaging (Vetrano, 1998). Fish may recover on ce removed from the chlorine environment, but the severity of the reaction and chance of death increases as the concentration of total residual chlorine increases (Booth et al., 1981). Studies have s hown that continuous chlorination

can lead to a shift in the co mposition of phytoplankton communiti es, thus altering the benthic and fish communities that feed on them (Sanders and Ryther, 1980).

Both traditional Type II MSD and AWT effluent concentrations exceed the NRWQC for total

residual chlorine at the end of the pipe (see Table 2-15). A site-specific evaluation would determine if these discharge concentrations w ould cause, have the potential to cause, or

contribute to non-attainment of wa ter quality standards in a given receiving water. As discussed in subsection 2.4.1 above, this may be less of a c oncern for AWTs because detection limits for these samples are generally higher than the NR WQC (the minimum detection limit reported by most analytical labs was 100 μ g/l). This may artificially increase the average concentration from

AWTs because the detection limit was used for n ondetect samples when calculating an average, and the majority of samples from AWTs were nondetect samples (total residual chlorine was detected in only 41 of 547 samples in Alaska).

Detection limits do not pose a similar issue for traditional Type II MSD discharges, as total

residual chlorine was detected in 12 of 18 traditional Type II MSD effluent samples at

concentrations above the minimum detection limit. The source for total residual chlorine in traditional Type II MSD effluent is the chlorination step in wastewater treatment. Chlorination is used in traditional Type II MSDs to meet fecal coliform and to tal suspended solids standards by killing pathogens in the wastewater.

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Table 2-15. Comparison of Traditional Ty pe II MSD and AWT Effluent to Numeric National Recommended Water Quality Criteria for Total Residual Chlorine

Analyte Average

Concentration in Traditional Type

II MSD Effluent 1 Average

Concentration in

AWT Effluent 2 NRWQC

Criteria

Maximum

Concentration (CMC) 3 NRWQC

Criterion

Continuous

Concentration (CCC) 3

Total Residual Chlorine ( μ g/l) 1,070* 338*^ 13 7.5

1 Based on data collected by the Alaska Cruise Ship Initiative (ACSI) in 2000; of 21 vessels sampled, 19 had

traditional Type II MSDs and 2 had prototype reverse osmosis treatment systems.

2 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004; and data

collected through EPA’s 200 4 cruise ship survey.

3 The National Recommended Water Quality Criteria for chlorine in marine waters are expressed as chlorineproduced oxidants (CPOs) as measured by total residual chlorine. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results. ^ The minimum detection limit reported for to tal residual chlorine was generally 100 μ g/l. Because chlorine was not

detected in most AWT effluent samples (total residual chlorine was detected in only 41 of 547 samples), the average presented here is weighted higher due to the use of the detection limit for nondetect samples. See section

2.4.1 for further discussion.

Metals

In the aquatic environment, elevated concentratio ns of metals can be toxic to many species of algae, crustaceans, and fish. Exposure to metals at toxic levels can cause a variety of changes in biochemical, physiological, morphologi cal, and behavioral patterns in aquatic organisms. One of the key factors in evaluating meta l toxicity is the bioavailabilit y of the metal in a waterbody. Some metals have a strong tendenc y to adsorb to suspended organi c matter and clay minerals, or to precipitate out of solution, t hus removing the metal from the wa ter column. The tendency of a given metal to adsorb to suspended particles is typically controlled by the pH and salinity of the waterbody. If the metal is highly so rbed to particulate matter, then it is likely not in a form that organisms can process. Therefore, a high concen tration of a metal measured in the total form may not be an accurate representation of the toxi c potential to aquatic organisms. Accordingly, NRWQC for the protection of aqua tic life for metals are typically expressed in the dissolved form. In contrast, human health criteria (for the consumption of organisms) for metals are commonly expressed in the total metal form. The us e of total metals for human health criteria is because human exposure to pollutants is assumed to be through the consumption of organisms, where the digestive process is assumed to transf orm all forms of metals to the dissolved phase, thus increasing the amount of bi ologically available metals.

ACSI did not report any dissolved metal data fo r traditional Type II MSD effluent. ACSI data for total metals in traditional Type II MSD e ffluent were consistently below the NRWQC for human health (for the consumption of organisms) . AWT effluent data show most metals at levels below the NRWQC for human health and aqua tic life. Several dissolved metals that are common components of ship pi ping -- copper, nickel, and zi nc -- were found at levels approximately one to four times above NRWQC for aquatic life (see Table 2-16). A site-specific

evaluation would determine if thes e discharge concentrations would cause, have the potential to cause, or contribute to non-attainment of water quality stan dards in a given receiving water.

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However, as discussed in section 2.4.3 on Mixing and Dilution below, these analytes would likely meet NRWQC after initial mixing (about 1 to 7 meters from the ship) even when a vessel

is at rest.

Table 2-16. Comparison of AWT Effluent to National Recommended Water Quality

Criteria for Metals

Analytes that

Exceed One or More NRWQC 1 Average

Concentration in Cruise Ship AWT

Effluent 2 NRWQC

Criteria

Maximum

Concentration (CMC) NRWQC

Criterion

Continuous

Concentration (CCC)

Copper (Dissolved) ( μ g/l) 13.7* 4.8 3.1

Nickel (Dissolved) ( μ g/l) 13.3* 74 8.2

Zinc (Dissolved) ( μ g/l) 185* 90 81

1 Analytes are not listed in this table if the number of detects was not considered representative of cruise ship

effluent (i.e., less than 10% of samples), if the data were not in the correct form for comparison with NRWQC, or if the average concentration wa s driven by detection limits.

2 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004; and data

collected through EPA’s 200 4 cruise ship survey. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Semivolatile and Volatile Organics

Tables 2-17 and 2-18 present the organic compou nds detected in traditional Type II MSD and AWT effluent that exceed NRWQC. Note that e ffluent from traditional Type II MSDs was not tested for all organic compounds that have a NR WQC. The magnitude of the exceedances of NRWQC for the semivolatile and volatile organic compounds di scussed in this subsection ranged from one to four times the standard. A site-specific evaluation would determine if effluent from traditional Type II MSDs or AWTs would cause, have the potential to cause, or

contribute to non-attainment of wa ter quality standards in a given receiving water. However, as discussed in section 2.4.3 below, these analytes would likely m eet NRWQC after initial mixing (about 1 to 7 meters from the ship) even when a vessel is at rest.

Table 2-17. Comparison of Traditional Type II MSD Effluent to National Recommended Water Quality Criteria for Semivola tile and Volatile Organics

Analytes that Exceed One or More NRWQC 1,2 Average

Concentration in Traditional Type

II MSD Effluent 3 NRWQC

Human Health (for the Consumption of

Organisms)

Bis(2-ethylhexyl) phthalate ( μ g/l) 3.5* 2.2

Carbon tetrachloride ( μ g/l) 2.0* 1.6

Bromodichloromethane ( μ g/l) 34* 17

Dibromochloromethane ( μ g/l) 27* 13

Tetrachloroethylene ( μ g/l) 13* 3.3

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1 Analytes are not listed in this table if the number of detects was not considered representative of cruise ship

effluent (i.e., less than 10% of samples), if the data were not in the correct form for comparison with NRWQC, or if the average concentration wa s driven by detection limits.

2 Traditional Type II MSD effluent data were not available for all analytes that have a NRWQC. Therefore, this

table may not include all analytes that exceed NRWQC.

3 Based on data collected by ACSI in 2000; of 21 vessels sampled, 19 had traditional Type II MSDs and 2 had

prototype reverse osmosis treatment systems. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Table 2-18. Comparison of AWT Effluent to National Recommended Water Quality Criteria for Semivolatile and Volatile Organics

Analytes that Exceed One or More NRWQC 1 Average

Concentration in Cruise Ship AWT

Effluent 2 NRWQC

Human Health (for the Consumption of

Organisms)

Tetrachloroethylene ( μ g/l) 5.59* 3.3

1 Analytes are not listed in this table if the number of detects was not considered representative of cruise ship

effluent (i.e., less than 10% of samples), if the data were not in the correct form for comparison with NRWQC, or if the average concentration wa s driven by detection limits.

2 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004; and data

collected through EPA’s 200 4 cruise ship survey. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Bis(2-ethylhexyl) phthalate is a manufactured chem ical that is commonly added to plastics to

make them flexible and can be found in a vari ety of common products such as wall coverings, tablecloths, floor tiles, furniture upholstery, and shower curtains. Carbon tetrachloride is used as an industrial and chemical solvent in a variety of applications such as household cleaning fluids and as a degreaser in industrial settings. Br omodichloromethane and di bromochloromethane are chlorine byproducts that are ge nerated when chlorine used to disinfect drinking water and wastewater reacts with natural organic matter and/or bromide in water. Tetrachloroethylene is widely used in dry cleaning and for metal-degreasing.

Nutrients

Sewage contains nutrients, such as nitrogen a nd phosphorus, which are im portant elements for aquatic plant and algae growth. The influx of excess nutrients can negatively affect marine ecosystems, resulting in diebacks of corals and seagrasses, eutrophi cation (oxygen-depleted “dead” zones), and increases in harmful algal bl ooms that can alter th e seasonal progression of an ecosystem and choke or poison other plants an d wildlife (National Resear ch Council, 1993).

Ammonia is the only nutrient for which there is a numeric saltwater or human health (for the consumption of organisms) NRWQC. In the aquatic environment, ammonia exists in the unionized (NH 3 ) and ionized (NH 4 + ) form. Unionized ammonia is the more toxic form of the two with several factors such as pH, temperature, and salinity determining the toxicity to aquatic organisms. Acute levels of NH 3 that are toxic to fish can a cause a loss of equilibrium,

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hyperexcitability, and increased breathing, cardiac output, and oxygen uptake (WHO, 1986). Extreme concentrations can cause convulsions, coma, and even death.

The marine NRWQC references EPA’s1989 Ambient Water Quality Criteria for Ammonia (Saltwater) document, which includes a matrix tabl e for ammonia standards based on the pH, temperature, and salinity of a waterbody. Tabl e 2-19 presents the aver age concentration of ammonia in traditional Type II MSD and AWT effluent. Table 2-20 presents examples of the ammonia NRWQC calculated from pH, temperature, and salinity for some cruise ship ports of

call in the United States.

Table 2-19. Ammonia Concentration in Trad itional Type II MSD and AWT Effluent

Analyte Average

Concentration in Traditional Type

II MSD Effluent 1 Average

Concentration in Cruise Ship

AWT Effluent 2
Ammonia (NH 3 -N μ g/l) 145,000 36,600*

1 Based on data collected by ACSI in 2000; of 21 vessels sampled, 19 had traditional Type II MSDs and 2 had

prototype reverse osmosis treatment systems.

2 Based on data collected by ADEC/Coast Guard from 2003 to 2005; data collected by EPA in 2004; and data

collected through EPA’s 200 4 cruise ship survey. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Table 2-20. Calculated Ammonia NRWQC for Some Cruise Ship

Ports of Call in the United States

Location State pH Average Temperature (°C) Salinity (psu) Ammonia NRWQC

Criteria Maximum Concentration (CMC) (NH 3 -N μ g/l) 4 Ammonia NRWQC

Criterion Continuous Concentration (CCC) (NH 3 -N μ g/l) 4

Galveston Bay 1 TX 8.1 29.0 14.0 2,140 321

Honolulu Harbor 1 HI 8.0 25.5 34.4 4,110 617

Los Angeles Harbor 1 CA 8.1 17.4 32.6 7,110 1,110

Port of Miami 2 FL 8.0 25.3 32.0 4,110 617

Monterey Harbor 1 CA 8.1 15.3 32.9 6,860 1,070

New York Harbor 1 NY 7.5 22.1 22.9 11,500 2,960

Southeast Alaska 3 AK 7.8 12.5 20.0 15,600 2,340

Portland Harbor 1 ME 7.8 19.4 29.6 9,040 1,400

1 Data source: EPA’s EMAP National Coastal Data base (http://oaspub.epa.gov/coastal/coast.search)

2 Data source: South Florida Water Management District Monitoring Stations

(http://glades.sfwmd.gov/pls /dbhydro_pro_plsq l/water_quality_interface.main_page)

3 Data source: Draft State of Alaska Department of Environmental Conservation Large Commercial Passenger

Vessel Wastewater Discharge Ge neral Permit No. 2007DB0002 (www.dec.state.ak.us/water/cruise_ships/pdfs/ PN%20Version%20LPV%20WWGP%20-%20DRAFT.pdf)

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4 Ammonia standards were calculated based on pH, temperat ure, and salinity values for each waterbody using the matrix table provided in EPA’s 1989 Ambient Water Quality Criteria for Ammonia (Saltwater) document. In cases

where measured values fell between column and row headings for pH and temp erature the standard was approximated based on the closest value. In addition, the ammonia standards were converted from μ g-NH 3 /l to

μ g-NH 3 -N/l by multiplying the standard by 0.822.

Average effluent concentrations of ammonia fr om traditional Type II MSDs and AWTs exceed all of the waterbody ammonia standards presente d in Table 2-20. Although ammonia standards can vary from waterbody to waterbody, there is only a small range of pH, temperature, and salinity values that result in an ammonia st andard that traditional Type II MSD and AWT average effluent concentrations will not exceed. This suggests th at ammonia concentrations in traditional Type II MSDs and AWTs effluent at the end-of-pipe are likely to exceed NRWQC regardless of the receiving water parameters used to calculate the criterion. A site-specific

evaluation would determine if thes e discharge concentrations would cause, have the potential to cause, or contribute to non-attainment of water quality stan dards in a given receiving water.

In addition to the ammonia standard, EPA has es tablished criteria for the general category of nutrients. The NRWQC references EPA’s nutrien t ecoregional criteria documents for lakes and reservoirs, rivers and streams, and wetlands. At this time, EPA has not developed ecoregional criteria for estuarine or marine systems; however, EPA has developed a guidance manual for establishing nutrient criter ia in estuarine and marine waters. In the 2001 Nutrient Criteria Technical Guidance Manual for Est uarine and Coastal Marine Waters , EPA states that:

[N]utrient criteria need to be established on an individua l estuarine or coastal water system basis and must be appropriate to each waterbody type. They should not consist of a single set of national numbers or values because there is simply too much natural variation from one part of the country to a nother. Similarly, the expression of nutrient enrichment and its measurement vary from one waterbody type to another. For example, streams do not respond to phosphorus and nitrogen in the same way that lakes, estuaries

or coastal waters.

To account for the extreme variations in residence time, salinity, and density profiles observed in

estuaries and coastal wa ters, EPA recommends using a refere nce condition approach for setting nutrient criteria in marine waters (EPA, 2001) . A reference condition is defined as the comprehensive representation of data, such as median total nitrogen, total phosphorus, and chlorophyll values, from minimally impacted or “natural” sites on a waterbody or from within a similar class of waterbodies (EPA, 2001). Once a reference condition is established, modeling and local expert anal ysis of the data are used to establish a criterion for each nutrient (e.g., total nitrogen and total phosphorus) to reflect the optimal nutrient c ondition for the waterbody in the absence of cultural impacts.

Although there are no national standards for nutrient cr iteria in coastal waters, some states have established waterbody-specific or state-wide standards for nu trients based on site-specific evaluations. For example, Hawaii has established nutrient criteria for several different categories of coastal waters, such as estuaries, embaym ents, open coastal waters, oceanic waters, and specifically for Pearl Harbor. Nutrient criteria in Hawaii include limitations on total nitrogen,

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ammonia, nitrate/nitrite, tota l phosphorus, chlorophyll, and turbidity. Hawa iian nutrient criteria are expressed as follows: criteria values which the geometric mean of samples is not to exceed, criteria values which sample values are not to exceed more than 10% of the time, and criteria values which sample values are not to exceed more than 2% of the time. This tiered approach to

nutrient criteria allows for the na tural variability in nutrient concen trations in the environment. Table 2-21 provides a subset of the criteria valu es for the different wate rbody classifications in

Hawaii. Stakeholders interested in site-specific nutrient criteria should consult th eir state water quality standards for additional information on state- wide or waterbody-specific nutrient criteria.

Table 2-21. Hawaii Nutrient Criteria Values Which the Geometric Mean of Samples Is Not to Exceed

Analyte All Estuaries Except Pearl

Harbor Pearl

Harbor Embayments Open Coastal

Waters Oceanic

Waters

Total Nitrogen ( μ g/l) 200 300 200 1

150 2 150 1

110 2 50

Ammonia Nitrogen ( μ g N/l) 6 10 6 1

3.5 2 3.5 1

2 2 1

Nitrate + Nitrite ( μ g N/l) 8 15 8 1

5 2 5 1

3.5 2 1.5

Total Phosphorus ( μ g p/l) 25 60 25 1

20 2 20 1

16 2 10

Chlorophyll ( μ g/l) 2 3.5 1.5 1

0.5 2 0.3 1

0.15 2 0.06

Turbidity (NTU) 1.5 4 1.5 1

0.4 2 0.5 1

0.2 2 0.03

1 Wet criteria apply when the average fresh water inflow from the land equals or exceeds 1% of the embayment

volume per day.

2 Dry criteria apply when the average fresh water inflow fr om the land is less than 1% of the embayment volume per

day.

2.4.3 Mixing and Dilution

Although average analyte concentrations in Type II MSD and AWT discharges from cruise ships exceed several NRWQC at the end-of-pipe, th e mixing and dilution that occurs following discharge also is relevant to an evalua tion of potential environmental impact.

Dilution at Rest

A Science Advisory Panel created by the ACSI used the Cornell Mixing Zone Expert System

model to estimate dilution of effluent achieved when a vessel is at rest . Their modeling showed that a discharge rate of 50 m 3 /hr yields a dilution factor of 36 at a distance of about 4.5 m from the ship, and a dilution factor of 50 at 7 m from the ship after 43 seconds (ADEC, 2002, Appendix 8, footnote 50).

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The ADEC modeled the dilution of large cruise ship e ffluent during stationary discharge under a very conservative scenario (a neap tide in Skag way Harbor), using the Visual Plumes model. Their modeling showed the dilution factors rang ing from 5 to 60, which would occur between 1 and 7 meters from the ship (ADEC, 2004). Such dilution factors may not necessarily apply to situations where the discharge port faces a dock, pilings, or other obstruction.

The initial dilution estimated by ACSI and ADEC fo r a vessel at rest suggests that most of the pollutants in traditional Type II MSD effluent th at were above NRWQC at the end-of-pipe would likely meet NRWQC after initial mixing when the ve ssel is at rest. However, for three pollutants -- fecal coliform (see Table 2-12 and discussion belo w), total residual chlorine (see Table 2-15), and ammonia (see Tables 2-19 and 2-20) -- end- of-pipe discharge levels are high enough that they may not meet NRWQC after initial mixing when the vessel is at rest. A site specific

evaluation would determine if thes e discharge concentrations would cause, have the potential to cause, or contribute to non-attainment of water quality stan dards in a given receiving water.

As discussed in subsection 2.4.2 above, a few dissolved metals, tetrachloroethylene, chlorine,

and ammonia in the effluent from AWTs may exceed certain NRWQC at the end-of-pipe. In the case of the metals and tetrachloroethylene, the exceedances at the end-of-pipe were approximately one to four times the NRWQC. Therefore, these analytes would likely meet NRWQC after initial mixing when the vessel is at rest, based on the initial dilution factors discussed above. In the case of chlorine, th e exceedance was 45 times the most stringent NRWQC. However, the detection limit for chlorine is generally about 13 times greater than the NRWQC, and thus may artificia lly increase the average concen tration from AWTs (because the detection limit is used for nondetect samples and chlorine was only detected in 41 of 547 samples). Therefore, chlorine from AWT efflue nt also may meet NRWQC after initial mixing in

most cases.

The NRWQC for ammonia depends on pH, temperature, and salinity of the waterbody, resulting in a large range of potential values for cruise ship ports around the country (see Table 2-20). Consequently, the amount of poten tial exceedance from AWTs at the end-of-pipe varies, but the range based on the values presented in Table 2-20 is 2 to 114 times, and in most cases is less than 34 times the calculated NRWQC. Therefor e, ammonia from AWTs would likely meet most water quality standards after initial mixing when the vessel is at re st, based on the in itial dilution

factors discussed above.

It is important to note that th e initial mixing estimate s discussed above are based on ship-specific and waterbody-specific input parameters such as discharge port size, effluent flow, waterbody temperature, and salinity. Therefore, they ar e not necessarily represen tative of the dilution factors that would be achieved by cruise ships in other ports of call in the United States. Sitespecific and ship-specific calcula tions would be needed to determine the dilution for ships in

other locations.

Dilution Underway

For vessels underway, there is si gnificant additional dilution due to movement of the vessel and mixing by ship propellers. In 2001, EPA conducte d dye dispersion studies behind four large

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cruise ships while underway off the coast of Miami, Florida. The results of this study indicate that dilution of discharges behind cruise sh ips moving at between 9.1 and 17.4 knots are diluted by a factor of between 200,000:1 and 640,000:1 im mediately behind the boat (EPA, 2002). Based on these dilution factors, effluent from traditional Type II MSDs and AWTs would likely meet all NRWQC while underway.

Using this information, the ACSI Science Advi sory Panel (ADEC, 2002) determined that the dilution for a ship underway is a f unction of the speed of the cruise ship, the rate of wastewater discharge, the beam (i.e., width) of the cruise sh ip, and the draft (i.e., depth) of the cruise ship, according to the following equation:

Initial Dilution Factor = 4 * (Ship Width [m] • Ship Dr aft [m] • Ship Speed [m/sec]) for Ships Underway Volume Discharge Rate [m 3 /sec]

For example, using a typical large cruise ship (s hip width = 31 m; ship draft = 7.8 m) discharging from an AWT (volume discharge rate = 0.00707 m 3 /sec or 25 m 3 /hr) and traveling at 6 knots (3.09 m/sec) would result in a dilution factor of 420,000.

2.4.4 Potential Treatment Techno logies in Addition to AWTs

As part of its assessment of th e large cruise ship sewage and graywater discharge standards in Alaska, EPA is evaluating upgrades to AWTs and technologies that could be added on to AWTs that would improve the quality of the treated effluent in terms of nutrients, metals, and temperature. These technologies have not been used or tested on cruise sh ips for the treatment of sewage or graywater. However, EPA believes th ese technologies are potentially feasible for this application because they currently are used in other shipboard applications or because they currently are used in land-based wastewater treatment facilities and could be adapted for shipboard application. Use of these technolog ies onboard large cruise ships would require engineering studies to adapt ex isting designs and materials sel ection (e.g., metallurgy, membrane and resin selection, loading rate s, reliability, space constrai nts), operating parameters (e.g., pressures, temperatures, service and maintenan ce cycles), and training for operating personnel to ensure effective and consistent perf ormance and minimize operating costs.

Nutrient Removal Technologies

Ammonia Removal by Biological Nitrification

Biological nitrification is a two-step process that converts ammonia to nitrate using nitrifying autotrophic bacteria ( nitrosomonas and nitrobacter ) in the aerobic activated sludge process. The equation below shows the two-step conversion of ammonia to nitrate in the treatment process (Metcalf & Eddy, 1991).

Step 1: NH 4 + + 3/2O 2  NO 2 - + 2H + + H 2 O Step 2: NO 2 - + 1/2O 2  NO 3 -

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All activated sludge processes, including those sampled on the cruise ships, have nitrifying bacteria present, although their numbers are much lower than the typical microorganisms that use organic carbon (measured as BOD 5 ) as their food source. To enhance ammonia removal in the combined carbon oxidation and nitrification proc ess, land-based sewage treatment plants (publicly owned treatment works (POTWs)) have made both equipment modications and operational changes. These enhancements have allowed POTWs to achieve ammonia nitrogen levels much less than one mg/l, with a corresponding increase in effluent nitrate concentration.

Cruise ships would require equipment modificati ons and operational change s to enhance existing AWTs. Possible equipment modifications woul d include increased hydrau lic retention time and additional aeration equipment to increase the amount of oxygen transferred to the activated sludge process. Possible operati onal modifications would include longer sludge retention times and optimized temperature, pH, and alkalinity control.

Nitrification converts ammonia to nitrat e, but does not reduc e total nitrogen.

Total Nitrogen Removal by Ion Exchange

Ion exchange for ammonia removal from cruise ship effluent is a process in which effluent from the UV disinfection system would be passed thro ugh a cylindrical tank containing a weak-acid ion exchange resin. Ammonium ions (NH 4 + ) present at neutral pH would become bound to the resin due to the negative charge on the resin. When the resin is fully saturated with ammonium ions, it could be either rege nerated onboard using a highly- concentrated salt solution or regenerated shore side by a waste management company. Theoretically, ion exchange could remove 100% of ammonia. However, wastes ge nerated from resin regeneration onboard would have to be appropriate ly managed, including an assessment against the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations at 40 CFR 262.11 (see Section 6 for further discussion). The costs and potentia l environmental concerns associated with management of these wastes would need to be considered as part of the assessment of this technology.

Cruise ships would need to either purchase a nd install the add-on ion exchange technology and all necessary ancillary equipmen t, or rent ion exchange canis ters from a vendor (who would handle resin regeneration) and purchase and install all necessary ancillary equipment. Operating

and maintenance costs would include rental and labor for exchange of the rental units (if applicable), labor and salt brine costs for onboard regeneration (if applicable), operating labor, electrical costs, and mainte nance equipment costs.

Ion exchange would remove ammonia from the wastewater, thereby reduc ing total nitrogen in the effluent. (This compares to biological nitrification, which does not reduce total nitrogen but instead converts one form of nitrogen to a nother -- relatively toxic ammonia to relatively nontoxic nitrate.) This cation ex change technology would not rem ove other forms of nitrogen, such as nitrogen oxyanions and nonionic organic n itrogen. However, these forms are present at only low concentrations in AWT effluent. The average nitrate/nitrite concentration in AWT

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effluent is 3.32 mg/l, which is less than one-tenth the concentration of amm onia. There is little or no organic nitrogen in the AWT effluent as the concentration of total Kjeldahl nitrogen (which measures organic nitrogen plus ammonia) is almost the same as the concentration of ammonia.

Phosphorus Removal by Chemical Precipitation

Phosphorus is typically removed at sewage trea tment plants by one of two methods: enhanced biological uptake or chemical precipitation. Since enhanced bi ological uptake is a complex process that would require signif icant modifications to the exis ting AWT, EPA instead evaluated chemical precipitation. Chemical precipitation of phosphorus is pe rformed at sewage treatment plants by adding ferric chloride, ferrous chloride , or aluminum sulfate (alum) to the aeration tanks of the activated sludge pl ants. The precipitated iron or aluminum phosphate is removed with the biological sludge. One adva ntage of ferric or ferrous chloride over alum is that ferric or ferrous chloride typically achieve s the same removal as alum using a lower dosage. On average, phosphorus precipitation at sewage treatment plants reduces tota l phosphorus levels to 0.8 mg/l

in the effluent.

Cruise ships would need to purch ase and install a chemical feed system to add ferric or ferrous chloride to the AWT bioreactors. Operating and maintenance costs for the chemical feed system would include operating labor, energy, chemicals, and maintenance equipment.

Metals Removal Technologies

Metals Removal by Ion Exchange

Ion exchange for metals removal from cruise ship effluent is a process in which effluent from the UV disinfection system would be passed through a cylindrical tank containing a chelating resin.

Metal ions would become bound to th e resin. When the resin is full y saturated with metal ions, it could be regenerated onboard with an acid so lution. The resulting regeneration solution from metals removal would contain the target metals and have a pH less than two. Alternatively, the

resin canister could be regenerated shore-side by a waste management company. Theoretically, ion exchange could remove 100% of metals such as copper, nickel, zinc and mercury. However, wastes generated from resin regeneration onboard would have to be appropriately managed, including an assessment against the RCRA h azardous waste regulations at 40 CFR 262.11 (see Section 6 for further discussion). The costs an d potential environmental concerns associated with management of these wastes would need to be considered as part of the assessment of this technology.

Cruise ships would need to either purchase a nd install the add-on ion exchange technology and all necessary ancillary equipmen t, or rent ion exchange canis ters from a vendor (who would handle resin regeneration) and purchase and install all necessary ancillary equipment. Operating

and maintenance costs would include rental and labor for exchange of the rental units (if applicable), labor and regenera tion solution costs for onboard re generation (if applicable), operating labor, electrical costs, an d maintenance equipment costs.

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Metals Removal by Reverse Osmosis

Reverse osmosis is a process in which dissolved ions would be removed from AWT effluent using pressure to force the wa ter through a semipermeable membrane element, which would pass the water but reject most of the dissolved mate rials. This membrane separation process is expected to remove more than 90% of copper, nickel, zinc, and merc ury from AWT effluent (FILMTEC, 1998). Reverse osmosis also would re move other metals and other analytes in cruise ship effluent, including other chlorinated solvents, phe nol- and benzene-based organic compounds, and possibly pharmaceuticals and personal care products.

Reverse osmosis is expected to generate a concen trate stream that is approximately 15% of the

total influent flow. This concentrate stream w ould have to be appropria tely managed, including an assessment against the RCRA hazardous wa ste regulations at 40 CFR 262.11 (see Section 6 for further discussion). The costs and potenti al environmental concerns associated with management of this waste would need to be c onsidered as part of the assessment of this technology.

Cruise ships would need to purchase and insta ll the add-on reverse osmosis technology and all necessary ancillary equipment. Operating and maintenance would include operating labor, electricity, membrane replacement, a nd membrane cleaning chemicals.

Temperature Control

One method of reducing temperatur e would be to install a shell and tube heat exchanger that transfers heat from the AWT effluent to a recirculating cold water system . Shell and tube heat exchangers are simply designed, able to operate under varying heat loads, and easily serviced. The recirculating cold water that passes thr ough the heat exchanger to reduce the effluent temperature could be provided by either the ve ssel’s existing chilled water system or by a separate chilled water system designed specifically for heat re moval from the final effluent.

Cruise ships would need to purch ase and install the add-on heat exchanger, as well as a new chiller if the existing chiller does not provide a sufficient volume of cold water to cool the effluent. Operating and maintenance costs fo r the heat exchanger system would include operating labor (e.g., start-up and shut-down maintenance at the start and end of the Alaska cruise season), electricity, and maintenance equipment.

2.5 What action is the federa l government taking to address sewage from cruise ships?

EPA is evaluating the performance of advan ced sewage and graywater treatm ent systems. EPA is evaluating the performance of various a dvanced sewage and graywater treatment systems as part of its effort to assess whether revised or additional standards for sewage and graywater discharges from large cruise ships operating in Alaska are warranted under Title XIV (see subsection 2.2.3). Some of the results of this in tensive effort, including sampling four different AWTs and a survey questionnaire for all cr uise ships operating in Alaska in 2004, are

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summarized in this Assessment Report. EPA anticipates making these full analyses publicly available in 2009. As part of this effort, EPA, in conjunction with the ADEC, conducted a scientific survey in July 2008 using EPA’s Ocean Survey Vessel Bold to (1) measure the dilution of AWT discharges from stationa ry cruise ships, and (2) eval uate the potential environmental impact of nutrients in AWT di scharges. EPA anticipates maki ng the results of these studies publicly available in 2009.

Coast Guard has developed regulations implementing the monitoring requirements of Title XIV. Under Title XIV, the Coast Guard has implemente d an inspection regime that includes sampling of cruise ship sewage and graywater discharg es in Alaskan waters. In July 2001, the Coast Guard published a final rule (33 CFR 159.301-321) th at outlines its oversight of cruise ship sampling in Alaskan waters.

Coast Guard is conducting a review of its inspection and enforcem ent policies.

The Coast Guard has started a review of th eir inspection and enforcement policies and regulations for cruise ship environmental practices . This review includes a survey of inspectors from Coast Guard regions, focusing on MSDs, oil/water separators, and the effectiveness and feasibility of various inspection practices.

California National Marine Sanctuaries propose to prohibit cruise ship sewage discharges

. Under the National Marine Sanctuaries Act (16 U. S.C. § 1431 et seq.), the Monterey Bay, Gulf of the Farallones, and Cordell Bank National Mari ne Sanctuaries have proposed regulations to prohibit the discharge of treated and untreated sewage from la rge vessels, includ ing cruise ships (71 FR 59050, Oct. 6, 2006; 71 FR 59338, Oct. 6, 2006; 71 FR 59039, Oct. 6, 2006). NOAA is currently reviewing the comment s on these proposed rules. The Channel Islands National Marine Sanctuary has published a proposed ru le (73 CFR 16580, March 28, 2008) to revise a proposed action concerning vessel discharges ( 71 FR 29096, Oct. 5, 2006). The proposed rule containing the revision includes a pr ohibition on treated and untreated sewage from cruise ships. NOAA is currently reviewing the comments on this proposed rule.

National Park Service manages cruise ship waste stream s in Glaci er Bay National Park. The National Park Service (NPS) manages cruise ship waste streams indirectly in Glacier Bay National Park through competitively awarded con cession contracts. The NPS has jurisdiction over the submerged lands and marine waters of Gl acier Bay National Park up to 3 miles from the mean high tide line and including all of Glacier Ba y proper. Glacier Bay is a well known, very popular attraction for the cruise ship industry in Alaska. Rece nt environmental reviews and decisions allow up to two cruise ship entries pe r day into Glacier Bay pr oper during the primary visitor season. Cruise ship operations in the park are authorized under concession contracts, which are awarded under a compet itive solicitation and prospectus process. Impact on park resources is a general standard selection criterion for park co ncessions. The NPS uses waste stream management as one of a number of selecti on criteria in this regard . In the past, cruise ship operators have usually proposed to minimi ze the impact of waste streams by committing to a no-discharge policy while in the park (even if legal under applicable law) for sewage, graywater, ballast water, bilge water, cooling water, hazardous waste, and solid waste. If awarded a contract, companies must comply with their proposal. Typicall y cruise ships operate

2-42December 29, 2008

in the park for 8-10 hours and then depart. Crui se ships do not dock or transfer any wastes to shore while in the park.

2.6 Possible Options and Alternatives to Address Sewage from Cruise Ships

Based on the public comments receiv ed on the draft of this report as well as other information gathered, listed below are a wide range of optio ns and alternatives that address sewage from cruise ships. Identification of any particular option does not imply any EPA recommendation or preference for future action, or that EPA has dete rmined that any of these options are necessary or feasible, or that EPA believes a change to the status quo is warranted, or that EPA or any other entity has the legal authority to implement that option.

Prevention & Reduction

 Establish standards or best management pr actices for operation, maintenance and/or training that will decrease or eliminate the co ntaminants and/or volume of treated sewage effluent, untreated sewage, a nd/or wastewater residuals.

Control: Discharge Standards

 Revise standards for the discharge of tr eated sewage effluent, for example,

o to require attainment of national federal water quality criteria at point of discharge.

o to require attainment of national federal water quality criteria at edge of a mixing

zone.

o to require attainment of state water quality standards.

o to require attainment of secondary treatment standards for publicly owned

treatment works.

o to require attainment of the efflue nt standards in MARPOL Annex IV.

o to require the reduc tion attainable through applica tion of the best available technology economically achievable.

o to require technology that w ould eliminate remaining pollutants of concern (i.e., reduce to level below concern).

o to require use of A dvanced Wastewater Treatment systems.

o to apply Title XIV standards (which appl y in certain Alaskan waters) nationwide.

o to address additional parameters, e.g., additional pathogen indicators.

o to account for potential bioaccumulation.

o to require periodic sampling and testing.

o to require attainment of CWA section 312 standards at point of discharge.

o to require more stringent standards in areas frequented by multiple cruise ships.

Control: Geographic Restrictions on Discharge

 Restrict discharge of treated sewage effluent, for example,

o no discharge out to a certain distance (e.g., 3 m iles from shore, 12 miles from shore, 12 nautical miles from the 20-meter contour line).

o no discharge in or within a certain dist ance (e.g., 0.5 nautical miles, 4 nautical miles) of sensitive areas (e.g., shellfish, por ts, coral reefs, bathing beaches, water

2-43December 29, 2008

bodies with restricted circ ulation, flushing or inflow, marine protected areas, breeding grounds, near la rge population centers).

o shoreside discharge of all treated sewage effluent.

o withhold discharge when a system upset occurs.

o establish specific se nsitive areas (e.g., Gl acier Bay National Park waters) as NDZs for large cruise ships pursuant to CWA Section 312.

 Restrict discharge of untr eated sewage, for example,

o no discharge out to a certain di stance (e.g., 12 miles from shore).

o no discharge in any U.S. waters.

o treatment of all sewage when in U.S. waters.

 Restrict discharge of wastewat er residuals, for example,

o no discharge out to a certain di stance (e.g., 12 miles from shore).

o no discharge in any U.S. waters.

o shore-side discharge only (off-load to approved land-based facility).

o require ports where cruise ships call to accept off-loading of wastes.

Enforcement & Compliance Assurance: Monitoring

 Require sampling and testing of MSD/AWT effl uent to ensure that it meets applicable

standards

o by government agencies with enforcement authority.

o by third-parties.

o by cruise lines.

 Require onboard observers to monitor all sa mpling, monitoring, and other effluent-related requirements/to oversee discharging practices , equipment operation and maintenance, and the completion and submittal of accurate logbooks.

 Require rapid testing methods for pathogen indicators.

Enforcement & Compliance Assurance: Reporting

 Require certain report ing by cruise ship operators, for example,

o immediate notification to appropriate ag encies in the event of an MSD/AWT malfunction or upset.

o disclosure of implementation or non-imp lementation of pollution reduction and prevention practices, including but not limited to MSDs and AWTs, in all

advertisements in the U.S.

o advance notification from ships planning to discharge in U.S. waters.

o notification to appropriate ag encies of all discharges of treated sewage effluent, untreated sewage, and wastewater residuals in U.S. waters.

o notification of discharges in state wa ters to appro priate state agencies.

 Require electronic transponders to signal land -based authorities when a discharge line is opened or closed.

Enforcement & Compliance Assurance: Inspections & Enforcement

 Increase penalties for failure to meet MSD st andards, including for tampering with MSDs or selling non-certified MSDs , and failing to install an approved MSD on a ship.

 Increase inspections and inspection requirements.

2-44December 29, 2008

 Establish a funding mechanism based on the polluter-pays model that will provide revenues to develop and implement a comprehensive regulatory scheme.

 Impose uniform requirements on all ships as a condition of port entry and within waters under the jurisdiction of the U.S. consistent with international law, regardless of flag

state.

 Prohibit or otherwise restrict noncompliant vessels (and sister ships, depending on the degree of involvement by parent companies) from operating in sens itive areas of the marine environment under U.S. jurisdiction.

2-45December 29, 2008

References

Alaska Department of Environmental C onservation (ADEC). 2000a (September 13). Alaska Cruise Ship Initiative Interim Report; Memorandum to Governor Tony Knowles . Juneau, AK. ( www.dec.state.ak.us/water/cr uise_ships/pdfs/interim rep.pdf )

Alaska Departm ent of Environmental Conservation (ADEC). 2000b. Alaska Cruise Ship Initiative Part 1 Final Report . Juneau, AK. ( www.dec.state.ak.us/water/cruis e_ships/pdfs/finreportp10808.pdf )

Alaska Departm ent of Environmental Conservation (ADEC). 2001. Alaska Cruise Ship Initiative Part 2 Report . Juneau, AK. ( www.dec.state.ak.us/water/cru ise_ships/pdfs/acsireport2.pdf )

Alaska Departm ent of Environmental Conservation (ADEC). 2002. The Impact of Cruise Ship Wastewater Discharge on Alaska Waters . Juneau, AK. ( www.dec.state.ak.us/water/cruise_ ships/pdfs/im pactofcruiseship.pdf )

Alaska Departm ent of Environmental Conservation (ADEC). 2004. Assessment of Cruise Ship and Ferry Wastewater Impacts in Alaska . Juneau, AK. ( www.dec.state.ak.us/water/cruise_ships/assessreport04.htm )

Booth, P.M., Jr., Sellers, C.M., Jr., & Garrison, N.E. 1981. Effects of Intermittent Chlorination on Plasma Proteins of Rainbow Trout ( Salmo gairdneri ). Bull. of Env. Contam. & Tox 26(2): 163-170.

Choi, Charles. 2007 (March 25). Cruise Ship s Face Tough New Waste Disposal Limits - Industry Says Its Self-Policing Negates Need for Crackdown. New York Times

. ( http://travel.nytimes.com/2007/03/25/travel/25heads.htm l?pagewanted=print )

Cruise Lines Internationa l Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry Waste Management Practices and Procedures . F ort Lauderdale, FLr. ( www.cruising.org/industry/PDF/CLIA W asteManagementAttachment.pdf and www.cruising.org/industry/PDF/ CLIAW asteManagement.pdf )

Extoxnet. 1996. Pestic ide Information Profiles: Simazine . Oregon State University. ( http://extoxnet.orst .edu/pips/sim azine.htm )

FILMTEC, Dow Chemical Company. 1998 (April). FILMTEC Membranes Fact Sheet: Estimated Percent Rejection of Vari ous Solutes by FILMTEC Membranes . Midland, MI. ( http://www.h2ro.com/_FilmRemo.pdf )

Hydroxyl System s, Inc. 2007. Hydroxyl CleanSea® Integrated Shipboard Wastewater Treatment Process. Victoria, British Columbia. (http:// www.hydroxyl.com/_pdfs/literature_cleansea.pdf )

2-46December 29, 2008

Metcalf & Eddy. 1991. Wastewater Engineering: Treatment and Reuse , Third Edition. New York, NY: McGraw Hill.

National Research Council (NRC): Committee on Wastewater Management for Coastal Urban Areas, Water Science and Technology Boar d, Commission on Engineering and Technical Systems. 1993. Managing Wastewater in Coastal Urban Areas . Washington, DC: National Academy Press. ( http://www.nap.edu/cata log.php?record_id=2049#toc )

National Re search Council (NRC): Committee on Oil in the Sea: Inputs, Fates, and Effects.

2003. Oil in the Sea III: Inputs, Fates, and Effects . Washington, DC: National Academy Press. ( http://www.nap.edu/catalog.php?record_id=10388#toc )

Pruss, Annette. 1998. Review of epidem iological studies on health effects from exposure to

recreational water

. International Journal of Epidemiology 27: 1-9.

Rees, G. 1993. Health Implications of Sewage in Coastal Waters - the British Case. Marine

Pollution Bulletin 26(1): 14-19.

Sanders, J.G., & Ryther J.H. 1980. Impact of ch lorine on the species composition of marine phytoplankton. In: R.L. Jolley, et al. (Eds.), Water Chlorination: En vironmental Impact and Health Effects 3: 631. Ann Arbor, MI: Ann Arbor Science Publishers.

U.S. Coast Guard. 1999. Policy Guidance for Marine Sanitation Device Acceptance (16714/159.015). Washington, DC. ( http://www.uscg.mil/hq/gm/mse/regs/msdpolicy.html )

U.S. Environm ental Protection Agency. 1983. Health Effects Criteria for Marine Recreational

Waters (EPA-600/1-80-031). Research Triangle Park, NC. ( http://www.epa.gov/nerlcwww/mrcprt1.pdf )

U.S. Environm ental Protection Agency. 1984a. Ambient Water Quality Criteria for Chlorine (EPA 440/5-84-030). Washington, DC. ( http://www.epa.gov/ost/pc/ambientwqc/chlorine1984.pdf )

U.S. Environm ental Protection Agency. (1984b). Health Effects Criteria for Fresh Recreational

Waters (EPA-600/1-84-004). Research Triangle Park, NC. ( http://www.epa.gov/nerlcwww/frc.pdf )

U.S. Environm ental Protection Agency. 1986. Quality Criteria for Water (EPA 440/5-86-001)

. Washington, DC. ( http://www.epa.gov/waterscience/criteria/goldbook.pdf )

U.S. Environm ental Protection Agency. 1989. Ambient Water Quality Criteria for Ammonia (Saltwater) ( EPA 440/5-88-004)

. Washington, DC. ( http://www.epa.gov/waterscience /pc/am bientwqc/ammoniasalt1989.pdf )

2-47December 29, 2008

2-48 U.S. Environmental Protection Agency. 1991. T echnical Support Documentfor Water Qualitybased Toxics Control (EPA 505-290-001). Washington, DC. ( http://www.epa.gov/npdes/pubs/owm0264.pdf )

U.S. Environm ental Protection Agency. 2001. Nutrient Criteria Technical Guidance Manual:

Estuarine and Coastal Marine Waters (EPA-822-B-01-003). Washington, DC. ( http://www.epa.gov/waterscience/cri teria/nutrient/guidance/m arine/ )

U.S. Environm ental Protection Agency. 2002. Cruise Ship Plume Tracking Survey Report (EPA842-R-02-001). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise _sh ips/plumerpt2002/plumereport.pdf )

U.S. Environm ental Protection Agency. 2004. Survey Questionnaire to Determine the Effectiveness, Costs, and Im pacts of Sewage and Graywater Treatment Devices for Large Cruise Ships Operating in Alaska (EPA Form No. 7500-64). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise_ships/cruise_ship_survey.pdf )

U.S. Environm ental Protection Agency. 2006a. Sampling Episode Report for Holland America

Veendam (Sampling Episode 6503). Washington, DC. ( http://www.epa.gov/owow/oceans/crui se_sh ips/Veendam/VeendamSER.pdf )

U.S. Environm ental Protection Agency. 2006b. Sampling Episode Report for Norwegian Star (Sampling Episode 6504). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise_s h ips/FinalStar/FinalStarSERNCBI.pdf )

U.S. Environm ental Protection Agency. 2006c. Sampling Episode Report for Princess Cruise

Lines – Island Princess (Sampling Episode 6505). Washington, DC. ( http://www.epa.gov/owow/oceans/crui se_sh ips/Island/IslandSER.pdf )

U.S. Environm ental Protection Agency. 2006d. Sampling Episode Report for Holland America

Oosterdam (Sampling Episode 6506). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise_ships/Oosterdam/OosterdamFinal.pdf )

U.S. Environm ental Protection Agency. 2006e. Sampling Episode Report for Nitrogen Compounds Characterization (Sampling Episodes 6517 Through 6520). Washington, DC. ( http://www.epa.gov/owow/oceans/crui se_ships/nitrogen/nitrogen_NCBI.pdf )

Vetrano, K.M. 1998. Molecular Chlorine: Health and Environmental Effects . TRC

Environm ental Corporation. Windsor, CT.

World Health Organization (WHO) . 1986. Ammonia Environmental He alth Criteria 54. Geneva, Switzerland. ( http://www.inchem.org/documents/ehc/ehc/ehc54.htm )

Wu, R.S.S. 1999. Eutrophication, Water Born e Pathogens and Xenobiotic Com pounds: Environmental Risks and Challenges. Marine Pollution Bulletin 39: 11-22.December 29, 2008

3-1 

### Section 3: Graywater

Graywater generally means wastewater from sinks , baths, showers, laundry, and galleys. On cruise ships using Advanced Wastewater Treat ment systems (AWTs), one or more graywater sources are often treated with sewage (see Sectio n 2 for more information). On other cruise ships, graywater generally is not treated.

This section discusses the current state of information about vessel graywater, the laws regulating graywater discharges from vessels, th e potential environmental impacts of untreated cruise ship graywater discharges , and federal actions taken to address graywater from cruise ships. The types of equipment used to treat gr aywater generated on some cruise ships, and how well they remove various pollutant s, are discussed in Section 2. The conclusion of this section lists a wide range of options and alternatives that could be consid ered when addressing graywater from cruise ships.

3.1 What is graywater and how much is generated on cruise ships?

Graywater generally means wastewater from sinks , baths, showers, laundry, and galleys (see Table 3-1). The source water fo r most graywater sources is potable water. Some common graywater sources and potential character istics are listed in Table 3-2 below.

Table 3-1. Graywater Definitions

Source Graywater Definition Clean Water Act, 33 U.S.C. § 312(a)(11) Galley, bath, and shower water

International Maritime Organization Guidelines for Implementation of Annex V of MARPOL (Sec. 1.7.8) Drainage from dishwasher, shower, laundry,

bath and washbasin drains and does not include drainage from toilets, urinals, hospitals, and animal spaces, as defined in regulation 1(3) of Annex IV, as well as drainage from cargo spaces

Title XIV – Certain Alaskan Cruise Ship Operations, 33 U.S.C. § 1901 Note (Sec. 1414(4)) Only galley, dishwasher, bath, and laundry

waste water

Coast Guard regulations implementing MARPOL and the Act to Prevent Pollution from Ships, 33

CFR 151.05 Drainage from dishwasher, shower, laundry, bath, and washbasin drains and does not include drainage from toilets, urinals, hospitals, and cargo spacesDecember 29, 2008

3-2 Table 3-2. Common Sources and Characteristics of Graywater

Water Source Characteristics
Automatic Clothes Washer bleach, foam, high pH, hot water, nitrate, oil and grease, oxygen demand, phosphate, salinity, soaps, sodium, suspended solids, turbidity
Automatic Dish Washer bacteria, foam, food particles, high pH, hot water, odor, oil and grease, organic matter, oxygen demand, salinity, soaps, suspended solids, turbidity Sinks, including kitchen bacteria, food particles, hot water, odor, oil and grease, organic matter, oxygen demand, soaps, suspended solids, turbidity Bathtub and Shower bacteria, hair, hot water, odor, oil and grease, oxygen demand, soaps, suspended solids, turbidity

Source: ACSI, 2001

According to information gathered by EPA during ship visits and via responses to EPA’s survey of cruise ships operating in Alaska in 2004, the following waste streams also may be sent to the graywater system on some cruise ships: wastewat er from bar and pantry sinks, salon and day spa sinks and floor drains, interior deck drains, shop sinks and deck drains in non-engine rooms (e.g., print shops, photo processing shops, dry cleaning areas, and chemical storage areas); refrigerator and air conditioner condensate; wastewater from laundry floor drains in passenger and crew laundries; dry cleaning condensate; wastewater from dishwashers, food preparation, galley sinks, floor drains, and the food pulper; wastewater from garbage room fl oor drains and from sinks in restaurants and cafes; wastewater from whirlpool s; and wastewater from medical facility sinks

and medical floor drains

. Some of these waste streams do not fa ll within the statutory definitions of graywater listed above and thus would not be considered graywater for purposes of compliance with these statutes. The United States has successfully prosecuted violations of the Clean Water Act (CWA) for unpermitted discharges of hazardous materials from cruise ship dry cleaning operations, photographic ch emicals from photographic proc essing equipment, solvents from print shop operations, as well as other chem icals, pollutants and wa ste streams, through the

graywater system.

Estimated graywater generation rates reported in response to EPA’s 2004 cruise ship survey ranged from 36,000 to 249,000 gallons/day/vessel or 36 to 119 gallons/day/person. Graywater generation rates generally are not measured, and EPA is not able to independently confirm the accuracy of these estimated rates. It is not clear why reported rates would vary this much. Average graywater generation rates were 170,000 gallons/day/vessel and 67 gallons/day/person (see Figure 3-1). There appear s to be no relationship between per capita graywater generation rates and number of persons onboa rd (see Figure 3-2). Estima ted graywater generation rates reported in response to EPA’s 2004 cruise ship survey indicate that approximately 52% of wastewater was from accommodations, 17% from laundries, and 31% from galleys.December 29, 2008

3-3 0 5 10 15 20

<20 20-40 40-60 60-80 80-100 100-120

Per Capita Graywater Generation (gal/day/pers) 67.4 ± 3.3 gal/day/pers (mean ± SE)

n = 29

Figure 3-1. Per Capita Graywater Generation as Reported in EPA's 2004 Cruise Ship Survey 0 20 40 60 80 100 120 140

0 1,000 2,000 3,000 4,000 5,000

Persons Onboard (passengers + crew)

Figure 3-2. Graywater Generation by Persons Onboard as Reported in EPA's 2004 Cruise Ship Survey

During EPA’s 2004 sampling of four ships with AWTs, graywater generation was measured on one ship at 45 gallons/day/person (EPA, 2006a). On other ships, measurements were made of sewage plus graywater sources tr eated by the AWTs. The Alaska Cruise Ship Initiative (ADEC, 2000) used a rule of thumb of 50 to 65 gallons of graywater generate d per person per day. Residential graywater generation has been esti mated at about 51 gallons per person per day (Mayer and DeOreo, 1998).

On ships where graywater is treated, treated gray water discharge rates are nearly equivalent to graywater generation rates. Differences between th ese two rates are attributed to the volume of wastewater treatment sludge, if any, that is removed during wastew ater treatment (see subsection 2.3.3).

A typical graywater piping system may lead to several graywater holding tanks segregated by graywater source. On some ships, graywater sources may undergo limited treatment enroute to the holding tanks (e.g., gross particle filters or grease traps). Graywater from holding tanks can be sent to an AWTs for treatment, discharg ed immediately upon generation, or diverted to longer-term storage in one or more double botto m holding tanks for controlled discharge.

Cruise vessel capacity to hold gr aywater varies significantly. A ccording to responses to EPA’s 2004 cruise ship survey, graywater holding capac ity ranges from 5 to 90 hours, with an average holding capacity of 56 hours. Wh en graywater is discharged unt reated, motor-driven centrifugal pumps force the wastewater overboard approximately five meters below the ship’s waterline via one or more discharge ports, approximately 140 mm in diameter.December 29, 2008

3-4 3.2 What federal laws apply to graywater from cruise ships?

3.2.1 Clean Water Act

Graywater discharges from commer cial vessels operating in the Great Lakes are regulated under section 312 of the Clean Water Act (CWA), as discussed below. Graywater discharges from vessels operating elsewhere historically have been excluded from CWA permitting requirements through regulations at 40 CFR 122.3(a). Howeve r, as explained in section 1.1, a court order

vacated that exclusion as of December 19, 2008, and as a result, except for the Great Lakes, graywater discharges into waters of the U.S. fr om cruise ships 79 feet or longer in length are subject to NPDES permitting.

As noted in Section 2, CWA section 312 requires that vessels with installe d toilet facilities be equipped with an operable marine sanitation de vice, certified by the Coast Guard to meet EPA performance standards, in order to operate on the navigable waters of the United States. Marine sanitation devices primarily treat vessel sewage . CWA section 312 also applies to graywater

from a limited set of vessels because the statutor y definition of sewage includes graywater with respect to commercial vessels on the Great Lakes (33 U.S.C. § 1322( a)(6)). For a full discussion of CWA section 312, see S ection 2 (subsection 2.2.1).

3.2.2 Certain Alaskan Crui se Ship Operations

On December 12, 2000, Congress enacted an omnibus appropriation that included new statutory requirements for certain cruise ship discharges occurring in Al aska (Departments of Labor, Health and Human Services, and Education, an d Related Agencies Appropriations Act, 2001, Pub. L. No. 106-554, 114 Stat. 2763, enacting into law Title XIV of Division B of H.R. 5666, 114 Stat. 2763A-315, and codified at 33 U.S.C. § 1901 Note). Title XIV sets discharge standards for sewage and graywate r from certain cruise ships (t hose authorized to carry 500 or more passengers for hire) while operating in the Alexander Archipelago and the navigable waters

of the United States in the St ate of Alaska and within the Kachemak Bay National Estuarine

Research Reserve. For a full discussion of Title XIV, see Section 2 (subsection 2.2.3).

3.2.3 National Marine Sanctuaries Act

The National Marine Sanctuaries Act (NMSA; 16 U. S.C. § 1431 et seq.), as amended, authorizes the National Oceanic and Atmospheric Administration (NOAA) to designate as National Marine

Sanctuaries areas of the marine environment that have special aesthetic, ec ological, historical, or recreational qualities, an d to provide comprehensive and c oordinated conservation management

for such areas. The National Marine Sanc tuary Program manages 13 sanctuaries and the Papah ā naumoku ā kea Marine National Monument (together referred to as “sites”). Designated sites are managed according to site-specifi c management plans developed by NOAA that typically prohibit by regulation the discharge or deposit of most materi al. Discharges of graywater and treated vessel sewage, however , are sometimes allowe d provided they are

authorized under the CWA. In some sanctuaries the discharge of graywater, as well as sewage, is prohibited in special zones to protect fragile habitat, such as coral. NMSA also provides for civil penalties for violations of its requi rements or the permits issued under it.December 29, 2008

3-5 3.3 Characterization of Untreated Graywater

Except in Alaska, graywater from cruise ships cu rrently is not required to be treated before discharge. For ships traveling regularly on itiner aries beyond the territorial waters of coastal states, Cruise Lines International Association (C LIA) environmental standards provide that the discharge of graywater should o ccur only while the ship is unde rway and proceeding at a speed of not less that six knots (for vessels operating under sail, or a combination of sail and motor propulsion, the speed shall not be less than four knot s); that graywater should not be discharged in port and should not be discharged within four nautical miles fr om shore or such other distance as agreed to with authorities having jurisdic tion or provided for by local law except in an emergency, or where geographically limited (CLIA, 2006).

While some cruise ships are using AWTs to tr eat graywater (as well as sewage), detailed

information on the effluent from AWTs can be found in Section 2 and will not be repeated here. The remainder of this subsection provides info rmation on untreated graywater from two sources: EPA’s 2004 sampling of cruise ships operating in Alaska and a voluntar y sampling effort in 2000 and 2001 by the Alaska Cruise Ship Initiative (ACSI).

Data Collection

EPA Sampling : EPA sampled wastewater in 2004 from f our cruise ships that operated in Alaska to characterize graywater and sewage generated onboard and to evaluate the performance of the Zenon, Hamworthy, Scanship, and ROCHEM AW Ts (see EPA, 2006 a-d). EPA analyzed individual graywater sources (accommodations, laundry, galley, and food pulper wastewater) on each ship for over 400 analytes, including pathogen indicators, suspended and dissolved solids, biochemical oxygen demand, oil and grease, dissolve d and total metals, organics, and nutrients. In addition, laundry wastewater samples were analyzed for dioxins and furans, and galley wastewater samples were analyzed for or ganohalide and organophosphorus pesticides.

Alaska Cruise Ship Initiative (ACSI) Sampling : Concerns over cruise sh ip wastewater discharges in Alaska led to a voluntary sampling effort in 2000 by the ACSI (ADEC, 2001). Twice during the 2000 cruise season, samples were collected from each sewage and graywater discharge port from each of the 21 large cruise ships operating in Alaska. Sampling was scheduled randomly at various ports of call on all major cruise routes in Alaska. Analytes included total suspended solids, biochemical oxygen demand, chemical oxygen demand, pH, fecal coliform, total residual chlorine, free residual chlorine , and ammonia for all samples, a nd priority pollutants (metals, hydrocarbons, organochlorines) for one sample per ship. Voluntary sampling continued at the start of the 2001 cruise ship season through July 1, 2001, when Alaska state graywater and sewage discharge regulations (AS 46-03.460 - 46.03.490) came into effect. Additional sampling of untreated graywater was done under these regulations during the remainder of the 2001 cruise season. Samples collected during both the voluntary and complianc e monitoring sampling programs characterized different types of wastewater depending on ship-specific discharge configurations. The ACSI sampling results presen ted in this section include only those sampling points designated as “Mixed Graywater.” Mixe d graywater samples were collected either as generated or following longer-term stor age in double bottom holding tanks.December 29, 2008

3-6 The results of these sampling efforts are discussed in greater detail below, but to summarize, the results of analyses of graywater demonstrated th at the strength of the graywater, in terms of biological oxygen demand, chemical oxygen demand a nd total suspended solid s, is variable and that it can have high levels of fecal coliform bacteria (ADEC, 2001).

Pathogen Indicators

EPA analyzed untreated graywater sources fo r the pathogen indicato rs fecal coliform, enterococci, and E. coli . Table 3-3 presents the graywate r sampling data for the individual graywater sources. All three pat hogen indicators were detected in all four food pulper samples and in the majority of galley and acc ommodations wastewater samples.

EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater, which resulted in an estimated fecal coliform concentration of 36,000,000 CFU/100mL. ACSI/Alaska Department of Environmental Conservation (ADEC) results indicated 2,950,000 MPN/100mL fecal colif orm for untreated mixed graywater (see Table 3-3). These fecal coliform concentrations are one to thr ee orders of magnitude greater than typical fecal coliform concentrations in untreated domestic wastewater of 10,000 to 100,000 MPN/100 mL (Metcalf & Eddy, 1991).

Conventional Pollutants and Other Common Analytes

Table 3-4 shows EPA’s and ACSI/ADEC’s sampli ng results for some conventional pollutants and other common analytes in untreat ed graywater, as well as typical concentrations in untreated domestic wastewater. Key an alytes commonly used to assess wastewater strength are biochemical oxygen demand, chemical oxygen dema nd, and total suspended solids. Food pulper wastewater is the highest strength graywater sour ce, with key analyte conc entrations more than an order of magnitude greater th an those in other graywater s ources. The remaining graywater sources in order of decreasing wastewater st rength are galley wastewater, accommodations wastewater, and laundry wastewater . Average untreated graywater strength is comparable or higher in strength than untr eated domestic wastewater.

Metals

EPA sampled for 54 total and dissolved metal analyt es (26 of which are priority pollutants) and ACSI sampled for 13 priority pollutant total meta l analytes in untreated graywater. Table 3-5 presents graywater sampling data for priority pollut ant metals that were detected in greater than 10% of either the EPA or ACSI/ADEC samples (less frequent detection of an alytes is considered not representative of the waste stream). Copper, nickel, and zinc, which showed the highest concentrations, are common components of ship piping.3-7Table 3-3. Comparison of Untreated Graywater Concentrationsto Untreated Domestic Wastewater -- Pathogen IndicatorsAnalyteGraywaterSourceUnitsAverageConcentration1RangeNumberof Results<200Number ofResults201 to<100,000Number ofResults100,001 to<1,000,000Number ofResults>1,000,000Accommodations MPN/100 mL83,500# ND(1.00) - 1,050,000(17 detects out of 21 samples)6 7 7 1Laundry MPN/100 mL1,930* ND(1.00) - 7,700(5 detects out of 21 samples)19 2 0 0Galley MPN/100 mL935,000# ND(1.00) - >24,200,000(21 detects out of 22 samples)1 10 7 4Food Pulper MPN/100 mL336,000** 17,300 - 2,420,000(4 detects out of 4 samples)0 3 0 1E. ColiGraywater2MPN/100 mL292,000#Accommodations MPN/100 mL532# ND(1.00) - >2,420(16 detects out of 21 samples)11 10 0 0Laundry MPN/100 mL253# ND(1.00) - >2,420(7 detects out of 21 samples)17 4 0 0Galley MPN/100 mL6,750** 95 – 51,700(22 detects out of 22 samples)3 19 0 0Food Pulper MPN/100 mL411,000**10,400 – 1,600,000(4 detects out of 4 samples)0 3 0 1EnterococciGraywater2MPN/100 mL8,920#Accommodations CFU/100 mL36,700,000# 1,500 - 120,000,000(18 detects out of 19 samples)0 7 6 6Laundry CFU/100 mL7,940# ND(2.00) - >60,000(11 detects out of 19 samples)11 8 0 0Galley CFU/100 mL29,100,000** 1,900 - 910,000,000(19 detects out of 19 samples)0 4 6 9Food Pulper CFU/100 mL87,400 29,000 - 170,000(4 detects out of 4 samples)0 2 2 0Graywater2CFU/100 mL36,000,000#FecalColiformGraywater (ASCI/ ADEC Data)MPN/100 mL2,950,000#3ND(2.00) – 32,000,000(134 detects out of 156 samples)36 29 42 491Based on data collected by EPA in 2004 unless otherwise noted.3-82EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater.3Based on data collected by ACSI/ADEC in 2000 and 2001.* Average includes at least one nondetect value; thiscalculation uses detection limits for nondetected results.** Average includes at least one result flagged by the laboratoryas not diluted sufficiently; therefore, this average represents a minimum value.# Average includes at least one nondetect value (calculation uses detection limits for nondetected results) and at least one result flagged by the laboratory as notdiluted sufficiently.The “>” symbol indicates that the laboratoryflagged the sample as not diluted sufficiently; therefore, this represents a minimum value for the sample.3-9Table 3-4. Comparison of Untreated Graywater Concentraions toUntreated Domestic Wastewater -- Conventional Pollutants andOther Common AnalytesAnalyteUnitAverageConcentrationin UntreatedCruise ShipAccommodationsWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipLaundryWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGalleyWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipFood PulperWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGraywater(EPA Data)2AverageConcentrationin UntreatedCruise ShipGraywater(ACSI/ADECData)3Concentrationin UntreatedDomesticWastewater4Alkalinity mg/l 48.1*(11 detects out of12 samples)71.6(12 detects out of12 samples)57.7*(9 detects out of12 samples)ND(57.5)(0 detects out of 4samples)53.8*(32 detects out of40 samples)57.8(4 detects out of 4samples)Biochemical OxygenDemand (5-Day)mg/l 260(11 detects out of11 samples)83.8(11 detects out of11 samples)1,490(11 detects out of11 samples)30,500(4 detects out of 4samples)1,140(37 detects out of37 samples)354(42 detects out of42 samples)110 to 400Chemical OxygenDemandmg/l 723(12 detects out of12 samples)257(12 detects out of12 samples)1,830(12 detects out of12 samples)26,400(4 detects out of 4samples)1,890(40 detects out of40 samples)1,000(41 detects out of41 samples)250 to 1,000Chloride mg/l 66.6(12 detects out of12 samples)22.4(12 detects out of12 samples)145(12 detects out of12 samples)1,240(4 detects out of 4samples)125(40 detects out of40 samples)NCConductivityμS/cm 236(43 detects out of43 samples)74.4(43 detects out of43 samples)647(48 detects out of48 samples)4,060(7 detects out of 7samples)427(141 detects out of141 samples)2,250(21 detects out of21 samples)Free Residual Chlorineμg/l NR NR NR NR NR 0.256*(6 detects out of43 samples)Hardness mg/l 38.2(12 detects out of12 samples)14.1(12 detects out of12 samples)65.1(12 detects out of12 samples)449(3 detects out of 3samples)54.5(39 detects out of39 samples)NCHexane ExtractableMaterialmg/l 37.6(12 detects out of12 samples)13.4(11 detects out of11 samples)172(12 detects out of12 samples)1,960(3 detects out of 3samples)149(38 detects out of38 samples)78.0Oil and Grease(4 detects out of 4samples)pH83.3% of pHsamples arebetween6.0 and 9.0(35 of 42 samples)81.8% of pHsamples arebetween6.0 and 9.0(36 of 44 samples)50.0% of pHsamples arebetween6.0 and 9.0(24 of 48 samples)0% of the pHsamples arebetween6.0 and 9.0(0 of 8 samples)66.9% of pHsamples arebetween6.0 and 9.0(95 of 142 samples)76.7% of pHsamples arebetween6.0 and 9.0(33 out of 43Between6.0 and 9.03-10AnalyteUnitAverageConcentrationin UntreatedCruise ShipAccommodationsWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipLaundryWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGalleyWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipFood PulperWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGraywater(EPA Data)2AverageConcentrationin UntreatedCruise ShipGraywater(ACSI/ADECData)3Concentrationin UntreatedDomesticWastewater4samples)Salinity ppt 1.72*(42 detects out of43 samples)1.26(43 detects out of43 samples)2.56(48 detects out of48 samples)6.05(7 detects out of 7samples)2.08*(140 detects out of141 samples)NCSettable Residuemg/l 4.43*(7 detects out of11 samples)0.432*(3 detects out of11 samples)18.7(11 detects out of11 samples)728(4 detects out of 4samples)25.6*(25 detects out of37 samples)1.10*(2 detects out of 4samples)Silica Gel Treated HexaneExtractable Materialmg/l ND(5.89)(0 detects out of12 samples)ND(5.37)(0 detects out of11 samples)8.39*(2 detects out of12 samples)821*(2 detects out of 3samples)36.6*(4 detects out of 38samples)NCSulfate mg/l 41.5(12 detects out of12 samples)16.3(12 detects out of12 samples)61.0(12 detects out of12 samples)194(4 detects out of 4samples)49.9(40 detects out of40 samples)NCTemperature °C 34.7(42 detects out of42 samples)48.6(44 detects out of44 samples)41.9(48 detects out of48 samples)66.5(8 detects out of 8samples)39.6(142 detects out of142 samples)NCTotal Dissolved Solids mg/l 244(12 detects out of12 samples)191(12 detects out of12 samples)897(12 detects out of12 samples)5,160(3 detects out of 3samples)578(39 detects out of39 samples)NCTotal Organic Carbon mg/l 78.9(12 detects out of12 samples)60.2(12 detects out of12 samples)358(12 detects out of12 samples)21,300(4 detects out of 4samples)535(40 detects out of40 samples)481(4 detects out of 4samples)Total Residual Chlorine mg/l NRNRNRNRNR0.372*(9 detects out of43 samples)Total Suspended Solids mg/l 207(12 detects out of12 samples)37.1(12 detects out of12 samples)877(12 detects out of12 samples)16,500(3 detects out of 3samples)704(39 detects out of39 samples)318(43 detects out of43 samples)100 to 350Turbidity NTU 186(43 detects out of43 samples)20.9(41 detects out of41 samples)408(33 detects out of33 samples)NC 224(117 detects out of117 samples)1Based on data collected by EPA in 2004.2EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater.3-113Based on data collected by ACSI/ADEC in 2000 and 2001.4Metcalf & Eddy, 1991.* Average includes at least one nondetect value; thiscalculation uses detection limits for nondetected results.“NC” indicates that this information was not collected.“NR” indicates that this information was not reported. Equipment used to measure free and total chlorine is not suitable for measuring low levels of chlorine andis subject to interferences; accordingly, field measurements collected for the sole purpose determining sample preservation requirements are not reported.3-12Table 3-5. Untreated Graywater Concentrations -- MetalsAnalyteUnitAverageConcentrationin UntreatedCruise ShipAccommodationsWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipLaundryWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGalleyWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipFood PulperWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGraywater(EPA Data)2AverageConcentrationin UntreatedCruise ShipGraywater(ACSI/ADECData)3Antimony, Totalμg/l ND(3.99)(0 detects out of 12samples)ND(3.99)(0 detects out of 12samples)ND(3.99)(0 detects out of 12samples)6.67*(3 detects out of 4samples)4.09*(3 detects out of 40samples)1.34*(4 detects out of 6samples)Arsenic, Totalμg/l ND(2.16)(0 detects out of 12samples)ND(2.16)(0 detects out of 12samples)2.44*(3 detects out of 12samples)5.85*(1 detect out of 4samples)2.25*(4 detects out of 40samples)1.22(6 detects out of 6samples)Beryllium, Totalμg/l 0.0688*(1 detect out of 12samples)ND(0.0620)(0 detects out of 12samples)0.116*(2 detects out of 12samples)ND(0.0448)(0 detects out of 4samples)0.0736*(3 detects out of 40samples)0.0907*(4 detects out of 6samples)Cadmium, Totalμg/l 0.463*(1 detect out of 12samples)0.270*(1 detects out of 12samples)0.391*(6 detects out of 12samples)1.29(4 detects out of 4samples)0.452*(12 detects out of 40samples)0.541*(10 detects out of 30samples)Chromium, Totalμg/l 22.4*(11 detects out of 12samples)2.25*(10 detects out of 12samples)7.03*(10 detects out of 12samples)16.7(4 detects out of 4samples)16.7*(35 detects out of 40samples)4.17*(8 detects out of 30samples)Chromium, Dissolvedμg/l 1.49*(9 detects out of 12samples)1.38*(6 detects out of 12samples)2.04*(10 detects out of 12samples)5.16(3 detects out of 3samples)1.70*(28 detects out of 39samples)NCCopper, Totalμg/l 677(12 detects out of 12samples)278(12 detects out of 12samples)383(12 detects out of 12samples)208(4 detects out of 4samples)510(40 detects out of 40samples)483*(20 detects out of 30samples)Copper, Dissolvedμg/l 167(12 detects out of 12samples)253(12 detects out of 12samples)232(12 detects out of 12samples)15.3(3 detects out of 3samples)195(39 detects out of 39samples)NCLead, Totalμg/l 14.8*(9 detects out of 12samples)5.77*(9 detects out of 12samples)21.2*(10 detects out of 12samples)14.1*(3 detects out of 4samples)12.3*(31 detects out of 40samples)19.3*(11 detects out of 30samples)Lead, Dissolvedμg/l 2.48*(5 detects out of 12samples)3.76*(8 detects out of 12samples)10.2*(7 detects out of 12samples)2.87*(1 detects out of 3samples)4.25*(21 detects out of 39samples)NC3-13AnalyteUnitAverageConcentrationin UntreatedCruise ShipAccommodationsWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipLaundryWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGalleyWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipFood PulperWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGraywater(EPA Data)2AverageConcentrationin UntreatedCruise ShipGraywater(ACSI/ADECData)3Mercury, Total4μg/l 0.153*(8 detects out of 12samples)0.0518*(7 detects out of 12samples)0.0703*(6 detects out of 12samples)0.197*(2 detects out of 4samples)0.100*(23 detects out of 40samples)0.0733*(2 detects out of 24samples)Mercury, Dissolved4μg/l 0.155*(5 detects out of 12samples)0.0895*(6 detects out of 12samples)0.108*(6 detects out of 12samples)0.143*(2 detects out of 3samples)0.122*(19 detects out of 39samples)NCNickel, Totalμg/l 34.0(12 detects out of 12samples)6.19(12 detects out of 12samples)29.2(12 detects out of 12samples)22.4(4 detects out of 4samples)29.7(40 detects out of 40samples)48.7*(12 detects out of 30samples)Nickel, Dissolvedμg/l 17.2(12 detects out of 12samples)4.85(12 detects out of 12samples)26.4(12 detects out of 12samples)31.1(3 detects out of 3samples)18.2(39 detects out of 39samples)NCSelenium, Totalμg/l 1.07*(4 detects out of 12samples)1.26*(3 detects out of 12samples)4.93*(9 detects out of 12samples)26.9(4 detects out of 4samples)3.37*(20 detects out of 40samples)4.45*(4 detects out of 6samples)Selenium, Dissolvedμg/l 1.05*(4 detects out of 12samples)1.02*(4 detects out of 12samples)4.74*(7 detects out of 12samples)22.1(3 detects out of 3samples)3.04*(18 detects out of 39samples)NCSilver, Totalμg/l 2.07*(1 detect out of 12samples)1.73*(6 detects out of 12samples)1.13*(4 detects out of 12samples)1.04*(1 detect out of 4samples)1.82*(12 detects out of 40samples)0.880*(13 detects out of 30samples)Thallium, Totalμg/l 1.13*(1 detects out of 12samples)ND(0.765)(0 detects out of 12samples)0.405*(2 detects out of 12samples)0.550*(3 detects out of 4samples)0.930*(6 detects out of 40samples)NDThallium, Dissolvedμg/l ND(0.405)(0 detects out of 12samples)0.407*(1 detects out of 12samples)0.405*(4 detects out of 12samples)0.296*(1 detects out of 3samples)0.403*(6 detects out of 39samples)NCZinc, Totalμg/l 3,130(12 detects out of 12samples)345(12 detects out of 12samples)1,460(12 detects out of 12samples)6,380(4 detects out of 4samples)2,540(40 detects out of 40samples)790*(19 detects out of 30samples)Zinc, Dissolvedμg/l 792(12 detects out of 12samples)266(12 detects out of 12samples)1,070(12 detects out of 12samples)47,800(3 detects out of 3samples)1,610(39 detects out of 39samples)NC3-141Based on data collected by EPA in 2004.2EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater.3Based on data collected by ACSI/ADEC in 2000 and 2001.4Because it was not possible to incorporate “clean” sampling andanalysis methodologies for mercury when sampling onboard ships, there is no way for EPA todetermine whether mercury reported here is present in the graywater or if the mercury was the result of contamination from nearby metal or sources of airbornecontamination.* Average includes at least one nondetect value; thiscalculation uses detection limits for nondetected results.“NC” indicates that this information was not collected.“ND” indicates that the analyte was not detected(number in parentheses is detection limit).3-15 Food pulper wastewater containe d the highest average concentr ation of 10 of the 21 metal analytes listed in Table 3-5. Six metal analytes were detected in accomm odations wastewater at the highest average concentration. Galley and la undry wastewater contai ned the highest average concentration of only three and tw o metal analytes, respectively.

Total and dissolved copper, total and dissolved nick el, and total and dissolve d zinc were detected in all EPA graywater samples. These six metal analytes also were detected at the highest average concentrations among the priority metal an alytes. Total copper, total nickel, and total zinc were also the priority pollutant metal analyt es detected at the highest average concentrations in ACSI/ADEC graywater samples.

Volatile and Semivolatile Organics

EPA tested for 84 volatile and semivolatile organi cs, of which approximately 85% are priority pollutants. ACSI/ADEC sampled for almost 140 pr iority pollutant and non priority pollutant volatile and semivolatile organic analytes. Table 3-6 presents untreated graywater sampling data for priority pollutant volatile and semivolatile organi cs that were detected in greater than 10% of either EPA or ACSI/ADEC samples (less frequent detection of analytes is considered not representative of the waste stream).

Analytes listed in Table 3-6 that were detected at the highest average concentration and/or frequency include plasticizer s (phthalates), chlorine bypr oducts (e.g., chloroform and bromodichloromethane), and compounds naturally produced in foods (phenol).

Nutrients

Table 3-7 shows average nutrient concentrations in untreated graywater, as well as typical

concentrations in untreated domestic wastewater . Food pulper wastewater contains the highest average concentration of nutrients.

Average nitrate/nitrite, total Kj eldahl nitrogen, and total phosphorus concentr ations in untreated graywater are comparable to concentrations in untreated domestic wastewater. The average ammonia concentration in untreated graywater is much less than that in untreated domestic wastewater (because the presence of a mmonia is indicative of human waste).3-16Table 3-6. Untreated Graywater Concentrations -- Volatile and Semivolatile OrganicsAnalyteUnitAverageConcentrationin UntreatedCruise ShipAccommodationsWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipLaundryWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGalleyWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipFood PulperWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGraywater(EPA Data)2AverageConcentrationin UntreatedCruise ShipGraywater(ACSI/ADECData)31,2-Dichloroethaneμg/l ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(5.24)(0 detects out of 4samples)ND(7.37)(0 detects out of 40samples)0.426*(4 detects out of 24samples)2,4-Dichlorophenolμg/l ND(11.2)(0 detects out of 12samples)ND(10.1)(0 detects out of 12samples)ND(10.4)(0 detects out of 12samples)ND(80.2)(0 detects out of 4samples)ND(11.9)(0 detects out of 40samples)0.275(6 detects out of 6samples)Bis(2-ethylhexyl) phthalateμg/l 25.3*(11 detects out of12 samples)56.3(12 detects out of12 samples)155*(11 detects out of12 samples)526*(2 detects out of 4samples)71.9*(36 detects out of 40samples)22.4*(21 detects out of 30samples)Bromodichloromethaneμg/l ND(7.50)(0 detects out of 12samples)7.50*(1 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(5.24)(0 detects out of 4samples)7.37*(1 detects out of 40samples)3.92*(15 detects out of 30samples)Bromoformμg/l ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(5.24)(0 detects out of 4samples)ND(7.37)(0 detects out of 40samples)1.97*(9 detects out of 30samples)Butyl benzyl phthalateμg/l ND(10.3)(0 detects out of 12samples)ND(10.0)(0 detects out of 12samples)ND(10.0)(0 detects out of 12samples)ND(80.2)(0 detects out of 4samples)ND(11.4)(0 detects out of 40samples)7.74*(6 detects out of 30samples)Chloroformμg/l 7.53*(1 detect out of 12samples)48.6*(11 detects out of12 samples)7.99*(4 detects out of 12samples)ND(5.24)(0 detects out of 4samples)13.5*(16 detects out of 40samples)13.3*(20 detects out of 30samples)Dibromochloromethaneμg/l ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(5.24)(0 detects out of 4samples)ND(7.37)(0 detects out of 40samples)3.08*(11 detects out of 30samples)Diethyl phthalateμg/l 14.1*(5 detects out of 12samples)10.6*(3 detects out of 12samples)11.1*(1 detect out of12 samples)ND(80.2)(0 detects out of 4samples)14.1*(9 detects out of 40samples)5.41*(18 detects out of 30samples)Di-n-butyl phthalateμg/l ND(10.3)(0 detects out of 12samples)ND(10.0)(0 detects out of 12samples)ND(10.0)(0 detects out of 12samples)ND(80.2)(0 detects out of 4samples)ND(11.4)(0 detects out of 40samples)2.96*(15 detects out of 30samples)3-17AnalyteUnitAverageConcentrationin UntreatedCruise ShipAccommodationsWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipLaundryWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGalleyWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipFood PulperWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGraywater(EPA Data)2AverageConcentrationin UntreatedCruise ShipGraywater(ACSI/ADECData)3Di-n-octyl phthalateμg/l ND(10.3)(0 detects out of 12samples)ND(10.0)(0 detects out of 12samples)ND(10.0)(0 detects out of 12samples)ND(80.2)(0 detects out of 4samples)ND(11.4)(0 detects out of 40samples)0.688(6 detects out of 6samples)Ethylbenzeneμg/l ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(5.24)(0 detects out of 4samples)ND(7.37)(0 detects out of 40samples)0.563*(10 detects out of 30samples)Methylene chlorideμg/l ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(5.24)(0 detects out of 4samples)ND(7.37)(0 detects out of 40samples)1.31*(4 detects out of 30samples)Phenolμg/l 46.2*(9 detects out of 12samples)55.3*(11 detects out of12 samples)58.3(12 detects out of12 samples)93.8*(2 detects out of 4samples)52.5*(34 detects out of 40samples)1.16*(5 detects out of 30samples)Tetrachloroethyleneμg/l 18.1*(1 detect out of 12samples)ND(7.50)(0 detects out of 12samples)ND(7.50)(0 detects out of 12samples)ND(5.24)(0 detects out of 4samples)11.4*(1 detect out of 40samples)10.7*(9 detects out of 30samples)Tolueneμg/l 28.0*(1 detects out of 12samples)ND(7.50)(0 detects out of 12sample)9.70*(5 detects out of 12samples)ND(5.24)(0 detects out of 4samples)21.3*(6 detects out of 40samples)0.589*(6 detects out of 30samples)Trichloroetheneμg/l 10.2*(1 detect out of 12sample)ND(7.50)(0 detects out of 12sample)ND(7.50)(0 detects out of 12sample)ND(5.24)(0 detects out of 4sample)8.40*(1 detect out of 40samples)3.12*(4 detects out of 30samples)1Based on data collected by EPA in 2004.2EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater.3Based on data collected by ACSI/ADEC in 2000 and 2001.* Average includes at least one nondetect value; thiscalculation uses detection limits for nondetected results.“ND” indicates that the analyte was not detected(number in parentheses is detection limit).3-18Table 3-7. Comparison of Untreated Graywater Concetrations to Untreated Domestic Wastewater -- NutrientsAnalyteUnitAverageConcentrationin UntreatedCruise ShipAccommodationsWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipLaundryWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGalleyWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipFood PulperWastewater(EPA Data)1AverageConcentrationin UntreatedCruise ShipGraywater(EPA Data)2AverageConcentrationin UntreatedCruise ShipGraywater(ACSI/ADECData)3Concentrationin UntreatedDomesticWastewater4Ammonia - Nitrogen mg-N /l 0.383*(6 detects out of12 samples)0.439*(6 detects out of12 samples)2.93*(8 detects out of12 samples)17.5*(3 detects out of 4samples)2.13*(23 detects out of40 samples)2.21*(28 detects out of30 samples)12 to 50Nitrate/Nitrite mg/l0.0858*(9 detects out of12 samples)0.100(12 detects outof 12 samples)0.0477*(8 detects out of12 samples)0.335*(3 detects out of4 samples)0.0872*(32 detects out of40 samples)0.00900(3 detects out of 3samples)0Total Kjeldahl Nitrogen mg/l 15.2(12 detects out of12 samples)4.14*(11 detects out of12 samples)38.8(12 detects out of12 samples)188(4 detects out of 4samples)26.2*(39 detects out of40 samples)11.1(4 detects out of 4samples)20 to 85Total Phosphorus mg/l 2.20(12 detects out of12 samples)4.31(12 detects out of12 samples)20.0(12 detects out of12 samples)186(4 detects out of 4samples)10.1(40 detects out of40 samples)3.34(4 detects out of 4samples)4 to 151Based on data collected by EPA in 2004.2EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater.3Based on data collected by ACSI/ADEC in 2000 and 2001.4Metcalf & Eddy, 1991.* Average includes at least one nondetect value; thiscalculation uses detection limits for nondetected results.December 29, 2008

3-19 3.4 What are the potential environmental impacts associated with untreated graywater from cruise ships?

In order to evaluate the potential environmen tal impacts of untreated graywater waste streams from cruise ships, EPA compared data from untreated graywater discussed in subsection 3.3 above to (1) current wastewater discharge sta ndards for ships and land-based sewage treatment plants and (2) EPA’s National Recommended Wate r Quality Criteria (NRWQC). Detailed information on treated graywater (that is, the e ffluent from Advanced Wastewater Treatment systems) can be found in Section 2, and will not be repeated here. Also relevant to an evaluation of potential environmental impact is the mixing a nd dilution that occurs following discharge; this

is discussed in subs ection 3.4.3 below.

3.4.1 Comparison to wastewater discharge standards

Table 3-8 shows the comparison of average anal yte concentrations from EPA and ACSI/ADEC untreated graywater sampling to:

 EPA’s standards for discharges from Type II MSDs on vessels;

 EPA’s standards for secondary treatment of sewage from land-based sewage treatment plants; and

 Alaska cruise ship discharge standard s under “Certain Alaskan Cruise Ship Operations” (also referred to as “Title XIV”).

Untreated cruise ship graywater concentrations exceeded the EPA standards for discharges from Type II MSDs (for fecal coliform and total suspe nded solids). In addition, untreated graywater

concentrations exceeded all wastewater discha rge standards under Title XIV for continuous discharge from cruise ships in Alaska, and seco ndary treatment discharge standards from landbased sewage treatment plants. (Graywater is not required to meet any of the standards shown in Table 3-8, with the exception that continuous graywater discharg es in Alaska waters must achieve the Title XIV continuous discharge standards.)

Table 3-8. Comparison of Untreated Crui se Ship Graywater to Wastewater Discharge

Standards

Analyte Average

Concentration

in Untreated Cruise Ship Graywater (EPA Data) 1 Average

Concentration

in Untreated Cruise Ship Graywater (ACSI/ADEC Data) 2 Performance

Standards for Type II MSDs (33 CFR Part 159 Subpart C) Secondary

Treatment Discharge

Standards for Sewage from

Land-based Sewage Treatment

Plants (40 CFR 133.102) Title XIV

Standards for

Continuous Discharge in

Alaskan Waters

(33 CFR Part 159 Subpart E)

Fecal coliform (fecal coliform/ 100 mL) 36,000,000* 2,950,000*

MPN/ 100 mL <200 <20 3

Total residual chlorine ( μ g/l) NR 372*^ <10December 29, 2008

3-20 Biochemical oxygen demand (5-day) (mg/l) 1,140 354 <45 4

<30 5 <45 4

<30 5

Total suspended

solids (mg/l) 704 318 <150 <45 4

<30 5 <45 4

<30 5

pH 67% of pH samples between

6.0 and 9.0 77% of pH samples

between 6.0 and

9.0 between

6.0 and 9.0 between

6.0 and 9.0

1 Based on EPA sampling data from 2004.

2 Based on data collected by ACSI/ADEC in 2000 and 2001.

3 The geometric mean of the samples from the discharge during any 30-day period does not exceed 20 fecal coliform

per 100 milliliters (ml) and not more than 10% of the samples exceed 40 coliform per 100 ml.

4 The 7-day average shall not exceed this value.

5 The 30-day average shall not exceed this value. In a ddition, the 30-day average per cent removal shall not be less

than 85%. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

^ The minimum detection limit for total residual chlori ne reported by most analytical labs is 100 μ g/l.

“NR” indicated that this information was not reported; equipment used to m easure free and total chlorine is not

suitable for measuring low levels of chlorine and is subj ect to interferences. Accordingly, field measurements collected solely for determining simple preservation requirements are not provided.

3.4.2 Comparison to EPA’s National Recommended Water Quality Criteria

EPA compared average untreated graywater co ncentrations from EPA’s and ACSI/ADEC’s sampling (discussed in subsection 3.3 above ) to EPA’s 2006 National Recommended Water Quality Criteria (NRWQC) for sa ltwater aquatic life and for human health (for the consumption of organisms only), and for pat hogen indicators, compared these effluent concentrations to criteria for the protection of hu man health from incidental ingestion during recreat ional activities (e.g., swimming and surfing) and to criteria for consumption of sh ellfish. Analytes that exceed the NRWQC are discussed in greater de tail in the subsections below.

EPA’s NRWQC are recommended concentrations of an alytes in a waterbody that are intended to protect human health and aquatic organisms and their uses from unacceptable effects from exposures to these pollutants. The NRWQC are not directly comparable to analyte concentrations in a discharge for a number of reasons. First, NRWQC not only have a concentration component, but also a duration and frequency component. S econd, it is not always necessary to meet all water quality criteria within the discharge pipe to pr otect the integrity of a waterbody (EPA, 1991). Sometimes it is appropriat e to allow for ambient concentrations above

the criteria in small areas near outfalls. These are called mixing zones. To ensure mixing zones do not impair the integrity of the waterbody, it should be determined that the mixing zone will not cause lethality to passing or ganisms and, considering likely pa thways of exposure, that there are not significant human health risks. Third, under EPA’s regulations (40 CFR 122.44(d)(1)(ii)), when determining whether a disc harge causes, has the reasonable potential to cause, or contributes to an in-s tream excursion above a narrative or numeric criteria within a state water quality standard, the permitting auth ority shall use procedur es which account for, where appropriate, the dilution of the effluent in the receiving water.December 29, 2008

3-21 Nevertheless, comparison of cruise ship wa stewater discharges to NRWQC provides a conservative screen of whether these discharges might cause, have the potential to cause, or contribute to non-attainment of the water quality standards in a given receiving water. If the concentration of a given analyte in cruise sh ip wastewater is less than the NRWQC, the wastewater should not cause, have the potential to cause, or c ontribute to non-attainment of a water quality standard based on that criterion. If the concentration of a particular analyte in cruise ship wastewater is greater than the NR WQC, additional analysis would determine whether the discharge would cause, have the potential to cause, or contribute to non-attainment of a water quality standard in a given receiving water. It should be noted that such an analysis may be more

difficult for mobile sources such as vessels, but in general, great er mixing and dilution would be expected for mobile sources.

Pathogen Indicators

Wastewater may contain many pathogens of concern to human health, including Salmonella, shigella , hepatitis A and E, and gastro-intestinal viruses (National Rese arch Council, 1993). Pathogen contamination in swimming areas and shellfish beds poses potential risks to human health and the environment by increasing the rate of waterborne illnesses (Pruss, 1998; Rees, 1993; National Research Council, 1993). Shellfish feed by filtering particles from the water,

concentrate bacteria and viruses from the wa ter column, and pose the risk of disease in consumers when eaten raw (National Research Council, 1993; Wu, 1999).

The NRWQC for pathogen indicators referenc es the bacteria standards in EPA’s 1986 Quality Criteria for Water , commonly known as the Gold Book. The Gold Book standard for bacteria is described in terms of three different waterbody use criteria: freshwater bathing, marine water bathing, and shellfish harvesting waters. The marine water bathing and shellfish harvesting waterbody use criteria shown in Table 3-9 were us ed for comparison with cruise ship graywater

concentrations.

Table 3-9. National Recommended Water Quality Criteria for Bacteria

Waterbody

Use Gold Book Standard for Bacteria

Marine

Water Bathing Based on a statistically sufficient number of samples (generally not less than five samples equally spaced over a 30-day peri od), the geometric mean of th e enterococci densities should not exceed 35 per 100 ml; no sample should exceed a one-sided confidence limit (C.L.) using the following as guidance: 1) Designated bathing beach 75% C.L. 2) Moderate use for bathing 82% C.L. 3) Light use for bathing 90% C.L. 4) Infrequent use for bathing 95% C.L. based on a site-specific log standard deviation, or if site data are insufficient to establish a log standard deviation, then using 0.7 as the log standard deviation.

Shellfish Harvesting

Waters The median fecal coliform bacter ial concentration should not exceed 14 MPN per 100 ml with not more than 10% of samples exceeding 43 MPN per 100 ml for the taking of shellfish.December 29, 2008

3-22 Pathogen indicator data from unt reated graywater consistently exceed the NRWQC for marine water bathing and shellfish harvesting waters (s ee Tables 3-3 and 3-10) . Over 66% of EPA samples for enterococci exceeded the 35 MPN/100 mL standard for marine water bathing. Over 80% of ACSI/ADEC samples for fecal colifor m exceeded the 43 MPN/100 mL standard for harvesting shellfish. Given the consistent ex ceedance of the NRWQC fo r bacteria, untreated graywater may cause, have the potential to cause, or contribut e to non-attainment of water quality standards; a site-specifi c evaluation would determine if these discharge concentrations would cause, have the potential to cause, or contribute to non- attainment of water quality standards in a given receiving water.

Table 3-10. EPA and ACSI Untreated Cruise Ship Graywater Pathogen Indicator Data

Analyte Average Concentration (and Range) in Untreated Cruise Ship Graywater (EPA Data) 1 Average Concentration in Untreated Cruise Ship Graywater (ACSI/ADEC Data) 2

Fecal coliform (fecal coliform/100 mL) 36,000,000* (ND [2.00] to 455,000,000) 2,950,000*

MPN/100 mL (ND [2.00] to 32,000,000) Enterococci (MPN/100 mL) 8,920* (ND [1.00] to 1,600,000) NC

1 Based on EPA sampling data from 2004.

2 Based on data collected by ACSI/ADEC in 2000 and 2001. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

“NC” indicates that this in formation was not collected.

Conventional Pollutants and other Common Analytes

Conventional pollutants and other common analytes that have a sa ltwater aquatic life or human health (for the consumption of organisms) na rrative NRWQC include oil and grease, settleable residue, total suspended solids (see Table 3-11), and temperature (s ee Tables 3-11 and 3-12). In addition, the NRWQC include a numer ic standard for total residual chlorine (see Table 3-13).

Table 3-11. Narrative National Recommended Water Quality Criteria for Conventional Pollutants and Other Common Analytes

Analyte Gold Book Standard

Oil and Grease For aquatic life : (1) 0.01 of the lowest continuous flow 96-hour LC50 to several important freshwater and marine species, each having a demonstrated high susceptibility to oils and petrochemicals. (2) Levels of oils or petrochemicals in the sediment which cause deleterious effects to the

biota should not be allowed. (3) Surface waters shall be virtually free from floating nonpetroleum o ils of vegetable or animal origin, as well as petroleum-derived oils.December 29, 2008

3-23 Settleable and Suspended Solids Freshwater fish and other aquatic life : Settleable and suspended solids should not reduce the depth of the compensation point for photosynthetic activity by more than 10% from the seasonally established norm for aquatic

life.

Temperature Marine Aquatic Life : In order to assure protection of the characteristic indigenous marine community of a waterbody segment from adverse thermal effects, the maximum acceptable increase in the weekly average temperature re sulting from artificial sources is 1°C (1.8 °F) during all seasons of the year, providing the summer ma xima are not exceeded; and daily temperature cycles characteristic of the waterbody segment sh ould not be altered in either amplitude or frequency. Summer thermal maxima, which define the upper thermal limits for the communities of the discharge area, should be established on a site-specific basis.

Oil and Grease

Annual worldwide estimates of petroleum input to the sea exceed 1.3 million metric tonnes (about 380 million gallons) (National Research Council, 2003). Levels of oil and grease of any kind can cause a variety of environmental impact s including the drowning of waterfowl because of loss of buoyancy, preventing fish respiration by coating their gills, asphyxiating benthic organisms from surface debris settling on the bottom, and reducing the natural aesthetics of waterbodies (EPA, 1986).

EPA does not have information on cruise ship graywa ter that would allow us to directly evaluate the narrative NRWQC for oil and grease. Hexane extractable ma terial (HEM) was detected in 100% of EPA’s untreated graywa ter samples (38 detects out of 38 samples) with detected amounts ranging between 5.6 and 5,010 mg/l. ACSI/ADE C also detected oil and grease in 100% of untreated graywater samples (4 detects out of 4 samples) with detected amounts ranging between 38 and 130 mg/l. However, EPA did not observe any floating oils in their untreated graywater samples; therefore, it is unlikely that there would be floating oils in the receiving water. (ACSI/ADEC did not provide a visual description of their samples to indicate if floating oils were observed.)

Settleable and Suspended Solids

Solids, either settleable or su spended, may harm marine organi sms by reducing water clarity and available oxygen levels in the wa ter column. In addition, solids can directly impact fish and other aquatic life by preventing the successful deve lopment of eggs and larva, blanketing benthic populations, and modifying the environment such that natural movements and migration patterns are altered (EPA, 1986).

EPA did not directly evaluate cr uise ship graywater against the narrative NRWQC for settleable and suspended solids because the criterion is ba sed on conditions in a specific waterbody. Total suspended solids were consistently detected by ACSI/ADEC in untreated graywater samples at levels ranging from 18 to 4,770 mg/l, with an av erage of 318 mg/l. Total suspended solids were consistently detected by EPA in untreated graywater samples at levels ranging from 24 to 29,400 mg/l, with an average of 704 mg/l. The detect ed values are substant ially higher than the discharge standards for sewage fr om land-based sewage treatment pl ants (7-day average shall notDecember 29, 2008

3-24 exceed 45 mg/l). A site-specific evaluation would determine if these discharge concentrations would cause, have the potential to cause, or contribute to non- attainment of water quality standards in a given receiving water.

Temperature

Temperature changes can directly affect aquatic organisms by altering their metabolism, ability to survive, and ability to reproduc e effectively. Increases in temperature are frequently linked to acceleration in the biodegradati on of organic material in a waterbody, which increases the demand for dissolved oxygen and can stress local aquatic communities.

EPA did not directly evaluate cruise ship graywater agai nst the narrative NRWQC for temperature because the criterion is based on co nditions in a specific waterbody, such as flushing and the factors that influence flushing. Th e average temperature from EPA’s untreated graywater samples was 39.6 °C (temperature data were not availa ble for ACSI/ADEC’s untreated graywater samples). Local waterbody te mperatures would be needed to determine if the average temperature from untreated graywater would cause, have the po tential to cause, or contribute to non-attainment of water quali ty standards in a given receiving water. Table 3-12 provides a few examples of the water temperatures observed in various coastal waters across the United States. The average temperature fo r untreated graywater effluent exceeds the temperatures presented in Table 3-12. A site-s pecific evaluation would determine if the cruise ship discharge volume is significant enough to alter the temperature of a given waterbody. However, considering the size of coastal waterbod ies where cruise ships operate, it is unlikely that cruise ship effluent temp eratures would cause an increase in waterbody temperature that would exceed the NRWQC.

Table 3-12. Seasonal Coastal Water Tempera tures in °C Across the United States

Location State Jan Feb March April May June July Aug Sept Oct Nov Dec

Boston Harbor MA 4.44 2.22 5.00 7.22 12.22 16.11 18.89 20.00 18.89 14.44 10.56 5.56

Baltimore MD 4.44 2.78 6.11 10.56 16.11 21.11 25.00 26.11 25.00 18.89 12.22 6.11

Miami Beach FL 21.67 22.78 23.89 25.56 26.67 28.89 30.00 30.00 28.89 28.33 24.44 22.78

Key West FL 20.56 21.11 23.89 26.11 27.78 30.00 30.56 30.56 30.00 28.33 24.44 22.22

Seattle WA 8.33 7.78 7.78 8.89 10.00 11.67 12.78 13.33 13.33 12.22 10.56 9.44

Los Angeles CA 14.44 14.44 15.56 15.56 16.11 16.67 18.33 20.00 19.44 18.89 17.78 15.56

Galveston TX 12.22 12.78 16.11 21.67 25.56 28.33 30.00 30.00 28.33 23.89 19.44 15.00

Juneau AK 2.22 2.22 2.78 4.44 7.78 10.56 11.11 10.56 9.44 6.67 4.44 3.33

Honolulu HI 24.44 24.44 24.44 24.44 25.56 26.11 26.67 26.67 27.22 27.22 26.11 25.00

Source: National Oceanographic Data Center Coast Wate r Temperature Guide (www.nodc .noaa.gov/dsdt/wtg12.html)

Total Residual Chlorine

Chlorine is extremely toxic to aquatic organi sms. Chlorine concentrations as low as 3 μ g/l can result in a high mortality rate for some species (EPA, 1984). In fish, exposure to low levels of

total residual chlorine (<1,000 μ g/l) can cause avoidance behavi or, respiratory problems, andDecember 29, 2008

3-25 hemorrhaging (Vetrano, 1998). Fish may recover on ce removed from the chlorine environment, but the severity of the reaction and chance of death increases as the concentration of total residual chlorine increases (Booth et al., 1981). Studies have s hown that continuous chlorination

can lead to a shift in the co mposition of phytoplankton communiti es, thus altering the benthic and fish communities that feed on them (Sanders and Ryther, 1980).

Total residual chlorine concentra tions were not available for EPA’ s untreated graywater samples. The average concentration of total residual ch lorine from ACSI/ADEC’s untreated graywater sampling data exceeded the NRWQC for total resi dual chlorine (see Table 3-13). A site-specific

evaluation would determine if thes e discharge concentrations would cause, have the potential to cause, or contribute to n on-attainment of water quality standard s in a given receiving water. The most likely source for total residual chlorine in untreated graywater is from the chlorination of the drinking water on the cruise ship.

Table 3-13. Comparison of Untreated Crui se Ship Graywater to Numeric National Recommended Water Quality Criteri a for Total Residual Chlorine

Analyte Average

Concentration

in Untreated Cruise

Ship Graywater (ACSI/ADEC Data) 1 NRWQC

Criteria

Maximum

Concentration (CMC) 2 NRWQC

Criterion

Continuous

Concentration (CCC) 2

Total Residual Chlorine ( μ g/l) 372*^ 13 7.5

1 Based on data collected by ACSI/ADEC in 2000 and 2001.

2 The National Recommended Water Quality Criteria for chlorine in marine waters are expressed as chlorineproduced oxidants as measure by total residual chlorine. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

^ The minimum detection limit for total residual chlori ne reported by most analytical labs is 100 μ g/l.

Metals

In the aquatic environment, elevated concentratio ns of metals can be toxic to many species of algae, crustaceans, and fish. Exposure to metals at toxic levels can cause a variety of changes in biochemical, physiological, morphologi cal, and behavioral patterns in aquatic organisms. One of the key factors in evaluating meta l toxicity is the bioavailabilit y of the metal in a waterbody. Some metals have a strong tendenc y to adsorb to suspended organi c matter and clay minerals, or to precipitate out of solution, t hus removing the metal from the wa ter column. The tendency of a given metal to adsorb to suspended particles is typically controlled by the pH and salinity of the waterbody. If the metal is highly so rbed to particulate matter, then it is likely not in a form that organisms can process. Therefore, a high concen tration of a metal measured in the total form may not be an accurate representation of the toxi c potential to aquatic organisms. Accordingly, NRWQC for the protection of aqua tic life for metals are typically expressed in the dissolved form. In contrast, human health criteria (for the consumption of organisms) for metals are commonly expressed in the total metal form. The us e of total metals for human health criteria is because human exposure to pollutants is assumed to be through the consumption of organisms,December 29, 2008

3-26 where the digestive process is assumed to transf orm all forms of metals to the dissolved phase, thus increasing the amount of bi ologically available metals.

EPA detected in the untreated graywater samp les several dissolved metals that are common components of ship piping

-- copper, nickel, and zinc

-- at levels approxim ately 2 to 63 times above NRWQC for aquatic life (s ee Table 3-14). Both EPA and ACSI/ADEC detected total arsenic in 10% or more of samples with av erage concentrations exceeding the NRWQC for human health (for the consumption of organism s) (see Table 3-14). EPA also detected total thallium in untreated graywater at levels ex ceeding the NRWQC for human health (for the consumption of organisms). A site-specific evaluation would determine if these untreated graywater concentrations would cause, have th e potential to cause, orcontribute to nonattainment of water quality standards in a give n receiving water. Howe ver, as discussed in section 3.4.3 on Mixing and Dilution below, th ese analytes would lik ely meet NRWQC after initial mixing (about 1 to 7 meters from the ship) even when a vessel is at rest.

Table 3-14. Comparison of Untreated Cruise Ship Graywater to National Recommended Water Quality Criteria for Metals

Analytes that

Exceed One or More NRWQC 1 Average

Concentration

in Untreated Cruise Ship Graywater (EPA Data) 2 Average

Concentration

in Untreated Cruise Ship Graywater (ACSI/ADEC Data) 3 NRWQC

Criteria

Maximum

Concentration (CMC) NRWQC

Criterion

Continuous

Concentration (CCC) NRWQC

Human Health (for the Consumption of Organisms)

Arsenic (Total) ( μ g/l) 2.25* 1.22 0.14

Copper (Dissolved) ( μ g/l) 195 NC 4.8 3.1

Nickel (Dissolved) ( μ g/l) 18.2 NC 74 8.2

Thallium (Total) ( μ g/l) 0.930* ND 0.47

Zinc (Dissolved) ( μ g/l) 1,610 NC 90 81

1 Analytes are not listed in this table if the number of de tects was not considered representative of untreated cruise

ship graywater (i.e., less than 10% of samples), if the data were not in the correct form for comparison with NRWQC, or if the average concentra tion was driven by detection limits.

2 Based on EPA sampling data from 2004.

3 Based on data collected by ACSI/ADEC in 2000 and 2001. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

“NC” indicates that this in formation was not collected. “ND” indicates that the analyte was not detected.

Semivolatile and Volatile Organics

Table 3-15 presents the organic compounds dete cted in untreated graywater that exceed NRWQC. Note that EPA and AC SI/ADEC did not test graywater for all organic compounds that have a NRWQC. The magnitude of the ex ceedances of NRWQC for the semivolatile and volatile organic compounds discussed in this subsection ranged from 3.2 to 33 times the standard. A site-specific eval uation would determine if these discharge concentrations wouldDecember 29, 2008

3-27 cause, have the potential to cause, or contribute to non-attainment of water quality standards in a given receiving water. However, as discussed in section 3.4.3 belo w, these analytes would likely meet NRWQC after initial mixing (about 1 to 7 mete rs from the ship) even when a vessel is at

rest.

Table 3-15. Comparison of Untreated Cruise Ship Graywater to National Recommended Water Quality Criteria for Semivola tile and Volatile Organics

Analytes that Exceed One or More NRWQC 1,2 Average Concentration in Untreated Cruise Ship Graywater (EPA Data) 3 Average Concentration

in Untreated Cruise

Ship Graywater (ACSI/ADEC Data) 4 NRWQC

Human Health (for the Consumption of

Organisms)

Bis(2-ethylhexyl) phthalate ( μ g/l) 71.9* 22.4* 2.2

Tetrachloroethylene ( μ g/l) 11.4* 10.7* 3.3

1 Analytes are not listed in this table if the number of de tects was not considered representative of untreated cruise

ship graywater (i.e., less than 10% of samples), if the data were not in the correct form for comparison with NRWQC, or if the average concentra tion was driven by detection limits.

2 Untreated graywater data were not available for all anal ytes that have a NRWQC. Therefore this table may not

include all analytes that exceed NRWQC.

3 Based on EPA sampling data from 2004.

4 Based on data collected by ACSI in 2000 and 2001. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Bis(2-ethylhexyl) phthalate is a manufactured chem ical that is commonly added to plastics to

make them flexible and can be found in a vari ety of common products such as wall coverings, tablecloths, floor tiles, furniture upholstery, and shower curtains. Tetrachloroethylene is widely used in dry cleaning and fo r metal-degreasing.

Nutrients

Untreated graywater contains nutrients, such as nitrogen and phosphorus , which are important elements for aquatic plant and algae growth. The influx of excess nutrients can negatively effect marine ecosystems, resulting in diebacks of co rals and seagrasses, eutrophication (oxygendepleted “dead” zones), and increases in harm ful algal blooms that can alter the seasonal progression of an ecosystem and choke or poison other plants and wildlife (National Research Council, 1993).

Ammonia is the only nutrient for which there is a numeric saltwater or human health (for the consumption of organisms) NRWQC. In the aquatic environment, ammonia exists in the unionized (NH 3 ) and ionized (NH 4 + ) forms. Unionized ammonia is the more toxic form of the two, with several factors such as pH, temperature, and salinity determining the toxicity to aquatic organisms. Acute levels of NH 3 that are toxic to fish can cause a loss of equilibrium, hyperexcitability, and increased breathing, cardiac output, and oxygen uptake (WHO, 1986). Extreme concentrations can cause convulsions, coma, and even death.December 29, 2008

3-28 The marine NRWQC references EPA’s 1989 Ambient Water Quality Criteria for Ammonia (Saltwater) document, which includes a matrix tabl e for ammonia standards based on the pH, temperature, and salinity of a waterbody. Tabl e 3-16 presents the aver age concentration of ammonia in untreated graywater. Table 3- 17 presents examples of the ammonia NRWQC calculated from pH, temperature, and salinity at some cruise ship ports of call in the United

States.

Table 3-16. Ammonia Concentration in Untreated Graywater

Analyte Average Concentration in EPA Graywater Sampling 1 Average Concentration in ACSI Graywater Sampling 2
Ammonia (NH 3 -N μ g/l) 2,130* 2,210*

1 Based on EPA sampling data from 2004.

2 Based on data collected by ACSI in 2000 and 2001. * Average includes at least one nondetect value; this calculation uses detection limits for nondetected results.

Table 3-17. Calculated Ammonia NRWQC for Some Cruise Ship Ports of Call in the

United States

Location State pH Average Temperature (°C) Salinity (psu) NRWQC

Criteria Maximum Concentration (CMC) (NH 3 -N μ g/l) 4 NRWQC

Criterion Continuous Concentration (CCC) (NH 3 -N μ g/l) 4

Galveston Bay 1 TX 8.1 29.0 14.0 2,140 321

Honolulu Harbor 1 HI 8.0 25.5 34.4 4,110 617

Los Angeles Harbor 1 CA 8.1 17.4 32.6 7,110 1,110

Port of Miami 2 FL 8.0 25.3 32.0 4,110 617

Monterey Harbor 1 CA 8.1 15.3 32.9 6,860 1,070

New York Harbor 1 NY 7.5 22.1 22.9 11,500 2,960

Southeast Alaska 3 AK 7.8 12.5 20.0 15,600 2,340

Portland Harbor 1 ME 7.8 19.4 29.6 9,040 1,400

1 Data source: EPA’s EMAP National Coastal Data base (http://oaspub.epa.gov/coastal/coast.search)

2 Data source: South Florida Water Management District Monitoring Stations

(http://glades.sfwmd.gov/pls /dbhydro_pro_plsq l/water_quality_interface.main_page)

3 Data source: Draft State of Alaska Department of Environmental Conservation Large Commercial Passenger

Vessel Wastewater Discharge Ge neral Permit No. 2007DB0002 (www.dec.state.ak.us/water/cruise_ships/pdfs/ PN%20Version%20LPV%20WWGP%20-%20DRAFT.pdf)

4 Ammonia standards were calculated based on pH, temperat ure, and salinity values for each waterbody using the matrix table provided in EPA’s 1989 Ambient Water Quality Criteria for Ammonia (Saltwater) document. In cases

where measured values fell between column and row headings for pH and temp erature the standard was approximated based on the closest value. In addition, the ammonia standards were converted from μ g-NH 3 /l to μ gNH 3 -N/l by multiplying the standard by 0.822.December 29, 2008

3-29 Average concentrations of amm onia in untreated graywater exceed most of the NRWQC Criteria Continuous Concentration and one of the NRWQ C Criteria Maximum Concentration presented in Table 3-17. Although ammonia standards ca n vary from waterbody to waterbody, there is only a small range of pH, temperature, and salin ity values that result in a chronic ammonia standard that untreated graywater concentrations will not exceed. This suggests that ammonia concentrations in untreated gray water at the end-of-pipe are li kely to exceed chronic NRWQC regardless of the receiving water. A site-speci fic evaluation would determine if these discharge concentrations would cause, have the potential to cause, or contri bute to non-attainment of water quality standards in a given receiving water. However, as discussed in section 3.4.3 below, ammonia in untreated graywater would likely m eet NRWQC after initial mixing (about 1 to 7 meters from the ship) even when a vessel is at rest. For additional discussion of the potential impacts of nutrients in cruise ship discharges, see Section 2.

3.4.3 Mixing and Dilution

Although average analyte concentrations in crui se ship untreated graywater exceed some NRWQC at the end-of-pipe, the mixing and dilu tion that occurs followi ng discharge also is relevant to an evaluation of pot ential environmental impact.

Dilution at Rest

A Science Advisory Panel created by the ACSI used the Cornell Mixing Zone Expert System

model to estimate dilution of effluent achieved when a vessel is at rest . Their modeling showed that a discharge rate of 50 m 3 /hr yields a dilution factor of 36 at a distance of about 4.5 m from the ship, and a dilution factor of 50 at 7 m from the ship after 43 seconds (ADEC, 2002, Appendix 8, footnote 50).

The ADEC modeled the dilution of large cruise ship e ffluent during stationary discharge under a very conservative scenario (a neap tide in Skag way Harbor), using the Visual Plumes model. Their modeling showed the dilution factors rang ing from 5 to 60, which would occur between 1 and 7 meters from the ship (ADEC, 2004). This dilution factor may not necessarily apply to situations where the discharge port faces a dock, pilings, or other another obstruction.

The initial dilution estimated by ACSI and ADEC fo r a vessel at rest woul d not likely be great enough for untreated graywater to meet all NRWQC, in particular fecal coliform and enterococci (see Tables 3-9 and 3-10). However, most of the other analytes that exceed NRWQC at the endof-pipe would likely meet NRWQC after initial mi xing when the vessel is at rest, based on the

initial dilution factors discussed above. For example, metal exceedances at the end-of-pipe ranged from 2 to 63 times the lowest NRWQC (s ee Table 3-14), and ammonia was 7 times the lowest estimated NRWQC (see Tables 3-16 and 3-17).

It is important to note that th e initial mixing estimates discus sed above are based on ship and waterbody-specific input parameters such as discharge port size, effluent flow, waterbody temperature, and salinity. Therefore, they ar e not necessarily represen tative of the dilution factors that would be achieved by cruise ships in other ports of call in the United States. Site-December 29, 2008

3-30 specific and ship-specific calcula tions would be required to determine the dilution for ships in

other locations.

Dilution Underway

For vessels underway, there is si gnificant additional dilution due to movement of the vessel and mixing by ship propellers. In 2001, EPA conducte d dye dispersion studies behind four large cruise ships while underway off the coast of Miami, Florida. The results of this study indicate that dilution of discharges behind cruise sh ips moving between 9.1 and 17.4 knots are diluted by a factor of between 200,000:1 and 640,000:1 immediately behind the boat (EPA, 2002). Based on these dilution factors, graywater would lik ely meet all NRWQC except for fecal coliform while underway.

3.4.4 Potential Treatment Techno logies in Addition to AWTs

As part of its assessment of the cruise ship se wage and graywater discharge standards in Alaska, EPA evaluated upgrades to AWTs and technologies that could be added on to AWTs that would improve the quality of the treated effluent in te rms of nutrients, metals, and temperature. See Section 2 (subsection 2.4.4) for a discussion of these potential tr eatment technologies.

3.5 What action is the federal government taki ng to address graywater waste streams from cruise ships?

EPA is evaluating the performance of advan ced sewage and graywater treatment systems. EPA is evaluating the performance of various a dvanced sewage and graywater treatment systems as part of its effort to assess whether revised or additional standards for sewage and graywater discharges from large cruise ships operating in Alaska are warranted under Title XIV (see subsection 2.2.3). Some of the results of this in tensive effort, including sampling four different AWTs and a survey questionnaire for all cr uise ships operating in Alaska in 2004, are summarized in this Assessment Report. EPA anticipates making these full analyses publicly available in 2009. As part of this effort , EPA in conjunction with the ADEC conducted a scientific survey in July 2008 using EPA’s Ocean Survey Vessel Bold to (1) measure the dilution of AWT discharges from stationa ry cruise ships, and (2) eval uate the potential environmental impact of nutrients in AWT di scharges. EPA anticipates maki ng the results of these studies publicly available in 2009.

EPA is developing a water permit program for po llutant discharges inci dental to the normal operation of vessels. Under a U.S. District Court decision, the exis ting EPA regulations that exclude discharges incidental to the normal operation of a vessel from CWA permitting were vacated (revoked) as of December 19, 2008. The District Court’s de cision to vacate that exclusion was recently upheld by the Ninth Circu it Court of Appeals. NW. Envt’l Advocates et al. v. EPA , 537 F.3d 1006 (9th Cir. 2008). Thus, as explained in section 1.1, as of December 19, 2008, discharges incidental to the normal operation of vessels into waters of the U.S. from cruise ships 79 feet or more in length are subject to National Pollu tant Discharge Elimination System permitting.December 29, 2008

3-31 Coast Guard has developed regulations implementing the monitoring requirements of Title XIV. Under Title XIV, the Coast Guard has implemente d an inspection regime that includes sampling of cruise ship sewage and graywater discharg es in Alaskan waters. In July 2001, Coast Guard published a final rule (33 CFR 159. 301-321) that outlines its oversig ht of cruise ships sampling

in Alaskan waters.

Coast Guard is conducting a review of inspection and enforcement policies.

The Coast Guard has started a review of th eir inspection and enforcement policies and regulations for cruise ship environmental practic es. This review includes a survey of inspectors from Coast Guard regions, focusing on MSDs, oil/water separators, and the effectiveness and feasibility of various inspection practices.

California National Marine Sanctuaries propose to prohibit cruise ship graywater discharges

. Under the National Marine Sanctuaries Act (16 U. S.C. § 1431 et seq.), the Monterey Bay, Gulf of the Farallones, and Cordell Bank National Mari ne Sanctuaries have proposed regulations to prohibit the discharge of treated and untreated graywater from large vessels, including cruise ships (71 FR 59050, Oct. 6, 2006; 71 FR 59338, Oct. 6, 2006; 71 FR 59039, Oct. 6, 2006). NOAA is currently reviewing the comments on th ese proposed rules. The Channel Islands National Marine Sanctuary has published a pr oposed rule (73 CFR 16580, March 28, 2008) to revise a proposed action concerning vessel discharges (71 FR 29096, Oct. 5, 2006). The proposed rule containing the revision includes a prohibition on treated and untreated graywater from cruise ships. NOAA is currently revi ewing the comments on this proposed rule.

National Park Service manages cruise ship waste streams in Glaci er Bay National Park. The National Park Service (NPS) manages cruise ship waste streams indirectly in Glacier Bay National Park through competitively awarded con cession contracts. The NPS has jurisdiction over the submerged lands and marine waters of Gl acier Bay National Park up to 3 miles from the mean high tide line and including all of Glacier Ba y proper. Glacier Bay is a well known, very popular attraction for the cruise ship industry in Alaska. Rece nt environmental reviews and decisions allow up to two cruise ship entries pe r day into Glacier Bay pr oper during the primary visitor season. Cruise ship operations in the park are authorized under concession contracts, which are awarded under a compet itive solicitation and prospectus process. Impact on park resources is a general standard selection criterion for park co ncessions. The NPS uses waste stream management as one of a number of selecti on criteria in this regard . In the past, cruise ship operators have usually proposed to minimi ze the impact of waste streams by committing to a no-discharge policy while in the park (even if legal under applicable law) for sewage, graywater, ballast water, bilge water, cooling water, hazardous waste, and solid waste. If awarded a contract, companies must comply with their proposal. Typically cruise ships operate in the park for 8-10 hours and then depart. They do not dock or transferany wastes to shore while in the park.December 29, 2008

3-32 3.6 Possible Options and Alternatives to Address Graywater from Cruise Ships

Based on the public comments receiv ed on the draft of this report as well as other information gathered, listed below are a wide range of options and alternatives that address graywater from cruise ships. Identification of any particular option does not imply any EPA recommendation or preference for future action, or that EPA has dete rmined that any of these options are necessary or feasible, or that EPA believes a change to the status quo is warranted, or that EPA or any other entity has the legal authority to implement that option.

Prevention & Reduction

 Establish standards or best management practices for design, operation, maintenance and/or training that will decr ease or eliminate the contaminants and/or volume of untreated graywater and/or treated graywater effluent.

Control: Discharge Standards

 Establish and/or revise standards for the discharge of graywater, for example,

o to require attainment of national federal water quality criteria at point of discharge.

o to require attainment of national federal water quality criteria at the edge of a mixing zone.

o to require attainment of applicable state water quality standards.

o to require attainment of secondary treatment standards for publicly owned

treatment works.

o to require the reduc tion attainable through applica tion of the best available technology economically achievable.

o to require technology that w ould eliminate remaining pollutants of concern (i.e., reduce to level below concern).

o to require use of A dvanced Wastewater Treatment systems.

o to apply Title XIV standards (which appl y in certain Alaskan waters) nationwide.

o to address additional parameters, e.g., additional pathogen indicators.

o to account for potential bioaccumulation.

o to require period sampling and testing.

o to require more stringent standards in areas frequented by multiple cruise ships.

o to define which waste streams/pollutants may be sent to the graywater system.

Control: Geographic Restrictions on Discharge

 Restrict discharge of untreated or all graywater, for example,

o no discharge out to a certain distance (e.g., 3 miles from shore, 12 miles from shore, 12 nautical miles from the 20-meter contour line).

o no discharge in or within a certain dist ance (e.g., 0.5 nautical miles, 4 nautical miles) of sensitive areas (e.g., shellfish, por ts, co ral reefs, bathing beaches, water

bodies with restricted circ ulation, flushing or inflow, marine protected areas, breeding grounds, near la rge population centers).

o no discharge in any U.S. waters.

o require shore-side discharge.

o withhold discharge when a system upset occurs.December 29, 2008

3-33 Enforcement & Compliance Assurance: Monitoring

 Require sampling and testing of untreated and/or treated graywater to ensure that it meets applicable standards

o by government agencies with enforcement authority.

o by third-parties.

o by cruise lines.

 Require onboard observers to monitor all sa mpling, monitoring, and other effluent-related requirements/to oversee discharging practices , equipment operation and maintenance, and the completion and submittal of accurate logbooks.

 Require rapid testing methods for pathogen indicators.

Enforcement & Compliance Assurance: Reporting

 Require certain report ing by cruise ship operators, for example,

o immediate notification to appropriate agenci es in the event of an treatment system malfunction or upset.

o disclosure of implementation or non-imp lementation of pollution reduction and prevention practices, including but not lim ited to treatment systems, in all

advertisements in the U.S.

o advance notification from ships planning to discharge in U.S. waters.

o notification to appropriate ag encies of all discharges of untreated graywater or treated graywater effluent in U.S. waters.

o notification of discharges in state wa ters to appropriate state agencies.

 Require electronic transponders to signal land -based authorities when a discharge line is opened or closed.

Enforcement & Compliance Assurance: Inspections & Enforcement

 Penalties for failure to meet treate d or untreated graywater standards.

 Increase inspections and inspection requirements.

 Establish a funding mechanism based on the polluter-pays model that will provide revenues to develop and implement a comprehensive regulatory scheme.

 Impose uniform requirements on all ships as a condition of port entry and within waters under the jurisdiction of the U.S. consistent with international law, regardless of flag

state.

 Prohibit or otherwise restrict noncompliant vessels (and sister ships, depending on the degree of involvement by parent companies) from operating in sens itive areas of the marine environment under U.S. jurisdiction.December 29, 2008

3-34 References

Alaska Department of Environmental Conservation (ADEC). 2000. Alaska Cruise Ship Initiative Part 1 Final Report . Juneau, AK. (www.dec.state.ak.us/water/cruis e_ships/pdfs/finreportp10808.pdf)

Alaska Department of Environmental Conservation (ADEC). 2001. Alaska Cruise Ship Initiative Part 2 Report . Juneau, AK. ( www.dec.state.ak.us/water/cruis e_ships/pdfs/acsireport2.pdf)

Alaska Departm ent of Environmental Conservation (ADEC). 2002. The Impact of Cruise Ship Wastewater Discharge on Alaska Waters . Juneau, AK. ( www.dec.state.ak.us/water/cruise_sh ips/pdfs/im pactofcruiseship.pdf)

Alaska Department of Environmental Conservation (ADEC). 2004. Assessment of Cruise Ship and Ferry Wastewater Impacts in Alaska . Juneau, AK. ( www.dec.state.ak.us/water/cruise_ships/assessreport04.htm )

Booth, P.M., Jr., Sellers, C.M., Jr., & Garrison, N.E. 1981. Effects of Intermittent Chlorination on Plasma Proteins of Rainbow Trout ( Salmo gairdneri ). Bull. of Env. Contam. & Tox 26(2): 163-170.

Cruise Lines Internationa l Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry Waste Management Practices and Procedures . Fort Lauderdale, FL. (www.cruising.org/industry/PDF/CLIAWa steManagem entAttachment.pdf and www.cruising.org/industry/PDF/CLIAWasteManagement.pdf)

Metcalf & Eddy. 1991. Wastewater Engineering: Treatment and Reuse , Third Edition. New York, NY: McGraw Hill.

Mayer, Peter W . and William B. DeOreo. 1998. Residential End Uses of Water. Aquacraft, Inc. Water Engineering and Management. Am erican Water Works Association. ( www.aquacraft.com/Publications/resident.htm)

National Re search Council (NRC): Committee on Wastewater Management for Coastal Urban Areas, Water Science and Technology Boar d, Commission on Engineering and Technical Systems. 1993. Managing Wastewater in Coastal Urban Areas . Washington, DC: National Academy Press. ( http://www.nap.edu/catal og.php?record_id=2049#toc)

National Re search Council (NRC): Committee on Oil in the Sea: Inputs, Fates, and Effects.

2003. Oil in the Sea III: Inputs, Fates, and Effects . Washington, DC: National Academy Press. ( http://www.nap.edu/catalog.php?record_id=10388#toc)

Pruss, Annette. 1998. Review of epidem iological studies on health effects from exposure to

recreational water

. International Journal of Epidemiology 27: 1-9.December 29, 2008

3-35 Rees, G. 1993. Health Implications of Sewage in Coastal Waters - the British Case. Marine

Pollution Bulletin 26(1): 14-19.

Sanders, J.G., & Ryther J.H. 1980. Impact of Chlorine on the Species Composition of Marine Phytoplankton . In: R.L. Jolley, et al. (Eds.), Water Chlorination: En vironmental Impact and Health Effects , 3: 631. Ann Arbor, MI: Ann Arbor Science Publishers.

U.S. Environmental Protection Agency. 1984. Ambient Water Quality Criteria for Chlorine (EPA 440/5-84-030). Washington, DC. ( http://www.epa.gov/ost/pc/ambientwqc/chlorine1984.pdf)

U.S. Environm ental Protection Agency. 1986. Quality Criteria for Water (EPA 440/5-86-001)

. Washington, DC. ( http://www.epa.gov/waters cience/criteria/goldbook.pdf)

U.S. Environm ental Protection Agency. 1989. Ambient Water Quality Criteria for Ammonia (Saltwater) (EPA 440/5-88-004)

. Washington, DC. ( http://www.epa.gov/waterscience/p c/am bientwqc/ammoniasalt1989.pdf)

U.S. Environmental Protection Agency. 1991.Tec hnical Support Documentfor Water Qualitybased Toxics Control (EPA 505-290-001). Washington, DC. ( http://www.epa.gov/npdes/pubs/owm0264.pdf)

U.S. Environm ental Protection Agency. 2002. Cruise Ship Plume Tracking Survey Report (EPA842-R-02-001). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise_s h ips/plumerpt2002/plumereport.pdf)

U.S. Environmental Protection Agency. 2004. Survey Questionnaire to Determine the Effectiveness, Costs, and Im pacts of Sewage and Graywater Treatment Devices for Large Cruise Ships Operating in Alaska (EPA Form No. 7500-64). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise_ships/cruise_ship_survey.pdf)

U.S. Environm ental Protection Agency. 2006a. Sampling Episode Report for Holland America

Veendam (Sampling Episode 6503). Washington, DC. ( http://www.epa.gov/owow/oceans/crui se_sh ips/Veendam/VeendamSER.pdf)

U.S. Environmental Protection Agency. 2006b. Sampling Episode Report for Norwegian Star (Sampling Episode 6504). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise_s h ips/FinalStar/FinalStarSERNCBI.pdf)

U.S. Environmental Protection Agency. 2006c. Sampling Episode Report for Princess Cruise

Lines – Island Princess (Sampling Episode 6505). Washington, DC. ( http://www.epa.gov/owow/oceans/crui se_sh ips/Island/IslandSER.pdf)

U.S. Environmental Protection Agency. 2006d. Sampling Episode Report for Holland America

Oosterdam (Sampling Episode 6506). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise_s h ips/Oosterdam/OosterdamFinal.pdf)December 29, 2008

3-36 U.S. Environmental Protection Agency. 2006e. Sampling Episode Report for Nitrogen Compounds Characterization (Sampling Episodes 6517 Through 6520). Washington, DC. ( http://www.epa.gov/owow/oceans/cruise _ships/nitrogen/nitrogen_NCBI.pdf)

Vetrano, K.M. 1998. Molecular Chlorine: Health and Environmental Effects. TRC

Environm ental Corporation. Windsor, CT.

World Health Organization (WHO) . 1986. Ammonia Environmental He alth Criteria 54. Geneva, Switzerland. ( http://www.inchem.org/documents/ehc/ehc/ehc54.htm)

Wu, R.S.S. 1999. Eutrophication, Water Born e Pathogens and Xenobiotic Com pounds: Environmental Risks and Challenges. Marine Pollution Bulletin 39: 11-22.December 29, 2008



### Section 4: Oily Bilge Water

Oily bilge water is the mixture of water, oily fluids, lubricants, cleaning fluids, and other sim ilar wastes that accumulate in the lowest part of a ve ssel from a variety of different sources including engines (and other parts of the propulsion system ), piping, and other mechanical and operational sources found throughout the machiner y spaces of a vessel. On most cruise ships, oily bilge water can be managed in one of two ways: (1) retained onboard in a holding tank and discharged later to a reception facility on shore, or (2) treated onboard with an Oily Water Separator (OWS) after which the treated bilge water can be discha rged overboard in accordance with applicable standards and regulations.

This section discusses the curren t state of information about bilge water, the laws regulating bilge water discharges from vessels, the types of equipment used to treat bilge water generated on cruise ships, the potential e nvironmental impacts of cruise ship bilge water, and federal actions taken to address bilge water from cruise sh ips. The conclusion of this section lists a wide range of options and alternatives that could be co nsidered when addressing oily bilge water from cruise ships.

4.1 What is bilge water and how much is generated on cruise ships?

Bilge water is the mixture of water, oily flui ds, lubricants, cleaning fl uids, and other similar wastes that accumulate in the lowest part of a ve ssel from a variety of different sources including the main and auxiliary engines; boilers, evapor ators and related auxiliary systems; equipment and related components; and other mechanical and operational source s found throughout the machinery spaces of a vessel. It is not uncommon on ships for oil or water to leak into the bilge from these sources, various seals, gaskets, fittings, piping, connections, and from related

maintenance and activities associated with th ese systems. These le aks, along with onboard spills, wash waters generated during the daily operation of a vessel, and waste water from operational sources (e.g., condensate from air co olers, etc.), collect in the bilge.

Machinery spaces onboard cruise ships are comple x power plants used to develop propulsion energy, electrical energy, and fresh water, as well as manage sewage and other wastes generated throughout the vessel. The machinery spaces onboa rd are very large and are not too different from shore side power plants. Cruise ship mach inery spaces consist of tanks, pumps, fittings, flanges, valves, control valves, and literally thousands of miles of piping and tubing, all used to manage the various fluids within the different systems. Although this menagerie of systems is designed to be leak free, many l eaks develop due to lack of ma intenance and repair of failed seals, gaskets, pump shaft seals, machinery casi ng gaskets and other components. The sizes of these leaks may vary tremendously and the si ze may be measured in ounces per minute or gallons per minute, depending on the severity of the leak. Further, the type of fluid leaked may vary, resulting in a complex mixture of fluids in the vessel’s bilge. This mixture can be difficult to separate and the oil content may be difficult to monitor with some of the best equipment. Bilge water is the most common source of oil po llution from cruise ships (National Association of Attorneys General, 2000).

4-1December 29, 2008

In addition to containing oil and grease, bilge wa ter may contain solid wastes such as rags, metal shavings, paint, glass, and a variety of chem ical substances (U.S. Environmental Protection Agency, 1997). Bilge water may contain variou s oxygen-demanding substances, volatile organic compounds, semi-volatile organics, inorganic salts, and metals. Bilge water also may contain other contaminants such as soaps, detergents, dispersants, and degreasers used to clean the engine room. These cleaning agents create an emulsion and prevent separation of oil and water. Moreover, they are often incompatible with Oily Water Separators and Oil Content Monitors.

Due to the various sources that contribute to the production of bilge water, the composition of bilge water varies from vessel to vessel, and from day to day. Other waste streams discussed in this Assessment Report, such as sewage and gray water (see Sections 2 a nd 3, respectively), are typically contained within their own systems and might only be pres ent in bilge water as a result

of leaks.

The amount of bilge water that accumulates onb oard can vary, and depends on a number of factors including the size of th e ship, engine room design, preven tative maintenance, and the age of the components. Accumulation of bilge wa ter is ongoing and needs to be properly managed, because if too much accumulates, it can cause damage to the propulsion systems and ancillary machinery on the vessel, as well as present a fire hazard and impact the vessel’s stability. Periodically, it is necessary to pump out the bilge spaces into a holding tank, which allows the vessel to maintain stability and eliminates potentially hazardous conditions from the accumulation of bilge water on the tank tops within the machinery spaces.

Large vessels such as cruise ships have several additional waste streams that contain sludge, waste oil, and oily water mixtur es, including fuel oil sludge, lubr icating waste oil, and cylinder oil, that can inadvertently find their way to the bilge. Sludge is produced by the constant purification of fuel, for the removal of contam inants improves low quality fuels and prevents damage to the ship’s engines and highly machin ed components. As the fuel is purified by centrifuges virtually continuously, the contaminants removed by the oil purifiers eventually drain into a sludge tank. Lubricating oil needed for the ship's engines are processed in the same fashion – removing various solids, water, and bypr oducts of combustion that contaminate the oil. Cylinder oil comes from the oil injected along the cylinder walls in the engine and contains contaminants from the combustion process. All of these waste oils are typically drained to individual drain tanks and ultimately to a co mmon sludge tank. The production of sludge derived from the fuel oil, unlike sludge derived from bilge water, remains fairly constant and is usually at least 1-2% of the heavy fuel oi l consumed onboard. Among the impurities separated out by the purifiers are water and oily water.

Most often sludge and bilge water systems are separate. However, management practices on some ships may lead to cross contamination of the bilge water from the sludge tank. For example, if the same pumps and manifolds are us ed for transferring both sludge and bilge water, there may be residual sludge and oil in the pipes from sludge when that system is then used for the bilge system. Also, if the oily water from the sludge tank is removed and decanted to the bilge water holding tank, it may also bring with it greater concentratio ns of oil and sludge particles.

4-2December 29, 2008

The Alaska Department of Environmental C onservation (2000) reporte d that cruise ships operating in Southeast Alaska produced 1,300 to 5,300 gallons of bilge water every 24 hours. Table 4-1 shows the bilge water production and treatment capacities based on ship tonnage.

Table 4-1. Maximum Daily Volume of Bilge Water Production

Ship Tonnage (Gross Tons) Passenger and Crew Capacity Bilge Water Production (max. gallons/day) Bilge Water Treatment Capacity (max. gallons/day)
22,000 1,100 1,000 5,000
46,000-48,000 1,500-2,160 3,000 4,000
50,700-55,400 1,850-2,380 5,000 5,000
76,000-78,000 2,700-3,200 2,640 6,400

Source: ADEC, 2000

It should be noted that although there could be a proportional rela tionship between ship tonnage and bilge water produced, many vari ables exist that can easily cause a smaller vessel to produce more bilge wastes than a larger vessel. Fo r example, a vessel with just six small 1/8 inch size

leaks and four 1⁄4 inch leaks without substant ial pressure behind them can produce over 1.43 millions gallons per year or the equivalent of 15 metric tons per day. Bilge ingress values or total accumulations can vary widely across a fleet of sister vessels simply due to one or a few

mechanical concerns.

4.2 What federal laws apply to bilge water from cruise ships?

4.2.1 International Convention for the Prevention of Pollution from Ships and the Act to Prevent Pollution from Ships

The International Convention for the Pr evention of Pollu tion from Ships (MARPOL) MARPOL Annex I, Regulations for the Preven tion of Pollution by Oil, addresses oil pollution and lists oil prevention requirements for machinery spaces on all ships covered by the Convention and provides requirements for cargo areas of oil tankers. The requirements of MARPOL Annex I cover all petroleu m products, including crude oil, fuel oil, oily waste, oily mixtures located in the bilge, and petroleum pr oducts in cargo spaces of oil tankers. In 1983, the

United States ratified MARPOL Annex I.

The Act to Prevent Pollution from Ships (APPS) The Act to Prevent Pollution from Ships (APPS; 33 U.S.C. § 1901 et seq.) is the federal law implementing those provisions of MARPOL that have been ratified by the United States. With respect to implementation of Annex I, APPS applie s to all U.S. flagged ships anywhere in the world, and to all foreign flagged vessels operating in the navigable waters of the United States. Violations of APPS or MARPOL may lead to detent ion of the vessel in port, denial of port entry,

or the initiation of civil or cr iminal enforcement proceedings.

4-3December 29, 2008

Applicable Coast Guard regulations The Coast Guard generally has the primary re sponsibility to prescribe and enforce the regulations necessary to impl ement APPS in the United States. The following Coast Guard regulations pertain to the manageme nt of the discharge of oil or oily mixtures into the sea from ships 1 :

 Coast Guard regulations (33 CFR 151.10) provide that, when within 12 nautical miles (nm) of the nearest land, any di scharge of oil or oily mixtures into the sea from a ship is prohibited except when all of the fo llowing conditions are satisfied: (1) The oil or oily mixture does not originate from cargo pump room bilges; (2) The oil or oily mixture is not mixed with oil cargo residues; (3) The oil content of the effluent without dilution does not exceed 15 parts per million (ppm); (4) The ship has in operation oily-water separating equipment, a bilge monitor, bilge alarm, or combination thereof, as required by Part 155 Subpart B; and (5) The oily-water separating equipment is equipped with a 15 ppm bilge alarm; for U.S. inspected ships, approved under 46 CFR 162.050 and for U.S. uninspected ships and foreign ships, either approved under 46 CFR 162.050 or listed in the current International Maritime Organization (IMO) Marine

Environment Protection Committee (MEPC) Circular summary of MARPOL approved equipment.

 Coast Guard regulations (33 CF R 151.10) provide that, when more than 12 nm from the nearest land, any discharge of o il or oily mixtures into the sea from a ship is prohibited except when all of the following conditions are satisfied: (1) The oil or oily mixture does not originate from cargo pump room bilges; (2) The oil or oily mixture is not mixed with oil cargo residues; (3) The ship is not within a special area; (4) The ship is proceeding en route; (5) The oil content of the effluent wit hout dilution is less than 15 ppm; and (6) The ship has in operation oily-water separating equipment, a bilge monitor, bilge alarm, or combination thereof, as required by Part 155 Subpart B.

Additional Coast Guard regulati ons (33 CFR 151.13) prohibit th e discharge of oil or an oily mixture within MARPOL special areas unless the above requirements are met and the vessels oily-water separating equipment is equipped with a device that stops the discharge automatically when the oil content of the effluent exceeds 15 ppm.

Further, Coast Guard regulati ons (33 CFR 151.10) provide that if the bilge water cannot be discharged in compliance with these standa rds, then it must be retained onboard or discharged to a designated reception facili ty. However, both MARPOL and the APPS regulations exempt emergency discharges needed to save the ship or save a life at sea.

1 Sections 151.09 through 151.25 of the Coast Guard regulations at Chapter 33 CFR do not apply to: 1) a warship, naval auxiliary, or other ship owned or operated by a country when engaged in noncommercial service; 2) a Canadian or U.S. ship being operated exclusively on the Great Lakes of North Amer ica or their connecting and tributary waters; and 3) a Canadian or U.S. ship being op erated exclusively on the in ternal waters of the United States and Canada; or 4) any other sh ip specifically ex cluded by MARPOL.

4-4December 29, 2008

Emergency discharges or other exceptional di scharges must nevertheless be accurately recorded in ship records and reported to the nearest port state or Co ast Guard Captain of

the Port.

 In addition, Coast Guard regul ations (33 CFR 151.25) provide that vessels of 400 gross tons and above shall fully maintain an Oil Record Book Part I (Machinery Space Operations) and vessels of 150 gross tons and above that carry 200 cubic meters or more

of oil in bulk shall also mainta in an Oil Record Book Part II (Cargo/Ballast Operations). The Oil Record Book is subject to routin e inspection by the Coast Guard. (33 CFR 151.23; 151.25(g)). In pertinent part , the APPS regulations require:

(a) Each oil tanker of 150 gross tons and above, ship of 400 gross tons and above other than an oil tanker, and manned fi xed or floating drilling rig or other platform shall maintain an Oil Record Book Part I (Machinery Space Operations). An oil tanker of 150 gross tons and above or a non oil tanke r that carries 200 cubic meters or more of oil in bulk, shall also maintain an Oil Record Book Part II (Cargo/Ballast Operations).

* * * (d) Entries shall be made in the Oil Record Book on each occasion, on a tank to tank basis if appropriate, whenever any of the following machinery space operations take place on any ship to which this section applies-- (1) Ballasting or cleaning of fuel oil tanks; (2) Discharge of ballast containing an oily mixture or cleaning water from fuel oil tanks; (3) Disposal of oil residue; and (4) Discharge overboard or disposal otherwise of bilge water that has accumulated in machinery spaces.

* * * (g) In the event of an emergency, accident al or other exceptiona l discharge of oil or oily mixture, a statement shall be made in the Oil Record Book of the circumstances of, and the reasons for, the discharge.

(h) Each operation described in paragraphs (d ), (e) and (f) of this section shall be fully recorded without delay in the Oil Record Book so th at all the entries in the book appropriate to that operation are comp leted. Each completed operation shall be signed by the person or persons in ch arge of the operations concerned and each completed page shall be signed by the master or other person having charge of the ship.

(i) The Oil Record Book shall be kept in su ch a place as to be readily available for inspection at all reasonable times and shall be kept onboard the ship.

(j) The master or other person having char ge of a ship required to keep an Oil Record Book shall be responsible fo r the maintenance of such record.

4-5December 29, 2008

MARPOL contains additional requ irements on what information mu st be recorded in an Oil Record Book, including the details of overboa rd discharges of “bilge water which has accumulated in machinery spaces” 2 / (MARPOL, Annex I, Appendix III(D)). MARPOL also requires the logging of any failu re of the oil discharge mon itoring and control equipment ( Id . at Appendix III(F)). MARPOL also requires that any accidental or other “exceptional” discharge be recorded in the Oil Record Book ( Id . at Appendix III(G)). In short, cruise ships must maintain an accurate record of overboard discharges per this requirement.

4.2.2 Oil Pollution Act and Clean Water Act

The Oil Pollution Act of 1990 (OPA; 33 U.S.C. § 2701 et seq.) is a comprehensive statute designed to expand oil spill prevention, prepared ness, and response capab ilities of the federal government and industry. It amends section 311 of the Clean Water Act (CWA; 33 U.S.C. § 1321) to clarify federal response authority, increa se penalties for spills, establish Coast Guard response organizations (including elements of the National Strike Force, district response advisory staff, Coast Guard personnel, and equipm ent of ports within the district), require tank vessel and facility response plans, and provide for contingency planning in designated areas. CWA section 311, as amended by OPA, applies to cr uise ships and prohibits discharge of oil or

hazardous substances in harmful quantities into or upon U.S. navigable waters, or into or upon the waters of the contiguous zone, or which may affect natural resources in the U.S. Exclusive Economic Zone (which exte nds 200 miles offshore).

EPA regulations (40 CFR 110.3) provide that for the purposes of section 311(b)(4) of the CWA, discharges of oil in quantities that the Admini strator has determined may be harmful to the public health or welfare or the environment of the United States include discharges of oil that:

 violate applicable water quality standards, or

2 The MARPOL Protocol, Annex I, Appendix III, in pertinent part requires logging of the following information: (D) Non-automatic discharge overboard or disposal otherwise of bilge water which has accumulated in machinery spaces 13. Quantity discharged or disposed of. 14. Time of discharge or disposal (start and stop). 15. Method of discharge or disposal: .1 through 15 ppm equipment (state position at start and end); .2 to reception facilities (identify port); .3 transfer to slop tank or holdi ng tank (indicate tank(s); state quantity transferred and the total quantity retained in tank(s).

* * * (F) Condition of oil discharge monitoring and control system 20. Time of system failure. 21. Time when system has been made operational.

22. Reasons for failure.

* * * (G) Accidental or other exceptional discharges of oil

23. Time of occurrence. 24. Place or position of ship at time of occurrence. 25. Approximate quantity and type of oil. 25. Circumstances of discharge or escape, the reasons therefore and general remarks.

4-6December 29, 2008

 cause a film or sheen upon or discolorati on of the surface of the water or adjoining shorelines, or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

4.2.3 National Marine Sanctuaries Act

The National Marine Sanctuaries Act (NMSA; 16 U.S.C. § 1431 et seq.), as amended, established a national program to designate certain areas of marine environments as areas of special national significance that warrant heightened care. The primary purpose of the law is to protect marine resources and ecosystems, such as coral reefs, sunken histor ical vessels, or unique habitats, from degradation while facilitating public or private us es compatible with resource protection.

NMSA authorizes the National Oceanic and At mospheric Administrati on (NOAA) to designate

as National Marine Sanctuaries areas of the marine environment that have special aesthetic, ecological, historical, or recreat ional qualities, and to provide comprehensive and coordinated conservation management for such areas. The National Marine Sanctuary Program manages 13

sanctuaries and the Papah ā naum oku ā kea Marine National Monument (tog ether referred to as “sites”). Designated sites are managed according to site-specific management plans developed by NOAA that typically prohibit by regulation the discharge or depos it of most material. Under NOAA's implementing regulations for NMSA, regulat ions for most sites allow for discharges incidental to the normal operation of a vessel but exclude oily wastes from bilge pumping. Since the regulations do not specify a limit, this has been interpreted as prohibiting any detectable

amount of oil.

4.3 What technologies are available to mana ge oily bilge water from cruise ships?

In order to maintain vessel stability and eliminate potential ly hazardous conditions from the accumulation of bilge waste, it is necessary to pe riodically pump out the bilge spaces into a holding tank. The bilge water then can be managed in one of two ways: (1) retained onboard in a holding tank and discharged later to a reception f acility on shore; or (2) treated onboard with an Oily Water Separator (OWS). The treated bilg e water then can be discharged overboard in accordance with applicable standa rds and regulations while the petroleum products extracted by the OWS (i.e., oily waste) are retained in a dedicated holding tank onboa rd (and later could be incinerated and/or off-loaded in port). The international standard established by MARPOL Annex I, and implemented into United States law by APPS, is that machinery space waste including bilge water may be discharged overboard if it contains a concentr ation of 15 ppm oil or less, and, for ships beyond the 12 nm limit, provi ded that the ship is underway. MARPOL and APPS also require that the disc harge be made through 15 ppm equipment, namely an OWS and Oil Content Monitor; this equipment must be fitted with the appropriate alarms and stopping devices for ships to discharge in special areas.

The holding tank may contain other oily water mixt ures including decanted water from the fuel and lubricating oil sludge tanks. In addition to removing the waste from the bilge area, a holding tank can allow for some separation of the oil and water. Bilge wate r may be discharged

4-7December 29, 2008

overboard after processing by an Oily Water Separato r and passing through a bilge alarm, more commonly known as an Oil Content M onitor that is designed to dete ct when the effluent exceeds an oil content of greater than 15 ppm. The requi red pollution prevention equipment also includes an automatic stopping device (typically a three-wa y solenoid valve) that when triggered by the Oil Content Monitor, will automa tically divert the oily water mi xture back into a holding tank. APPS and MARPOL define machinery spac e waste as an oily water mixture.

The amount of machinery space waste, as menti oned above, may be reduced through the use of water-lubricated shaft bearing systems. While traditional propeller shaft bearing systems use oil as a lubricating and cooling me dium, water-lubricated propel ler shaft bearing systems use

seawater instead of oil. This substitution can have benefits should a ship experience a shaft bearing leak, for instead of pot entially leaking oil, seawater would be leaked. Depending on where the failure in the propeller shaft beari ng system occurs, the use of water-lubricated systems can potentially reduce the potential for oily waste mixtures to leak into the bilge. Waterlubricated shaft bearing systems are currently installed on a number of Carnival’s larger ships (Carnival Corporation and PLC, 2006).

Under MARPOL, all ships over 400 gross tons are required to have equipment installed onboard that limits the discharge of oil into the oceans to 15 ppm when a sh ip is en route. Such ship equipment allows for compliance with both in ternational regulations (MARPOL) and Coast Guard regulations that require th e oil content of the discharged effluent to be less than 15 ppm

and that it not leave a visible sheen on the surface of the water. Re gulations also require that all

oil or oil residues that cannot be discharged in compliance with these regulations, be retained onboard or discharged to a reception facility.

Conventional bilge water systems use an OWS to remove oil to meet regulatory standards prior to discharge. These systems use the techniques of centrifugal force, coalescence, gravity, and other methods to isolate oil from water (T able 4-2 describes some OWS technologies). The management of bilge water by most vessels consists of the following steps: 1) Bilge water is pumped into a holding tank, which is usually of sufficie nt size to hold the water for several days. 2) Bilge water is processed by an OWS to extract oil and petr oleum products from the bilge water. Different cruise ships may use differe nt types of OWS (e.g., ce ntrifugal, filtration, and gravity based systems). 3) The treated bilge water from the OWS is disc harged overboard provi ded that the OWS is certified by the Coast Guard, using Intern ational Standards Or ganization 9377-2:2000; the discharge does not have an oil content of greater than 15 ppm; a nd the discharge does

not leave a visible sheen on th e surface of the water. 4) All oil or oil residues that cannot be discha rged in compliance with the abovementioned requirements – generally the oily waste collec ted by the OWS – is retained in a holding

tank until it can be incinerated onboard or off- loaded to a land-based treatment facility (CELB, 2003).

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Table 4-2. Oily Water Separator Technologies

Description/Capabilities of OWS Devices Processing Capacity

– Removes oil and grease using naturally-occurring microbes

– C ontinuous monitoring of hydrocarbons in effluent

– Typically reduces oil content to 1-5 ppm Up to 5400 gallons/day)

– Designed to separate and remove free and emulsified oil

– System can treat bilge and sludge

– Oil content meter (bilge alarm calibrated to measure 15 ppm oil content) 12 - 24 m 3 /day (or 53 - 106 gallons/day)

– Utilizes fluid velocity reduction, differential specific gravity, and coalescences to separate nonsoluble oil, solids, and entrained air from oily water; uses ultra-filtration membranes

– Provides efficient removal or reduction of oil content to less than 5 ppm Up to 44 gallons/minute

– High-speed centrifugal separation system for treatment of large bilge

water volumes at sea

– Generally reduces oil content to below 5 ppm

– Continuous operation (24 hours/day) Approximately 400 - 1320 gallons/hour

Sources: EnSolve, 2008(a and b); Senitec, 2006 and 2008; Coffin World Water Systems, 2008; Alfa Laval, 2008

All vessels are required to have a bilge alarm or bilge monitor integrated into the piping system to detect whether the treated bilge water that is being discharged from the oily water separator has turbidity levels calibrated to be equivalent to samples containing an oil content greater than 15 ppm. If the monitor senses that the oil in the bilge water exceeds 15 ppm, the system is required to stop the overboard discharge and dive rt the effluent back to a holding tank. Any bilge water found to contain oil or oil residues with an oil content greater than threshold levels must be retained onboard or discharged to a designated reception facility . According to the Center for Environmental Leadership in Busine ss (CELB) (2003), several cr uise lines now often use two oily water separators to assure that effluent levels meet or exceed the 15 ppm limit. Also, California’s multi-agency Cruise Ship Envi ronmental Task Force Report to the Legislature (2003) identified some of the more modern oil water separator systems that include a series of filters to further scrub oil from the bilge water prior to discharging. As mentioned earlier, all discharges from the OWS system are required to be logged in the cruise ship’s oil record log

book.

California’s Cruise Ship Envi ronmental Task Force Report (2003) identified the following potential problems associated with OWS systems:

 Data recorders can be manipulated or s hut off and not record all discharges;

 Oil-water interface detectors (o il content monitor) can easily get out of calibration and

allow more oil to be discha rged than legally allowed;

 Piping systems can be re-routed to bypass the oil-water detectors;

 Substances such as cleaning solvents are not removed from bilge water and are routinely discharged with the liqui ds into the ocean; and

 Bilge water tanks are used to dispose of other hazardous materials, both liquids and solids, illegally because the bilge alarm/ bilge monitor will not detect these other

substances.

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In an attempt to improve the in tegrity of Oily Water Separators , as of 2007 a number of cruise lines have purchased a bilge water processing syst em “White Box” (Marinfloc AB, 2007a). The “White Box” is a proprietary system considered to be a tamper resistant fail-safe for overboard discharges of processed bilge water, serving as the final monitoring and control device through which processed bilge water passes prior to di scharging overboard. The “White Box” System basically includes the pressure co ntrol valve, oil content meter, flow control box, 3-way valve, flow meter, flow switch, 3-way rinse valve, and a recorder (Marinfloc AB, 2005). All the equipment is built into a lockable cabinet. The sy stem monitors the oil content in the water from the oily water separator or bilg e water cleaning system. When the water from either of these systems is clean enough for discharge, a valve is opened and the water is pumped overboard. Before the water is discharged, it passes through a flow meter with a pulse transmitter connected

to the recorder which records and stores the following information (M arinfloc AB, 2006a):

 time when the overboard pumping starts;

 oil content meter level over a discharge cycle;

 total quantity of water pumped over board in a discharge cycle; and

 time when the overboard pumping stops.

Further, the “White Box” can be supplied with a more sophisticated recorder that enables the ship’s position and course to be recorded as well (Marinfloc AB, 2006a). According to the

Carnival cruise line’s Envi ronmental Management Report (C arnival Corporation and PLC, 2006), all Carnival ships route all bilge water de stined for overboard discharge, including that stored in clean bilge water holding tanks, through a bilge water processi ng system “White Box.”

The “White Box” is one of many commercially avai lable control technologi es designed to make bypassing more difficult. Other ideas are relativel y simple, such as placing a unique number tag on every overboard flange in order to prevent un authorized discharges or locking the overboard valve. Any technological solution to deter de liberate pollution, however, remains subject to compromise by an engineer determined to circ umvent treatment. Other means to treat oily wastes in bilge water that are being explored include electro- chemical flocculation, biological digestion, membrane polishing, oil absorp tion, and incineration (Bryant, 2001).

A number of cruise lines have purchased equipment that br eaks emulsions in oily bilge water (Marinfloc AB, 2007b). Cleaning agents, emulsifier s, solvent, or surfactants used for cleaning purposes may cause bilge water to emulsify. As stated in MEPC 107(49) , “with the possibility of emulsified bilge water always present, th e 15 ppm Bilge Separator must be capable of separating the oil from the emulsion to produce an effluent with an oil content not exceeding 15 ppm.” The use of an emulsion br eaking bilge water cleaning system can help achieve this. After free oil is separated from preheat ed oily bilge water, the remain ing emulsified bilge water is

directed to a circulati on tank where a flocculent and small am ount of service air is fed into the water at which point a circulation pump causes mixing. Flocks are then skimmed off, and the remaining water goes through a number of filtering stops. The effluent water from the emulsion breaking bilge water cleaning system then pass es through the OWS monitor. Bilge water less than 15 ppm can be discharged accordingly; bi lge water exceeding 15 ppm is returned to the bilge water holding tank or settling/ primary tank. (Marinfloc AB, 2006b).

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Under the Cruise Lines Interna tional Association (CLIA) member agreement identified earlier, bilge and oily water residue should be processed pr ior to discharge to remove oil residues, such

that oil content of the effluent is less than 15 ppm as specified by MARPOL Annex I. In accordance with MARPOL Regulation 20 and U.S. regulations (33 CFR 151.25) as appropriate, CLIA member lines report that they have agreed that every cr uise ship of 400 gross tons and above shall be provided with an oil record book which shall be completed on each occasion whenever any of numerous specifi ed operations take place on the ship. Those operations include the following (CLIA, 2006):

a. ballasting or cleaning of fuel oil tanks;

b. discharge of dirty ballast or cleaning water form the fuel oil tanks above;

c. disposal of oily residues; and

d. discharges of bilge water that accumulated in machinery spaces.

4.4 What are the potential environmental impacts associated with inadequately treated bilge water from cruise ships?

In an examination of oil pollution in the marine environment, the Urban Harbors Institute (2000)

indicates that about 70% of su ch oil pollution is due to chronic pollution from municipal and industrial wastes or runoff, dumping of waste oil, release of oily bilge water, and from otherthan-tanker transportation. Bilge water is the most common source of oil pollution from cruise ships (National Association of Attorneys General, 2002). Cruise ships have th e potential to create oil pollution throu gh discharges of inadequately treate d oily bilge water as a result of a faulty or malfunctioning OWS, human error, ma lfunctioning bilge monitors, or a deliberate OWS bypass.

The impacts from oil pollution can vary depe nding upon numerous factors. The Port of Cordova, Alaska, has produced educational materi als for harbor and non-ha rbor users explaining that “one pint of spilled oil can cause a sheen over an acre of water and kill the marine organisms that live on the surface” (Urban Harbors Institute, 2000). The National Research Council (2003)

states that the effect of a rele ase of petroleum is not directly related to the volume, rather the effect is a “complex function of the rate of release, the nature of the released petroleum (and the proportions of toxic compounds it may contain), and the local phys ical and biological ecosystem exposed.” Other factors include the s eason, weather conditions, and the surrounding environment. Consequently, even a small sp ill at the wrong place, at the wrong time can result in significant damage to individual organisms or entire populations.

Oily bilge water may contain emulsified oil and gr ease, diesel, hydraulic oil, lube oil, and a full range of marine fuel oils. Oil is composed of thousands of compounds in varying quantities;

some oils are more harmful to the environment a nd more toxic than others. The toxicity of many of the individual compounds contained in petroleum can be significant, and even small releases can kill or damage organisms from the cellu lar- to the population-leve l (National Research Council, 2003). Recent studies suggest that polyc yclic aromatic hydrocarbons (PAHs), even in low concentrations, can have a deleterious e ffect on marine biota. PAHs are known human carcinogens and occur in varyi ng proportions in crude oil a nd refined products (National Research Council, 2003). Environment Canada (2006) further indicate s that the different

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physical and chemical properties of crude and refi ned oils influence the physical and biological effects of an oil spill, the be havior of a slick, and the effec tiveness of clean-up operations.

Lighter petroleum products, such as gasoline or diesel fuels, can dissipate and evaporate quickly but are highly toxic and create severe environmental impacts. In contrast, the medium and heavier oils do not evaporate, and therefore ma y require intensive structural and shoreline cleanup. Although heavier oils are less toxic than light oils, the heavy oils can harm waterfowl and fur-bearing mammals through coating and inges tion. Also, heavy oils can sink and create prolonged contamination of the sea bed and create ta r balls that can scatter along beaches. (U.S. Government Accountability Office, 2007).

Table 4-3 provides a description of oil types and th e interactions that occur when such oil types

are released into the marine environment. This table does not take into acc ount the fact that bilge

waste is a mixture of different oils and frequently contains an emulsion due to the use of surfactants and degreasers such as soap. Surfactants and degreasers, which are often incompatible with the proper use of pollution prev ention equipment, may also have an impact on

the introduction of oil into the marine environment.

Table 4-3. Description of Oil Types and the Interaction When Released

into the Marine Environment

Oil Type Removal and Response Environmental Impact Very light oils (jet fuels, gasoline) Highly volatile (they will evaporate within 1-2 days). It is rarely possible to clean up the oil from such spills. Highly Toxic: Can cause severe impacts to shoreline resources.

Light oils (diesel, no. 2 fuel oil, light crudes) Moderately volatile, but will leave a residue after a few days. Clean-up can be very effective for these spills. Moderately Toxic: Has the potential to create long-term contamination of

shoreline resources.

Medium oils (most crude oils) Some oil (about one-third) will evaporate in 24 h ours. Clean-up is most effective if conducted quickly. Less Toxic: Oil contamination of shoreline can be severe and long-term, and can have significant impacts to waterfowl and fur-bearing mammals. Heavy oils (heavy crude oils, No. 6 fuel oil, bunker C fuel) Little or no oil will evaporate. Cleanup is difficult. Less Toxic: Heavy contamination of shoreline resources is likely, withsevere impacts to waterfowl and furbearing mammals through coating and ingestion.
Source: U.S. Government Accountability Office, 2007

When considering the types of fuels and oils that cruise ships use, the California Cruise Ship Environmental Task Force Report (2003) indicates that cruise sh ips generally run their main engines on intermediate fuel (IFO 180 or IFO 380). This fuel is also referred to as “bunker fuel” and requires heating to reduce its viscosity in or der to be properly atomized and combusted. The California Cruise Ship Environmental Task Forc e Report also notes that marine gas oil or a blend of marine gas oil and bunker fuel may be used by some ships during maneuvering.

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According to the National Research Council (2 003), the discharges from bilge water are

considered to be moderate in terms of their lo ss by evaporation and dissolution, formation of tar balls, and potential for lo ng-distance transport. In addition, ve ssel discharges pose a low risk of vertical mixing because the releases are gene rally viscous (National Research Council, 2003).

Oil released into the marine environment imme diately begins to move and weather, breaking down and changing its physical and chemical pr operties. Some of these processes occur immediately after the spill, wh ile others occur over time. Some of the processes include dissolution, sedimentation, movement, bio-degrad ation, evaporation, weat hering, and dispersion. As these processes occur, the oil threatens surf ace resources and a wide range of subsurface marine organisms, which are linked in complex food chains. Some orga nisms may be seriously injured or killed very soon after contact with the oil in a spill, however, non-lethal toxic effects are more subtle and often longer lasting (U.S. Environmental Protection Agency, 2006).

Oil can kill marine organisms, reduce their fitness through sublet hal effects, and disrupt the

structure and function of marine communities and eco systems. The chemical contaminants in oil can poison marine life, disrupt feeding, or cause chronic dise ase, reproductive failure and deformities – ultimately impacting the survival ra tes of the affected species. Contaminants concentrate in the sea surface microlayer which is an important area for the early development of many fish and other marine species with planktonic life stages. Effects of contaminants on eggs

and larvae found at the sea surf ace in sites along U.S. coasts include mortality, malformation, and chromosome abnormalities. (Urban Harbor Institute, 2000).

Exposure of marine organisms to petroleum hydro carbons can result in mortality due to acute toxicity or physical smothering. Additionall y, possible long-term impacts include: impaired survival or reproduction; chronic toxicity of persistent components; and habitat degradation (Peterson and Holland-Bartels, 2002). Oil, even in minute concentrations, can kill fish or have various sub-lethal chronic effects (CRS, 2007), as well as severely damage coral reefs. According to the Bluewater Network (2000), ingesti on of oil can kill birds or lead to starvation, disease, and predation of thes e animals. A Canadian study has estimated that 300,000 seabirds are killed annually in Atlantic Canada as a result of illegal discharges of oil from ships (Wiese, 2002). In that report, Wiese (2002) indicates that the analysis of oil collected from bird plumage

in Atlantic Canada and the No rth Sea over the last 10 years s howed that over 90% of the oil collected was composed of heavy fuel oil mixed w ith lubricant oil – the t ype found in bilges of large ocean-going vessels. In addition to th e strong evidence for the impact of massive contamination associated with an oil spill, ther e is increasing evidence that chronic, low-level exposures to hydrocarbons in the sea can ha ve a significant effect on the survival and reproductive performance of seabirds and some marine mammals (National Research Council, 2003).

According to CELB (2003), any oils that re main on the surface can interfere with larvae development and marine birds; heavier oils can sink to the bottom of the ocean and contaminate the sediment, causing potential long-term impact s to benthic habitats. According to CELB (2003), diesel fuel is acutely toxic to fish, invertebrates, and seaweed, although in open water this fuel dilutes quite rapidly. CELB (2003) furthe r states that spills can be particularly toxic to

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crabs and shellfish in shallow, confined near -shore areas because in these organisms oil bioaccumulates – often over a period of several weeks after exposure.

As stated by the Urban Harbors Institute (2000), “while overall con centrations of oil toxins from chronic sources might be lower compared to c oncentrations following a catastrophic spill in the marine environment, chronic pollution can be eq ually toxic to marine life if sustained over extended periods of time.” The Urban Harbors Ins titute further suggests that “while contingency planning for large oil spills is important and mandated by the Oil Pollution Act, planning for the small and recurrent contributions to water qua lity problems from chronic sources is equally important.” Chronic source contribu tions from cruise ships (i.e., cruise ships discharge oily bilge water treated to 15 ppm) should be considered in the context of cumulativ e impacts of repeated discharges because cruise ships frequently trans it an established route and port destinations. In fact, the National Research Counc il (2003) identified th at research on the cumulative effects of multiple types of hydrocarbons in combination with other types of pollutants is needed to assess the toxicity and organism response under cond itions experienced by organisms in polluted

coastal zones.

4.5 What action is the federal government taki ng to address oily bilge water from cruise ships?

The federal government’s bilge water manageme nt efforts have focused on responding to oil spills and developing preventative programs. Th e Coast Guard is the primary federal agency responsible for monitoring and enforcing requirements for cruise ship discha rges. In addition to monitoring and enforcing standard s, the Coast Guard has been working with the IMO to develop new international performance standards fo r oil pollution prevention equipment.

The National Park Service (NPS) manages cruise ship waste streams indirectly in Glacier Bay National Park through competitively awarded con cession contracts. The NPS has jurisdiction over the submerged lands and marine waters of Gl acier Bay National Park up to 3 miles from the mean high tide line and including all of Glacier Ba y proper. Glacier Bay is a well known, very popular attraction for the cruise ship industry in Alaska. Rece nt environmental reviews and decisions allow up to two cruise ship entries pe r day into Glacier Bay pr oper during the primary visitor season. Cruise ship operations in the park are authorized under concession contracts, which are awarded under a compet itive solicitation and prospectus process. Impact on park resources is a general standard selection criterion for park co ncessions. The NPS uses waste stream management as one of a number of selecti on criteria in this regard . In the past, cruise ship operators have usually proposed to minimi ze the impact of waste streams by committing to a no-discharge policy while in the park (even if legal under applicable law) for sewage, graywater, ballast water, bilge water, cooling water, hazardous waste, and solid waste. If awarded a contract, companies must comply with their proposal. Typically cruise ships operate in the park for 8-10 hours and then depart. Crui se ships do not dock or transfer any wastes to shore while in the park.

EPA has developed a water permit program for po llutant discharges inci dental to the normal operation of vessels. Under a U.S. District C ourt decision, the existing EPA regulations that

4-14December 29, 2008

exclude discharges incidental to the normal operation of a vessel from Clean Water Act permitting were vacated (revoked) as of December 19, 2008. The District Court’s decision to vacate that exclusion was recently upheld by the Ninth Circuit Court of Appeals. NW. Envt’l

Advocates et al. v. EPA , 537 F.3d 1006 (9th Cir. 2008). As explained in section 1.1, as of December 19, 2008, discharges incidental to th e normal operation of vessels (such as bilge water) into waters of the U.S. from cruise ship s 79 feet or longer in length will be subject to National Pollution Discharge Elimination System permitting.

In a report produced by the U.S. Genera l Accounting Office (now the Government Accountability Office) in 2000, 87 confirmed illega l discharges from foreign-flagged cruise ships in U.S. waters were identified during the period from 1991-1998. Of the 87 cases, 81 incidents involved illegal discharges of oil or oi l-based products. The re port indicated that about three-fourths of these cases were accidental, resu lting from human or mechanical error, while the

remainder were either intentional or the lack of information pertaining to the case made it difficult to determine the cause. The report also stated that a few of the 87 cases of illegal discharges involved multiple illegal discharge in cidents that numbered in the hundreds over the 6-year period. (U.S. General Accounting Office, 2000.)

In an effort to curb the number of illegal oil discharges, the federal government is taking criminal

enforcement actions to address violations of bilge water quality and treatment requirements. More specifically, th e Coast Guard has a robust enforcem ent regime involving all vessels regarding violations of MARPOL Annex I. The Coast Guard conduc ts inspections of all cruise vessels operating in United Stat es ports and waters quarterly and annually. These inspections typically include examination and testing of po llution prevention equipment and review of Oil Record Books. The Coast Guard works closely w ith the U.S. Department of Justice. Through this cooperation, criminal enforcement actions have been taken for intentional discharges of oily bilge waste. The most common violations of bilge water quality and treatment requirements

include the intentional falsifica tion of Oil Record Books to c onceal the deliberate bypassing of the OWS entirely or tampering with the mon itoring equipment. Tampering has included disabling or modifying the Oil Content Monitor or flushing the device with freshwater to prevent sampling of the actual effluent. Inspections of vessels have found the following problems:

 Data records that are manipulated or data recorders that are disabled;

 Poorly maintained OWS equipment and related piping systems;

 Crew error or lack of crew training;

 Bilge alarms/monitors that are out of ca libration due to poor maintenance (thereby allowing bilge water discharges that exceed 15 ppm of oil);

 Piping systems that are re-routed to b ypass the bilge alarms/monitors; and,

 Improper use of cleaning chemicals and surf actants which degrade OWS efficiency and conceal oil discharge sheens.

Deliberate discharges of untreated bilge water might be accompanied by efforts to deceive port state control officials by falsifyi ng the Oil Record Book. Several por t states (i.e., the country the cruise ship visits) have reacted by increasing th eir scrutiny of OWS systems and diligence for oil record book keeping (OECD, 2003). The U.S. is ta king a lead in enforcement actions for such

criminal violations. To date the U.S. has prosecuted over 75 cases involving intentional discharges of oily bilge waste from vessels in general, with over $150 million collected in

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criminal fines since 2000. Many of the major cr uise ship companies calling on U.S. ports have

been convicted of such viola tions, including, Royal Caribbean, Holland America, Carnival and Norwegian Cruise Line Limited. As a result of the prosecutions, all the companies have been at one time placed on probation with a requirement to implement Environmental Compliance Plans.

4.6 Possible Options and Alternatives to Add ress Oily Bilge Water from Cruise Ships

Based on the public comments receiv ed on the draft of this report as well as other information gathered, listed below are a wide range of options and alternatives that address oily bilge water from cruise ships. Identification of a ny particular option does not imply any EPA recommendation or preference for future action, or that EPA has determined that any of these options are necessary or feasible, or that EPA believes a change to the status quo is warranted, or that EPA or any other entity has the le gal authority to implement that option.

Prevention & Reduction

 Establish standards or best management pr actices for operation, maintenance, and/or training that will decrease the contaminants in bilge water and/or the volume of treated and/or untreated oily bilg e water on cruise ships.

 Conduct research to determine the presence of hazardous wastes (other than oil) entering the bilge that will be eventually discharged, given that present treatment processes target

oil.

 Encourage cruise lines to switch to water-ba sed lubricants wherever possible to reduce total production of petroleum-based oily wastes onboard the ship.

 Conduct research on the environmental benefits of alternative lubricants, such as bio-oils, taking into account additional environmenta l risks and damages caused by failures of machinery and systems that use bio-oils.

 Encourage recycling of lubricants and other waste oils from oil storage systems.

Control: Discharge Standards

 States could enact laws prohibi ting the discharge of any petr oleum product into marine or

fresh waters.

 Require the highest attainab le reduction of oil concentr ation in bilge water through application of the best available technology economically achievable.

 Treat effluents from oily bilge water to an oil content <15 ppm en route and provided that the ship is operating outside special areas.

 Review current Coast Guard vessel inspection and enforcement programs and practices, including those applicable to oily wastewater treatment and discharge, to determine if modifications are necessary.

 Evaluate the need for increased oily water separator performance standards.

 Prohibit the addition of any hazardous wast e into the bilge area to then be managed/treated as oily bilge water.

 Require m ore stringent standards in areas fre quented by multiple cruise ships in order to adequately address cumulative impacts.

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Control: Geographic Restrictions on Discharge

 Ban discharges of untreated or treated oily bilge water in all U.S. waters.

 Require discharge to proper shore-side facilities.

Enforcement & Compliance Assurance: Monitoring

 Conduct an assessment of the concentrations of metals and organic contaminants in treated bilge water to determine the presence of other pollutants in the discharge.

 Require sampling and testing of oily bilge water discharges to ensure that it meets applicable standards by:

o government agencies with enforcement authority,

o third-parties, and

o cruise lines.

 Require onboard observers to monitor sampli ng, monitoring, and othe r effluent-related requirements to oversee discharging practices , equipment operation and maintenance, and the completion and submittal of accurate Oil Record Books.

Enforcement & Compliance Assurance: Reporting

 Require the installation of electronic transponders to signa l land-based authorities when a waste discharge line is opened or closed.

 Require cruise ship operators to immediately notify appropriate agencies in the event of

an OWS malfunction.

 Require that cruise ship ope rators provide advance notific ation from ships planning to discharge in U.S. waters.

 Require that the cruise ship operators notify al l appropriate agencies of all discharges of oily bilge water.

 Publicize the APPS whistleblower provisions under 33 U.S.C. 1908(a) to passengers and crew members in order to encourage both to aid in the detection of illegal pollution by alerting authorities when witnessing activ ities they believe to be illegal.

Enforcement & Compliance Assurance: Inspections & Enforcement

 Revise current inspection practices to mo re aggressively identify noncompliant OWS equipment and include more detailed inspec tion of a vessel’s piping system to identify rerouting of discharges to circumvent bilge monitors and alarms.

 Provide states enforcement authority to ta ke actions when discharges occur where otherwise prohibited; require substantial penalt ies for violations of those laws and require the full recovery of all costs arisi ng from enforcement of such laws.

 Establish penalties for failure to meet applic able standards and regul ations pertaining to oil content in bilge water discharges.

 Establish a funding mechanism based on the polluter-pays model that will provide revenues to develop and im plement a comprehensive regulatory scheme.

 Impose uniform requirements on all ships as a condition of port entry and within waters under the jurisdiction of the U.S. consistent with international law, regardless of flag

state.

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 Prohibit or otherwise restrict noncompliant vessels (and sister ships, depending on the degree of involvement by parent companies) from operating in sens itive areas of the marine environment under U.S. jurisdiction.

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References

Alaska Department of Environmental Conservation (ADEC). 2000. Alaska Cruise Ship Initiative Part 1 Final Report . Juneau, AK. ( www.dec.state.ak.us/water/cruis e_ships/pdfs/finreportp10808.pdf )

Alfa Laval. accessed Decem ber 28, 2008. EcoStream: Oily Water Cleaning System

. ( http://www.alfalaval.com/solution-finder/pr oducts/eco-stream/Documents/Ecostream.pdf )

Bluewater Network. (2000, March 17). Peti tion to Environmental Protection Agency Administrator Carol M. Browner. ( www.epa.gov/owow/oceans/cruise_ships/petition.pdf )

Bryant, Dennis L. 2001. Environmental Complia nce in the Cruise Industry . Holland and Knight Articles and White Papers. (http://www.gsy.fi/id24660/P ublicationId3/ReturnId33/ ServiceId131/contentid45721/)

Carnival Corporation and PLC. 2006. Environmental Management Report: Fiscal Year 2006

. (http://phx.corporate-ir .net/phoenix.zhtml?c= 140690&p=irol-hess)

Center for Environmental Lead ership in Business (CELB). 2003. A Shifting Tide: Environmental Challenges and Cruise Industry Responses. Washington, DC. ( www.celb.org/ImageCache/CELB/content/travel _2dleisure/cruise_5finterim _5fsummary _2epdf/v1/cruise_5finterim_5fsummary.pdf )

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Congressional Research Service (CRS). 2007. Cruise Ship Pollution: Background, Laws and Regulations, and Key Issues (Order Code RL32450). Washington, DC. ( www.ncseonline.org/NLE/CRSreports/07Jul/RL32450.pdf )

Cruise Lines Internationa l Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry Waste Management Practices and Procedures . F ort Lauderdale, FL. ( www.cruising.org/industry/PDF/CLIA W asteManagementAttachment.pdf and www.cruising.org/industry/PDF/ CLIAW asteManagement.pdf )

Cruise Ship Environm ental Task Force. 2003. Report to the Legislatur e: Regulation of Large Passenger Vessels in California

. (http://www.swrcb.ca.gov/publ ications_forms/publications /legislative/docs/2003/cruisesh iplegrpt.pdf)

EnSolve. accessed December 28, 2008a. Petroliminator PL 630M OWS: Product Fact Sheet

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EnSolve. October, 2008b. EnSolve Biosystems Inc. News – Volume 1, Issue 1

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Environment Canada. 2006. Oil, Water, and Chocolate Mousse . The Green Lane, Environment

Canada’s World Wide Website. (http://www.ec.gc.ca/ee-ue/def ault.asp?lang=EN&n=88F67B04)

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Marinfloc A B. May, 2006b. USCG MED IMO MEPC 107(49) Approved Emulsion Breaking Bilge Water Cleaning System EBBWCS Mk III – Model “CD.” Data Sheet # 8. ( http://www.marinfloc.com/upload/f iles/ebbwcs/08%20CD%20Com plete%2015%2001% 202008.pdf )

Marinfloc A B. 2007a. List of References: Whit e Box System – Type WBS . Data Sheet # 50004, 2007-10-24. ( http://www.marinfloc.com )

Marinfloc A B. 2007b. List of References: Emulsion Breaki ng Bilge Water Cleaning System – Type CD . Data Sheet # 21, 2007-10-24. ( http://www.marinfloc.com )

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. Washington, DC.

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2003. Oil in the Sea III: Inputs, Fates, and Effects . Washington, DC: National Academy Press. ( http://www.nap.edu/catalog.php?record_id=10388#toc )

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Maritime Sector . Paris, France. ( www.oecd.org/dataoecd/4/26/2496757.pdf )

Peterson, Charles H.; Holland-Barte ls, Leslie. 2002. Nearshore verteb rate predators: constraints to recovery from oil pollution. Marine Ecology Progress Series 241:235-236.

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SEA . Senitec MB 1000. ( http://www.senitecsludge-oilywatertreatment.com/pdf/sea1.0.pdf )

Senitec 2006. EC Type Examination Certific ate: Oil-Filtering Equipmen t (for oil content of the effluent not exceeding 15 p.p.m.) . Senitec SEA 1.0. (http://www.senitecsludge-oilywatertreatment.com/pdf/cert_senitecSEA1.0.pdf)

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4-21 Urban Harbors Institute (University of Massachusetts Boston). 2000. Green Ports: Environmental Management and Technology at US Ports . Boston, MA.

U.S. General Accounting Office (now the Government Accountability Office). 2000. Marine Pollution: Progress Made to Reduce Marine Pollution by Cruise Ships, but Important

Issues Remain . Report to Congressional Requesters. GAO/RCED-00-48.

U.S. Government Accountability Office. 2007 . Marine Transportation: Major Oil Spills Occur Infrequently, but Risks Remain . Testimony before the Subcommittee on Oceans, Atmosphere, Fisheries, and Coast Guard; Committee on Commerce, Science and Transportation, U.S. Senate. GAO-08-357T.

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. (EPA/310-R-97-003). Washington, D.C.: Author. ( http://www.epa.gov/compliance/ resources/publications/assis tance/sectors/notebooks/wat ersct.pdf )

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W iese, F.K. 2002. Seabirds and Atlantic Canada’s Ship-Source Oil Pollution: Impacts, Trends,

and Solutions . Prepared for World Wildlif e Fund Canada. Toronto, Canada. (http://www.wwf.ca/Document s/Marine/SeabirdsReport.pdf)December 29, 2008



### Section 5: Solid Waste

Solid waste, as defined in section 1004(27) of the Resource Conservation and Recovery Act (RCRA), is the garbage, refuse, sludge, rubbis h, trash, and other discarded materials resulting from industrial, commercial, and other operations , as well as that disposed of every day by individuals, businesses, and communities. Solid waste can be either non-hazardous or hazardous waste. On most cruise ships, solid waste is managed by utilizing a multifaceted strategy that includes source reduction, source segregation for waste streams, wa ste minimization, and recycling. According to the Alaska Department of Environmental Conservation (ADEC) (2001), 75 to 85% of trash is generally incinerated onboar d, and the ash is typically discharged at sea;

some solid waste is landed ashore for disposal or recycling (CRS, 2007).

This section discusses the curren t state of information about solid waste, the laws regulating solid waste from vessels, how solid waste is managed on cruise ships, the potential environmental impacts of cruise ship solid waste, and federal actions take n to address solid waste from cruise ships. The conclusion of this secti on lists a wide range of options and alternatives

that could be considered when addre ssing solid waste from cruise ships.

5.1 What is solid waste and how much is generated on cruise ships?

Solid waste is the garbage, refuse, sludge, rubbi sh, trash, and other discarded materials resulting from industrial, commercial, and other operations , as well as that disposed of every day by individuals, businesses, and communities. Solid waste can be either non-hazardous or hazardous waste. Non-hazardous waste, for example, may be in the form of trash and the waste associated with product packaging, cans, bottles, food wast e, newspapers, product and machinery parts, disposable products, and recyclable products. This section discusses non-hazardous solid waste generated on cruise ships. Hazardous waste, howeve r, is a type of solid waste, which, because of its quantity, concentration or physic al or chemical characteristics, may pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed or otherwise managed. Hazardous waste generall y contains hazardous substances which can be liquids, solids, or contained gases and mu st be handled, tracked, treated, and disposed of separately from other types of solid waste. Hazardous waste generated on cruise ships is discussed separately in Section 6.

Solid waste generated onboard a cr uise ship typically comprises th e materials used for packaging products for transportation or st orage, waste generated by passe nger and crew activity, and food waste. More specifically, the types of solid wa ste generated on a ship can include food waste, glass, paper, wood, cardboard, inci nerator ash, metal cans, and pl astics. Table 5-1 identifies some types of common solid waste items, includi ng specific examples, generated aboard cruise ships.

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Table 5-1. Some Types and Specific Exam ples/Descriptions of Solid Waste Generated on Cruise Ships

Type of Solid Waste Examples and Descriptions

Cardboard Dunnage (lining and packaging materials that float) and cardboard from all manner of packaging materials
Paper Paper and packaging

Plastic Synthetic ropes, plastic containers, plastic bags, biodegradable plastics, poly-ethylene terephthalate plastics, and high density polyethylene plastics

Wood Wood pallets and waste wood

Glass Chipped or broken glasses, food and beverage jars, bottles

Metal cans Aluminum soft drink cans, tin cans from the galley, steel cans from ship maintenance operations

Food waste Wastes derived in whole or in part from fruits, vegetables, meats, or other plant or animal material (includes food scraps, table refuse, galley refuse, food wrappers or packaging materials contaminated with food residue)

Incinerator ash Ash generated from the incineration of packaging materials, paper and cardboard wastes, etc. Food wrappers and packaging Paper and plastic wrapping/packaging materials with food residue

According to a 1999 Royal Caribbean Cruises Envi ronmental Report, packaging materials from consumables and spare parts for a ship can generate up to 15 tons of wast e in a single day. Table 5-2 presents the estimates of cer tain types of solid waste gene rated per week on an individual

vessel in the Holland America Lines and Royal Caribbean Cruises fleets.

Table 5-2. Estimates of Solid Waste Generated Per Vessel per Week

Holland America Lines Royal Caribbean Cruises Dunnage 30 cubic meters 60 cubic meters

Glass and Cans 6,000 lbs of glass

450 lbs of cans 5 cubic meters of glass

2.5 cubic meters of cans

Food Wastes 12 cubic meters 12 cubic meters
Sources: ADEC, 2002 and Royal Caribbean Cruises Ltd., 1999

The amount of solid waste generate d by cruise ships varies from ship to ship, based on the size of the vessel, number of passengers and crew, an d consumption of material. Compared to other types of vessels, cruise ships generate large volumes of solid waste. Environmental Resources Limited (1991) estimated that a cruise ship gene rates 70 times more solid waste per day than a typical cargo ship. However, the National Research Council (1995) acknowledges that when examining vessel garbage, the estimate of the quantity of garbage generated is not necessarily a measure of the amount handled by onboard treatment technologies or port reception facilities. When determining the amount of garbage genera ted on a vessel, the National Research Council (1995) suggests that the “amount of garbage is proportional to the community’s standard of living; the higher the standard, the more seafarer s are likely to use packaged prepared foods,

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supplies, and single use items rath er than provisions requiring added preparation and cleanup.”

It has been further estimated that 24% of the solid waste generated by vessels worldwide (by weight) comes from cruise ships (N ational Research Council, 1995).

With large cruise ships carrying several thousan d passengers, the amount of waste generated in a given day can be considerable. One large crui se ship of 2,500 passengers and 800 crew (total 3,300 persons onboard) can generate 1 ton of garbag e from normal operations in a day (National Research Council, 1995). On average, each cruise ship passenger gene rates at least two pounds of non-hazardous solid waste per day (CELB, 2003). In addition to that, each cruise ship passenger disposes of two bottles and two cans (bot h of which are recyclable materials) per day (CELB, 2003). Table 5-3 presents various estimates of the amount of solid waste a passenger generates in a given day during a cruise.

Table 5-3. Estimates of Solid Waste Genera ted per Person per Day on a Cruise Ship

Source of Data Trash Generated (lbs/person/day)

Environmental Resources Limited 7.7

Florida Caribbean Cruise Association 0.7

Holland America Line 1.8 Organization of Eastern Caribbean States Waste Management Study 6.5

Seebacher 5.7
Source: Simmons & Associates, 1994

The newest addition in Royal Caribbean ’s Freedom family of ships, the Liberty of the Seas , is currently the largest cruise ship at 1,112 ft long and carries up to 3,634 passengers and 1,360 crew. Building even larger cruise ships is on the horizon with Royal Ca ribbean building Genesis class ships that will be almost 1,200 feet long (Bell, 2007). Over the past two decades, the average ship size has been increa sing at the rate of roughly 90 ft every 5 years (Bell, 2007). As the size and number of passengers these cruise sh ips can carry increases, the volume of wastes generated – and discharged – will presumably increase as well.

5.2 What federal laws apply to solid waste from cruise ships?

5.2.1 International Convention for the Prevention of Pollution from Ships and Act to Prevent Pollution from Ships

The International Convention for the Pr evention of Pollu tion from Ships (MARPOL) MARPOL Annex V regulates the disposal of garbag e into the sea, by sett ing forth prohibitions on disposal (e.g., of plastics), to establishing how and wher e garbage generated during the normal operation of a ship is to be disposed (e.g., food wastes). Under Annex V, the term garbage includes “all kinds of victual, domestic and operational waste, excluding fresh fish and parts thereof, generated during th e normal operation of the ship a nd liable to be disposed of continuously or periodically ex cept those substances which ar e defined or listed in other

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Annexes.” The Annex also requires governments to ensure the provision of facilities at ports and terminals for the reception of garbage. Annex V sets more stringent discharge standards for specifically identified “special areas.” The special areas are “sea areas where for recognized

technical reasons in relation to its oceanographic and ecological c onditions and to the particular character of its traffic, the a doption of mandatory methods for the prevention of sea pollution by garbage is required.” The special areas identif ied by Annex V are the Mediterranean Sea, Baltic Sea, Black Sea, Red Sea, Gulfs area, North S ea, Antarctic, and Wider Caribbean Region. In addition, the Annex requires some ships (i.e., de pending on size and passenge r load) to maintain Garbage Record Books, develop Garbage Manageme nt Plans, and display placards that outline the disposal requirements.

Act to Prevent Pollution from Ships The Act to Prevent Pollution from Ships (APPS) and its implementing regulations (33 CFR 151.51-77) prohibit the discharge of all garbage within th ree miles of shore; certain types of garbage from 3-25 miles offshore; and plastic an ywhere. Vessels are also required to record each discharge or incineration of garbage in a Garbage Record Book. Under APPS, the definition of “ship” includes fi xed or floating platforms. Ther e are separate garbage discharge provisions applicable to these un its. For these platforms, and for any ship within 500 meters of these platforms, disposal of certain types of garbage is prohibited. Additionally, all manned, oceangoing U.S. flagged vessels of 12.2 meters or more in length that are engaged in commerce, and all manned, fixed, or floating platforms subject to the jurisdiction of the United States, are required to keep records of ga rbage discharges and disposals. The Coast Guard regularly inspects vessel discharge records and logbooks required by MARPOL, and investigates all allegations of illegal discharges on the high seas or within United States waters. Receipts and record-keeping for Annex V waste streams from ships are addressed in MARPOL Annex V, Regulation 9.

Applicable Coast Guard Regulations The Coast Guard generally has the primary re sponsibility to prescribe and enforce the regulations necessary to impl ement APPS in the United States. The following Coast Guard regulations pertain to the manage ment of solid waste on ships:

 Every manned oceangoing ship of 400 gross to ns and above and every ship certified to carry 15 passengers or more shall ensure that a written record is maintained on the ship for the following discharge or disposal operations:

o discharge overboard,

o discharge to another ship,

o discharge to a reception facility, and

o incineration on the ship (33 CFR 151.55).

 Each manned, oceangoing ship of 40 feet or more in length must have a garbage management plan in place and each person handling the garbage must follow the plan (33 CFR 151.57).

 Each ship of 26 feet or more must ensure that appropriate placa rds outlining disposal requirements are placed in prominent loca tions and in sufficient numbers for both passengers and crew (33 CFR 151.59).

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 No person onboard any ship may discharge garb age into navigable waters of the United States. Navigable waters means the waters of the United States, including the territorial seas (i.e., the belt of seas measured from the line of ordinary low water along that portion

of the coast which is in direct contact with the open sea and the line marking the seaward limit of inland waters, and extending seawar d a distance of three miles). No person onboard any ship may discharge into the sea, or into the navigable waters of the United States, plastic or garbage mixed with plastic, including but not limited to synthetic ropes, synthetic fishing nets, and plas tic garbage bags. All garbage containing plastics must be discharged ashore or incinera ted (33 CFR 151.66 and 151.67).

 For vessels operating outside a special area, no person may discharge, into the sea, garbage that is separated from plastic, if the distance from nearest land is less than: (1) 25 nautical miles (nm) for dunnage, lining and pack ing materials that float; or (2) 12 nm for victual wastes (any spoiled or unspoiled f ood wastes) and all othe r garbage including paper products, rags, glass, metal, bottles, cr ockery and similar refuse, except that, such garbage may be discharged outside of 3 nm from nearest land afte r it has been passed through a grinder or comminuter (i.e., pulverizer) and is capable of passing through a screen with openings no greater than 25 mm (33 CFR 151.69).

 When the garbage is mixed with other discha rges having different di sposal or discharge requirements, the more stringent requirements shall apply.

Table 5-4 provides a summary of garbage discharg e restrictions per 33 CFR Part 151 for vessels operating both in special areas and outside of special areas.

Table 5-4. Summary of Garbage Di scharge Restrictions for Vessels

All Vessels Except Fixed or Floating Platforms and Associated Vessels Garbage Type Outside special areas (33 CFR 151.69) In special areas 2

(33 CFR 151.71) Plastics, including synthetic ropes and fishing nets and plastic bags Disposal prohibited (33 CFR 151.67) Disposal prohibited (33 CFR 151.67)

Dunnage, lining, and packaging

materials that float Disposal prohibited less than 25

miles from nearest land and in the navigable waters of the U.S. Disposal prohibited (33 CFR 151.71)

Paper, rags, glass, metal bottles, crockery and similar refuse Disposal prohibited less than 12

miles from nearest land and in the navigable waters of the U.S. Disposal prohibited (33 CFR 151.71)

Paper, rags, glass, etc. -- comminuted or ground 1 Disposal prohibited less than 3 miles

from nearest land and in the navigable waters of the U.S. Disposal prohibited (33 CFR 151.71)

Victual waste 4 not comminuted or ground Disposal prohibited less than 12

miles from nearest land and in the navigable waters of the U.S. Disposal prohibited less than 12

miles from nearest land

Victual waste comminuted or ground 1 Disposal prohibited less than 3 miles

from nearest land and in the navigable waters of the U.S. Disposal prohibited less than 12

miles from nearest land

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M ixed garbage types 3 See Note 3 See Note 3
Source: 33 CFR 151.51- 151.77 Appendix A

1 Comminuted or ground garbage must be able to pass throug h a screen with a mesh size no larger than 25 mm (1 inch) (33 CFR 151.75).

2 Special areas under Annex V are the Mediterranean, Baltic , Black, Red, and North Seas areas, the Gulfs area, the Antarctic area, and the Wider Caribbean region, including the Gulf of Mexico and the Caribbean Sea (33 CFR 151.53).

3 When garbage is mixed with other substances having different disposal or discharge requirements, the more stringent disposal restrictions shall apply.

4 Victual waste is any spoiled or unspoiled food waste.

 The regulations applicable to port reception facilities for garbage are published at 33 CFR Part 158. Under those regulations, the Coas t Guard administers the reception facility “Certificate of Adequacy” (C OA) program for certification, including periodic inspection of the port reception facilities to which those regulations apply. All port facilities and terminals under the jurisdiction of the United States, including commercial fishing facilities, mineral and oil shor e bases, and recreational boati ng facilities, must have a garbage reception facility whic h meets the regulatory requirem ents for adequacy (33 CFR 158.133(c)). These regulations apply to U.S. ports and terminals that receive garbage from cruise ships. Though only a subset of those ports require a COA, (see 33 CFR 158.135(c) for COA criteria with respect to Annex V wastes), Coast Guard field units regularly inspect all port recepti on facilities for adequacy, regardless of the requirement for a COA, and investigate all allegations of inadequate reception facilities.

5.2.2 Clean Water Act

As a general matter, the Clean Water Act (CWA ; 33 U.S.C. § 1251 et seq.) prohibits any person from discharging any pollutant from any point source into waters of the United States, which includes the territorial seas (i.e., the belt of seas measured from the line of ordinary low water along that portion of the coast which is in dire ct contact with the open sea and the line marking

the seaward limit of inland waters , and extending seaward a distan ce of three miles), except in compliance with a National Pollutant Discharg e Elimination System (NPDES) permit or as

otherwise authorized under the Ac t. The term “point source” is defined to include a “vessel or other floating craft.” The term “pollutant” does not include se wage from vessels (within the meaning of CWA section 312). Outs ide the territorial se as, i.e., in the con tiguous zone or the ocean, the addition of any pollutant from a “vessel or other floating craft” is not a “discharge of pollutants,” and therefore does not require an NPDES permit (CWA section 502(12)(b)). The addition of any pollutant to the waters of the contiguous zone or ocean from any point source

other than a “vessel or other floating craft” is a “discharge of pollutants,” and therefore does require an NPDES permit. However, EPA has interpreted this permitting requirement to apply to certain discharges from a vessel that operate s in a capacity other than as a means of transportation such as when used as an energy or mining facility, a storag e facility or a seafood processing facility, or when secured to the bed of the ocean, contiguous z one, or waters of the United States for the purpose of mineral or oil exploration or developm ent (40 CFR 122.3(a)).

In addition, EPA regulations (40 CFR 122.3(a)) have historically ex cluded discharges incidental to the normal operation of a vessel (for exampl e, effluent from prope rly functioning marine engines, laundry, shower, and ga lley sink wastes) from the requirement of an NPDES permit.

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This regulatory exclusion has not applied and does not apply to discharges of rubbish, trash, garbage, or other such materials discharged overboard a vessel, which would be solid waste subject to RCRA. Whether a discharge is authorized under an NPDES permit affects applicability of RCRA; dissolved and solid materials in i ndustrial discharges which are point sources subject to NPDES permits are not “s olid waste” under the RCRA statute. This only applies to materials once they have been discha rged. For further information regarding operation of the RCRA statute as it applie s to solid waste and hazardous waste, see sections 5.2.4 and 6.2.2, respectively.

5.2.3 National Marine Sanctuaries Act

The National Marine Sanctuaries Act (NMSA; 16 U.S.C. § 1431 et seq.), as amended, established a national program to designate certain areas of marine environments as areas of special national significance that warrant heightened care. The primary purpose of the law is to protect marine resources and ecosystems, such as coral reefs, sunken histor ical vessels, or unique habitats, from degradation while facilitating public or private us es compatible with resource protection. NMSA authorizes the National Oceanic a nd Atmospheric Administration (NOAA) to designate as National Marine Sa nctuaries areas of the marine environment that have special aesthetic, ecological, historical , or recreational qualities, a nd to provide comprehensive and coordinated conservation management for such areas. The National Marine Sanctuary Program manages 13 sanctuaries and the Papah ā naum oku ā kea Marine National Mo num ent (together referred to as “sites”). Designated sites are managed according to site-specific management plans developed by NOAA that typically prohibit by regulation the discharge or deposit of most material. Under NOAA's implementing regulation s for NMSA, it is illegal to discharge solid

waste into most national marine sanctuaries.

5.2.4 Resource Conservation and Recovery Act

The Resource Conservation and Recovery Act (R CRA; 42 U.S.C. § 6901 et seq.) is the federal law that, among other things, de fines and provides for regulati on of solid waste and hazardous waste. RCRA is designed to minimize the hazard s of waste disposal, conserve resources through waste recycling, recovery, and reduction, and en sure waste management practices that are protective of human health and the environmen t. In order to achieve these goals, RCRA established a Solid Waste Program (RCRA Sub title D) and a Hazardous Waste Program (RCRA Subtitle C). 1 RCRA Subtitle D encourages environmentally-sound solid waste management practices that maximize source re duction, reuse, and recycling effort s, and establishes regulations that specify how solid waste disposal facilities (i.e., municipal solid waste landfills) should be designed and operated. RCR A provides that solid waste is predominantly regulated by state and local governments (U.S. Envir onmental Protection Agency, 2006).

1 In states with hazardous waste pr ograms authorized by EPA, the auth orized state hazard ous waste program operates in lieu of the federal hazardous waste program. Some states have authorized hazardous waste programs that are more stringent than the federal hazardous waste program.

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5.2.5 Marine Protection, Research, and Sanctuaries Act

The Marine Protection, Researc h, and Sanctuaries Act (MPRSA, 33 U.S.C. § 1401 et seq.) (also called the Ocean Dumping Act) prohibits (1) the transportation of any material from the United States for the purpose of disposal in ocean wate rs without a permit; (2) the transportation of any material by U.S. agencies or by U.S. flagged vess els or aircraft for the purpose of disposal in ocean waters without a permit; a nd (3) any person from dumping, without a permit, any material transported from a location outside the United States into the U.S. territorial seas or into the contiguous zone, to the extent it may affect the territorial seas or the territory of the United States. This Assessment Report does not addres s the transportation of materials that would require an ocean dumping permit under MPRSA.

5.3 What practices are available to manage solid wastes generated on cruise ships?

The m anagement of shipboard-gener ated waste is a challenge not onl y for cruise ships at sea, but also for other commercial vessels, military ships, fishing vessels, and recreational boats. Most cruise ship trash is treate d onboard (incinerated, pulped, or ground for discharge overboard) (CRS, 2007). According to ADEC (2001), 75 to 85 % of trash is generally incinerated onboard, and the ash is typically discharg ed at sea; some solid waste is landed ashore for disposal or recycling (CRS, 2007). The Center for Environmental Leadership in Business (CELB) (2003) states that Royal Caribbean’s Vision-class ships sort, crush, and off-load about 450 pounds (204kgs) of aluminum cans for recycling per week-long trip.

Food wastes and hazardous wastes generated on crui se ships are often separated from other solid wastes and processed separate ly. Food waste is often pulped or compressed, and then incinerated. According to ADEC (2000), the food liquids (1,300 to 2,600 gallons per day) removed during dehydration are recycled through a pulping/compression process several times, and eventually end up in the graywater holdi ng tanks; the remaining compressed, dehydrated

food waste is incinerated. Hazardous wastes ar e separated from other solid wastes because onboard incinerators do not operate at the temperatures necessary to properly destroy hazardous substances. Therefore, proper wa ste identification and segregation of hazardous waste prior to burning is critical. As a result, waste segregation, as well as crew and passenger training, and compliance with appropriate waste handling procedures is a fundamental aspect of vessel waste management and safe discharges. Upon arriving in port, the solid waste generator (the cruise ship) off-loads any remaining solid waste (inc luding incinerator ash) in accordance with applicable state solid wast e management requirements. 2 Examples of Royal Caribbean Cruise’s waste management practices are presented in Table 5-5.

2 RCRA Subtitle D established regulations addressing how solid waste disposal facilities should be designed and operated.

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Table 5-5. Waste Management Practices as Reported by Royal Caribbean Cruises

Type of Waste Management Practice

Cardboard Packaging materials are collected onboard and incinerated or off-loaded for recycling or disposal. Incinerator ash is landed ashore for disposal.
Paper Paper wastes are collected onboard and incinerated or off-loaded for recycling or disposal. Incinerator ash is landed ashore for disposal.

Plastic Plastic wastes are collected onboard an d incinerated or off-loaded for recycling or disposal. Incinerator ash is landed ashore for disposal.

Glass Glass is collected, crushed onboard, stored, and off-loaded for recycling.

Metal Cans Cans are collected and sorted onboard to separate out the aluminum cans that have a high market recycling value. Cans are crushed on board, stored, and off-loaded for recycling.

Food Waste Wet food waste is processed through giant grinders (called pulpers) that reduce the size of food particles, which allows for more efficien t removal of water by extractors. Removing

excess water allows food waste to be bu rned and managed more easily. The water removed in the process is ultimately discharged as gray water. Incinerator ash is landed ashore for disposal.

Source: RCCL, 1999

The Cruise Lines International Association (CLIA) environmenta l standards noted earlier are intended to provide for improved solid waste management through:

 source reduction,

 minimization,

 recycling,

 collection,

 processing, and

 discharge ashore.

The CLIA environmental standards are intended to provide for the elimination of, to the maximum extent possible, the disposal of MARPOL Annex V wastes into the marine environment through purchasing practices, reuse and recycling programs, landing ashore, and onboard incineration in approved shipboard incinerators. Some cruise sh ips report that they employ various types of equipment such as glas s crushers, metal can compactors, and shredders in addition to incinerators, to prepare waste to be recycled in port (U.S. General Accounting Office, 2000).

Adopting a multifaceted strategy that include s waste minimization, source reduction, and recycling, along with waste stream management a nd periodic ash testing, should be sufficient to

ensure that incinerator ash does not meet the de finition of hazardous wast e (e.g., if it exhibits a

characteristic of hazardous waste as define d in 40 CFR Part 261 Subpart C. For more information, see Section 6 for the hazardous waste discussion). Proper hazardous waste management procedures are to be instituted onbo ard each ship to ensure that waste products

which will result in a hazardous ash are not introduced into the incinerator. The CLIA environmental standards further provide that when such items are separated out from the waste stream, the waste will be identi fied and segregated for indivi dual handling and management in accordance with appropriate laws and regulations. (CLIA, 2006).

As mentioned above, the CLIA envi ronmental standards call for the testing of incinerator ash at least once quarterly for the firs t year of operation to establis h a baseline, and annual testing

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thereafter. Any incinerator ash that exhibits a characteristic of hazardous waste as defined in 40 CFR Part 261 Subpart C must be disposedonshore in accordance with RCRA, which may include additionally applicable st ate law requirements specific to the jurisdiction where the ash is landed. MARPOL Annex V specifies requirement s for the disposal at sea of non-hazardous incinerator ash, which alternat ively can be landed ashore.

Some additional reported approaches available to large cruise ship line s to reduce solid waste discharges that specifically target the proper handling of plastics in clude the following (U.S. General Accounting Office, 2000; RCCL, 1998):

 replacing disposable plastic and St yrofoam cups with reusable cups;

 reducing paper and plastic wrapping;

 replacing plastic condiment pack ages with bulk dispensers;

 eliminating plastic garbage bag liners;

 replacing disposable plastic plates and cutle ry with china and washable plastic dishes;

 eliminating plastic bottles of shampoo and body lotion and replacing them with dispensers in the cabins; and

 using recycled paper in laundr y bags instead of plastic.

5.4 What are the potential environmental impacts associated with solid waste from cruise ships?

Waste products in the past were made from natu ral materials and were mostly biodegradable. Now, much of the non-hazardous wa ste generated is either not eas ily biodegradable or does not biodegrade at all (CELB, 2003). According to Campbell (1999), the average solid waste generated daily per cruise ship passenger is 3.5 k ilograms, which consists of food wastes, glass, plastics, paper, cans, cardboard, a nd wood. If cruise ships fail to properly store solid waste that is destined for off-loading to por t reception facilities or fail to properly incinerate their solid waste before disposing of it into the ocean, or if passengers throw litter overboard or items are inadvertently blown overboard (e.g., towels, clothes, soda cans, plastic bottl es, etc.), there is the potential for the introduction of plas tics and other solid wastes from cruise ships into the marine environment. In such instances, the solid wast e introduced into the marine environment becomes marine debris. According to NOAA, any persiste nt solid material that is manufactured or processed and directly or indire ctly, intentiona lly or unintentionally, disposed of or abandoned

into the marine environment or the Great Lakes is marine debris (NOAA, 2008). Marine debris has also been defined as “any man-made object that enters the marine environment due to numerous processes, including car eless handling or disposal, inte ntional or unint entional release

of materials or as a result of national disasters and storms (Sh eavly, 2007). Marine debris can also be considered simply as objects that are found in the marine environment but do not naturally occur there (U.S. Environmental Protection Agency, 1992).

Even though under the MARPOL agreement and U.S. federal law it is illegal for any vessel to discharge plastics or garbage c ontaining plastics into any waters, there have been cases when unlawful discharges of solid waste and plas tics h ave taken place. From 1993 through 1998,

federal data indicate that fore ign-flagged cruise ships were in volved in 6 cases of confirmed illegal discharges of garbage or plastic (U.S. General Accounting Office, 2000). Solid waste that

5-10December 29, 2008

enters the ocean directly or i ndirectly can pose a threat to ma rine organisms, humans, coastal communities, and commercial industries. This ma rine debris may accumulate on beaches, on the surface of waters, and in the benthos.

The fate of garbage after it is discharged overboard depends on a number of factors, including the physical characteristics (espec ially the density) of the solid a nd whether the garbage is loose or bagged. According to the National Research C ouncil (1995), large, dense particles, such as ground glass and shredded metal, quickly sink. In areas where there is a strong pycnocline, small particles tend to disperse in the surface layer, while emulsifi ed particles may remain in the water column for long periods of time. Organic material may or may not sink.

Plastics are quite buoyant and may accumulate on the surface of water and on beaches. According to Cohen (2008), 60% of trash on beaches is plastic, and 90% of debris floating in the ocean is plastic. Newly discarded plastic items fl oat and may be transported far from the site of discharge. Plastics also may sink over time as they break apart, weather, or accumulate organic coatings, tar, shells, or sand. Floating debris, such as plastics, is be ing implicated in the

contamination of some habitats by nonindigenous invasive species (Cruise Ship Environmental Task Force, 2003). Consequently, implementing proper garbage handling practices for plastics is especially critical given that plastics are “highly functional materials and will continue to be available” (National Res earch Council, 1995).

Regardless of how materials are predicted to fl ow in the ocean, wash ups of some types of marine debris on beaches seem to defy logica l explanation (National Research Council, 1995). Not only can beach users be injured by pieces of gl ass, cans, or other litter washed ashore, such marine debris on beaches may cause significant adverse economic impact in coastal communities. For example, in 1988, it was estimat ed that New Jersey lost between $379 million
and $3.6 billion in tourism and other revenue as a result of debris washing ashore (National Research Council, 2008).

The potential environmental and physical effects of marine debris incl ude (National Research Council, 1995):

 aesthetic degradation of surface waters and beach areas;

 physical injuries to humans and life-threa tening interference with their activities;

 ecological damage caused by the interference of plastics with gas exchange between overlying waters and those in the benthos;

 alterations in the composition of ecosystems caused by debris that provide habitat for opportunistic organisms;

 entanglements of birds, fish, tu rtles, and cetaceans in lost or discarded nets, fishing gear, and packaging materials; and

 ingestion of plastic particles by marine animals.

Food is often the largest single co mponent of the garbage stream in ships (Polglaze, 2003). If discharged in sufficient quantities, food waste can contribute to increases in biological oxygen demand, chemical oxygen demand, and total orga nic carbon, diminish water and sediment quality, adversely effect marine biota, increase turbidity, and elevate nutrient levels. Polglaze (2003) further states that food wa ste components may be detrimental to fish digestion and health,

5-11December 29, 2008

and have unsuitable nutrient content. Conti nued disposal of food wastes in restricted environments can cause nutrient pollution, if th e water is not freely ex changed (Cruise Ship Environmental Task Force, 2003). Also, regular and sufficiently large inoculations of food waste to an area may cause ecological changes su ch as perturbations to species behavioral patterns and alternation to comm unity species composition and dive rsity (Polglaze, 2003). An additional potential environmental impact of di scharged food waste may be the inadvertent introduction of food associated plastics. To a void an unintentional introd uction of plastics with food wastes to the marine environment, it is critic al to remove all food associated plastics before food wastes are comminuted prior to being discharged at sea or incinerated to then be discharged

at sea.

Ash generated from the incinerator consists of trash (e.g., cardboard, paper, plastic), food solids from the food pulper systems, and sewage/grayw ater residuals (e.g., gray water screening solids, sewage/graywater screening solid s, and sewage/graywater waste biosludge). Th e International Maritime Organization (IMO) guidelines for A nnex V implementation recognize the potential for air pollution associated with incinerator use and therefore discourage th e use of incinerators in ports in or near urban ar eas (Annex V, Appendix B, Sect ion 5.4). The guidelines further recognize that some disadvantages of incinerators may in clude the hazardous nature of the ash or vapor, and that when in use, incinerators may not meet air pollution regulations imposed in certain harbors (Annex V, Appendix B, Section 5.4.5). Further, the incineration of plastics requires special precautions due to the potential environmental and health effects from the combustion of by-products. In these cases, the guid elines suggest that the incineration of plastic wastes complying with Annex V is to take place in a safe manner with an incinerator suitable for the incineration of plastics, otherwis e the following problems can result:

 Depending on the type of plastic and conditions of combusti on, some toxic gases can be generated in the exhaust str eam, including vaporized hydrochlor ic and hydrocyanic acids. These and other intermediary products of plastic combustion can be extremely dangerous (Annex V, Appendix B, Section 5.4.6.1).

 The ash from the combustion of some plastic products may contain heavy metal or other

residues which can be toxic and should theref ore not be discharged into the sea (Annex V, Appendix B, Section 5.4.6.2).

Further, the Parliamentary Commi ssion for the Environment (2003) stat es that a cruise ship solid waste incinerator may produce small amounts of polychlorinated biphe nyls and polycyclic aromatic hydrocarbons.

5.5 What action is the federal government taking to address so lid waste from cruise ships?

The Interagency Marine Debris Coordinating Committee, a federa l group co-chaired by EPA and NOAA, is looking into ways to reduce the impact and sources of marine debris (any abandoned

or uncontrolled solid material that is introduced into the oc ean and coastal environment), including debris from vessels such as cruise ships. The group provided recommendations for research priorities, educational program s, monitoring techniques, and federal agency action in a Report to Congress in 2008. This report is requ ired by section 5(c) of the Marine Debris Research, Prevention, and Re duction Act (Pub. L. 109-449).

5-12December 29, 2008

According to the IMO (2007), the United Nation s General Assembly invited IMO to review MARPOL Annex V, in consultation with releva nt organizations and bodies, to assess the

Annex’s effectiveness in addressi ng sea-based sources of marine debris. Comprehensive review of MARPOL Annex V began in February 2006 w ith the formation of a correspondence group. The U.S. Government has been an active particip ant in this group. A working group to consider whether amendments to the Annex are necessary will be formed in July 2009 at MEPC 59.

The Coast Guard implements ongoing inspecti on and compliance programs to insure the adequacy of port reception facilities. In 2006 alone, the Coast Guard conducted over 14,000 facility inspections (up from approximately 3,500 in calendar year 2000), including inspections of MARPOL Annex V port reception facilities for compliance and adequacy. During the period from 2002 to 2006, vessel arrivals at U.S. ports n early doubled, which in turn increased pressure on the capacities of U.S. ports. In meeting this increased compliance and inspection challenge, the Coast Guard issued or responded to and inves tigated 7,424 facility de ficiencies in calendar year 2006, including reception facil ity deficiencies (up from 2,587 in calendar year 2000). From the time period between 2002 and 2006, the Coast Gu ard has documented a 26% reduction in the number of pollution incidents re ported at facilities, which de monstrates the Coast Guard’s continuing commitment to vigorous impleme ntation of the pollution prevention and environmental stewardship missions which have b een entrusted to the Coast Guard by Congress. This includes the administration of the COA prog ram and insuring the adequacy of all U.S. port reception facilities for Annex V wastes from vessels.

The United States (as a party to MARPOL), with active Coast Guard engagement, participates in international work groups in efforts to sta ndardize both Advance Notice Forms generated by vessels with respect to th eir reception facility needs for all wast es and a standard receipt form for such wastes. Addressing this standardization issue has been an ongoing effort by the MEPC of the IMO (since at least October 200 4) to improve the performance of port reception facilities for solid waste management. The Coast Guard itself has focused on ways to address standardized reporting, including updates to implementing regulati ons, as well as the Coas t Guard instructions that provide guidance to its fiel d units. Implementation of standardized receipts, as proposed by the IMO with Coast Guard concurrence, will enhance the capacity of Coast Guard inspectors to confirm both allegations of illegal discharges and reports of inadequate reception facilities (approximately 80 reports of inadequacies have b een received and investigated in 2007). Coast Guard inspectors will be able to compare Advanc e Notice records with reception facility receipts (which are required to be kept with the vesse l garbage log book for a period of two years under Section 4.2 of the Appendix to MARPOL Anne x V, 2006 Consolidated Edition). Presently, reports of inadequate reception facilities ar e available through the IMO’s Global Integrated Shipping Information System public website at http://gisis.imo.org/Public/.

The National Park Service (NPS) manages cruise ship waste streams indirectly in Glacier Bay National Park through competitively awarded con cession contracts. The NPS has jurisdiction over the submerged lands and marine waters of Gl acier Bay National Park up to 3 miles from the mean high tide line and including all of Glacier Ba y proper. Glacier Bay is a well known, very popular attraction for the cruise ship industry in Alaska. Rece nt environmental reviews and decisions allow up to two cruise ship entries pe r day into Glacier Bay pr oper during the primary

5-13December 29, 2008

visitor season. Cruise ship operations in the park are authorized under concession contracts, which are awarded under a compet itive solicitation and prospectus process. Impact on park resources is a general standard selection criterion for park co ncessions. The NPS uses waste stream management as one of a number of selecti on criteria in this regard . In the past, cruise ship operators have usually proposed to minimi ze the impact of waste streams by committing to a no-discharge policy while in the park (even if legal under applicable law) for sewage, graywater, ballast water, bilge water, cooling water, hazardous waste, and solid waste. If awarded a contract, companies must comply with their proposal. Typicall y cruise ships operate in the park for 8-10 hours and then depart. Crui se ships do not dock or transfer any wastes to shore while in the park.

5.6 Possible Options and Alternatives to Address Solid Waste from Cruise Ships

Based on the public comments receiv ed on the draft of this report as well as other information gathered, listed below are a wide range of options and alternatives that address solid waste from cruise ships. Identification of any particular option does not imply any EPA recommendation or preference for future action, or that EPA has dete rmined that any of these options are necessary or feasible, or that EPA believes a change to the status quo is warranted, orthat EPA or any other entity has the legal authority to implement that option.

Prevention & Reduction

 Increase use and range of on-board garbag e handling and treatmen t technologies (e.g., compactors, pulpers, shredders, and incinerators).

 Resolve issues that may be impeding safe waste storage and expa nded use of compactors

and incinerators.

 Improve infrastructure to assist in recyc ling of all glass, pa per, wood, cardboard, and

aluminum and other metals.

 Introduce and encourage cruise line participation in EPA’s WasteWise and Recycle on the

Go solid waste reduction programs which provide technical assistance to organizations to develop and implement solid waste reduction prac tices (further information is available at http://www.epa.gov/wastewise/about/overview.htm and http://www.epa.gov/osw/conserve/rrr/rogo/index.htm ).

 Em ploy waste reduction for waste material s and plastics by reducing the amount of plastics and other packagi ng materials brought onboard.

 Increase efforts to buy in bulk and choose products with less packaging.

Control: Discharge Standards

 Expand training for employees regarding wa ste segregation requirements by including the legal and environmental basis for those requirements.

 Post waste segregation requirements (al ong with the associated the legal and environmental concerns) onboard (via placard s and written information) for employees and passengers.

 Initiate rulemaking to provide for stronger waste management plans than the current cruise industry practices in orde r to control solid waste discha rges from cruise ships into

all U.S. waters.

5-14December 29, 2008

 Include adequate port reception facilities as a component of a comprehensive vessel garbage management system, and establish a fee system to encour age the use of the

facilities.

 Require that U.S. ports initiating port expansions also build additional reception facilities to receive Annex V wastes from cruise ships.

 Sort all wastes onboard and off-load recyclab les only at ports with recycling facilities.

 Establish accountability for both vessel operato rs and port operators w ith regard to proper solid waste management.

 Determine who should pay for vessel garbage services.

 Ensure all biohazard wastes and infirmary/ sickbay wastes are properly processed for disposal in compliance with state solid wast e disposal regulations for hospital wastes.

 Require an analysis and accounting of the c ontaminants typically found in cruise ship

incinerator ash to determine whether each ba tch of ash generated should be categorized as a solid waste or hazardous waste to then be managed accordingly.

 Require standardized incinerator ash te sting before each overboard discharge.

 Establish performance standards for onboard in cinerators to ensure Annex V compliance.

 Develop standards for compacted solid waste discharges to the marine environment.

Control: Geographic Restrictions on Discharge

 Prohibit the discharge of any waste, food, or otherwise macerated waste into any marine sanctuary or any other sensitive area.

 Prohibit the discharging of incinerator ash from cruise ships into U.S. waters.

 Discontinue discharges of dunnage and floating waste in all waters.

 Bring all solid waste to shore for disposal or recycling.

 Encourage the cruise industry to work with private vendors and ports to ensure that ample recycling opportunities ex ist in foreign ports.

 Expand all port reception fac ilities to accept solid waste.

 Require that wherever cruise ships call, r eceiving ports provide reception facilities for solid waste off-loading and have established waste reception plans.

 Prohibit the use of inci nerators while in port.

 Require that cruise ships off-lo ad garbage during U.S. port calls.

 Encourage EPA and Coast Guard to :

o conduct a feasibility study to determine the costs to provide adequate port reception facilities for cruise ships; and

o develop a “polluter pays” funding mechanism to pay for some or all of the capital costs, operations, and maintenance of such port reception facilities.

Enforcement & Compliance Assurance: Monitoring

 Establish a mandatory, standardized incine rator ash testing program to determine appropriate management of the ash.

 Ensure no discharge of solid waste into the marine environment by establishing a system of monitoring compliance, adequate sanc tions for noncompliance, and forwarding noncompliance data to the vessel’s next port of call.

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Enforcement & Compliance Assurance: Reporting

 Require that ports provide receipts for garb age off-loaded to their reception facilities; compare the receipts to vessel garb age logs for inconsistencies.

 Assess the need for increased recording/l ogging of garbage generation onboard cruise ships.

 Require that cruise ships maintain certifie d log books documenting incinerator ash test results, dates, volumes, ultimate disposition of ash, and locations of legal ash discharges.

 Publicize the APPS whistleblower provisions under 33 U.S.C. 1908(a) to passengers and crew members to encourage detection of illegal pollution.

Enforcement & Compliance Assurance: Inspections & Enforcement

 Streamline enforcement by issuing “tickets” in civil cases.

 Encourage vessel owners to report inadequate reception facilities.

 Conduct public awareness campaigns urging citi zens to report illegal garbage disposal (e.g., passengers on cruise ships who observe a ny illegal dumping and/or the disposal of plastic at sea should report this to the National Response Center or the nearest Coast Guard Marine Safety Office).

 Provide incentives for third party re porting of environmental violations.

 Impose uniform requirements (consistent with international law) on all ships as a condition of port entry and within U.S. waters, regardless of flag state.

 Prohibit or otherwise restrict noncompliant vessels (and sister ships, depending on the degree of involvement by parent companies) from operating in sens itive areas of the marine environment under U.S. jurisdiction.

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References

Alaska Department of Environmental Conservation (ADEC). 2000. Alaska Cruise Ship Initiative Part 1 Final Report . Juneau, AK. ( www.dec.state.ak.us/water/cruis e_ships/pdfs/finreportp10808.pdf )

Alaska Departm ent of Environmental Conservation (ADEC). 2001. Alaska Cruise Ship Initiative Part 2 Report . Juneau, AK. ( www.dec.state.ak.us/water/cru ise_ships/pdfs/acsireport2.pdf )

Alaska Departm ent of Environmental Conservation (ADEC). 2002. The Impact of Cruise Ship Wastewater Discharge on Alaska Waters . Juneau, AK. ( www.dec.state.ak.us/water/cruise_ ships/pdfs/im pactofcruiseship.pdf )

Bell, Tom . 2007 (September 28). Experts: Mega-berth needed for cruise ships. Portland Press

Herald . ( www.pressherald.mainetoday.c om /story_pf.php?id=137059&ac=PHnws )

Center for E nvironmental Lead ership in Business (CELB). 2003. A Shifting Tide: Environmental Challenges and Cruise Industry Responses. Washington, DC. ( www.celb.org/ImageCache/CELB/content/travel _2dleisure/cruise_5finterim _5fsummary _2epdf/v1/cruise_5finterim_5fsummary.pdf )

Cohen, Roz. 2008 (January 18). There’s a future in plastics

. (http://www.conservation.org/FMG/ ARTICLES/Pages/01180802.aspx)

Congressional Research Service (CRS). 2007. Cruise Ship Pollution: Background, Laws and Regulations, and Key Issues (Order Code RL32450). W ashington, DC. ( www.ncseonline.org/NLE/CRSreports/07Jul/RL32450.pdf )

Cruise Lines Internationa l Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry Waste Management Practices and Procedures . F ort Lauderdale, FL. ( www.cruising.org/industry/PDF/CLIA W asteManagementAttachment.pdf and www.cruising.org/industry/PDF/ CLIAW asteManagement.pdf )

Cruise Ship Environm ental Task Force. 2003. Report to the Legislatur e: Regulation of Large Passenger Vessels in California

. (http://www.swrcb.ca.gov/publications_forms/publica tions/legislative/docs/2003/cruiseshiplegrpt. pdf)

Environmental Resources Limited. 1991. Port Reception and Disposal Fa cilities for Garbage in

the Wider Caribbean (Final Report) . Prepared for the International Maritime Organization, the World Bank. London, England.

International Maritime Or ganization (IMO). 2007. Prevention of Pollution by Garbage from Ships. London, England. (www.imo.org/Environment/mainframe.asp?topic_id=297 )

5-17December 29, 2008

5-18 National Oceanic and Atmosphe ric Administration (NOAA). 2008. Marine Debris 101

. (http://marinedebris.noaa.gov/ma rinedebris101/welcome.html)

National Research Council (NRC). 2008. Tackling Marine Debris in the 21 st Century (Report in Brief). Washington, D.C. (http://www.nationalacademies.org/includes/marinedebris.pdf)

National Research Council (NRC), 1995. Clean Ships, Clean Ports, Clean Oceans: Controlling Garbage and Plastic Wastes at Sea . National Academy Press: Washington, DC.

Parliamentary Commissioner for the Environment. 2003. Just Cruising? Environmental Effects of Cruise Ships . Wellington: Parliamentary Commissi oner for the Environment. ISBN: 1-877274-23-2. ( http://www.pce.govt.nz/re ports/allreports/1_877274_23_2.shtm l )

Polglaze, Jo hn. 2003. Can We Always Ignore Ship-Generated Food Waste? Marine Pollution

Bulletin . Volume 46, Issue 1. pp. 33-38. ( http://www.sciencedirect.com/science?_ob=ArticleURL&_udi=B6V6N-47MHXHP3&_user=14684&_rdoc=1&_fmt=&_orig=search&_ sort=d&view=c&_acc t=C000001678&_vers ion=1&_urlVersion=0&_userid=14684 &md5=75901cf546aed19 105a093695ad6388e)

Royal Caribbean Cruises Ltd. (RCCL). 1999. Save the Waves . Environmental Report

.

Sheavly, S.B. 2007. National Marine Debris Monitoring Pr ogram: Final Program Report, Data Analysis and Summary . Prepared for U.S. Environmental Protection Agency by Ocean Conservancy, Grant Number X83053401-02. (http://www.oceanconservancy.org/site/PageServer?pagename=mdm_debris)

Simmons & Associates. 1994. The Impact of Tourism on the Marine Environment of the Caribbean: With Special Refere nce to Cruise and Other Types of Marine-based Tourism

. Caribbean Tourism Organization, Barbados.

U.S. Environmental Protection Agency. 1992. Turning the Tide on Trash: Marine Debris

Curriculum . EPA842-B-92-003. ( http://www.epa.gov/owow/OCP D/ Marine/contents.html )

U.S. Environm ental Protection Agency. 2006. RCRA Orientation Manual 2006: Resource Conservation and Recovery Act . EPA530-R-06-003. (http://www.epa.gov/epaoswer/g eneral/orientat/rom.pdf)

U.S. General Accounting Office (GAO) (now the Government Accountability Office). 2000. Marine Pollution: Progress Made to Redu ce Marine Pollution by Cruise Ships, but Important Issues Remain . Report to Congressional Requesters. GAO/RCED-00-48.December 29, 2008



### Section 6: Hazardous Waste

Hazardous waste is a subset of “solid waste,” an d is a waste that contains hazardous constituents that can be liquid, solid, semisolid, or contained gas. On most cr uise ships, the hazardous waste generated onboard is stored onboard until the wastes can be off-loaded for recycling or disposal. Hazardous waste that is off-loaded for disposal in the United States is handled in accordance with RCRA requirements, and must be sent to a licensed hazar dous waste Treatment, Storage, and Disposal Facility.

This section discusses the curren t state of information about hazar dous waste, the laws regulating hazardous waste from vessels, how hazardous waste is managed on cruise ships, the potential environmental impacts of cruise ship hazardous waste, and federal actions taken to address hazardous waste from cruise ships. The conclusion of this section lists a wide range of options

and alternatives that could be considered when addressing hazardous waste from cruise ships.

6.1 What is RCRA hazardous waste and how much is landed by cruise ships to the

United States?

Under federal law, “hazardous waste” is a su bset of “solid waste.” The regulations implementing the Resource Conservation Recove ry Act (RCRA) establish the criteria for defining “hazardous waste” with two basic approaches: a solid waste is a hazardous waste if it is either a waste that appears on one of the four haza rdous waste lists (i.e., F- List, K-List, P-List, or U-List); or the solid waste exhibits at least one of four hazardous char acteristics (ignitability, corrosivity, reactivity, or toxicity ). Once a waste is identified as a hazardous waste, any person who generates or manages the hazardous waste must comply with all appli cable state and federal regulations regarding its management. Hazardous wa stes need to be stored, treated, and disposed

in a manner so as to minimize the risks to human health and the environment.

The universe of hazardous waste is diverse – it is a waste that contains hazardous constituents that can be liquid, solid, semisoli d, or contained gas. The unive rse of wastes generated as a result of daily cruise ship activ ities is diverse as well. Cruise ship activities such as photo processing, dry cleaning, and e quipment cleaning can produce hazardous waste containing a wide range of substances such as water with perchlorethylene from dry cleaning machines, hydrocarbons, chlorinated hydrocarbons, heavy metals, and solvents. Additional wastes generated on cruise ships that may be hazardous include paint waste, aerosol liquid waste from the crushing of aerosol cans, some incinerato r ash, fluorescent and me rcury vapor light bulbs, various types of batteries, and unused or outdated pharmaceuticals. Table 6

- 1 identifies different types of wastes generated on cruise ships that ar e, or may be, hazardous. This is only a list of typical wastes, and ultimately it is the responsibility of the pers on generating the wa ste (i.e., ship owner and/or operator) to make this determ ination and to comply with all applicable environmental requirements.

6-1December 29, 2008

Table 6-1. Types of Potentially Hazardou s Waste Generated Aboard Cruise Ships

Waste Type Description Photo Processing Waste (including X-ray development fluid waste) Spent fixer, spent cartridges, expired film, and silver flake. The fixer removes unexposed silver compounds from the film during the developing process. Though silver-bearing waste is typically hazardous waste under RCRA due to silver content, RCRA regulations at 40 CFR 266.70, which apply to materi als recycled to recover econom ically significant amounts of certain precious metals, including silver, do not include all of the requirements applicable to other types of hazardous wastes generally. Dry Cleaning Wastes Dry cleaning units produce a small volume of waste from the bottoms of the internal recovery stills and filter media. This waste comprises dirt, oils, filter material, and spent solvent. The spent solvent is a chlorinated solv ent called perchlorethylene (perc) and must be managed as a hazardous waste. Print Shop Wastes Printing solvents, inks, and cleaners may contain hydrocarbons, chlorinated hydrocarbons, and heavy metals. Photocopying and Laser Printer Cartridges Spent or discarded cartridges, inks, and toner ma terials are not typically defined as hazardous under the federal RCRA program, but may be hazardous waste under some authorized state

programs. Used Cleaners, Solvents, Paints, and Thinners Degreasing materials are a common element of maintenance onboard vessels; tetrachloroethylene is used for metal-degreasing.

Used or Outdated

Pharmaceuticals Cruise ships have pharmaceuticals based on the ship’s itinerary and the demographics of the passenger base. Inventory that is discarded because it is off specification or has exceeded shelf life may qualify as hazardous waste.

Incinerator Ash Incinerator ash may contain constituents, such as heavy metals, in concentrations that would classify the ash as hazardous waste under RCRA. Fluorescent/Mercury Vapor Bulbs These bulbs contain small amounts of mercury, and therefore lamps containing these types of bulbs might qualify as RCRA hazardous waste when discarded. To promote the safe recycling and disposal of certain used lamps, EPA classifies these lamps as Universal Waste (40 CFR 273.5). For more information, see www.epa.gov/epaoswer/hazwast e/id /univwast/lamps/lamps.htm

. Batteries Large batteries are used on tenders and standby generators; small batteries are used in flashlights and cameras. Other equipment on board may also require batteries. Four types of batteries typically used onboard cruise ships are:

 Lead-acid – Batteries that are wet, recharg eable, and usually six-celled typically contain a sponge lead anode, a lead diox ide cathode, and a sulfuric acid electrolyte

that is corrosive.

 Nickel Cadmium (Nicad) – Batteries that are usually rechargeable and contain wet or dry potassium hydroxide as an electrolyte. The potassium hydroxide is corrosive;

cadmium is a characteristic hazardous waste.

 Lithium – Batteries used for flashlights and portable electronic equipment. Some spent lithium batteries (specifically, lithium metal-sulfide batteries) may constitute

hazardous wastes based on the “reactivity” criterion (D003).

 Alkaline – Batteries used for flashlights and other personal equipment. Though spent alkaline batteries are not cons idered hazardous waste under federal regulations, some alkaline batteries might be defined as hazardous waste under some authorized states’ more stringent (or broa der in scope) hazardous waste regulations (e.g., some states include tests, such as bioassay tests, to define hazardous waste, and some alkaline batteries may fail this test).

Spent Explosives Explosives are used occasionally in small quantities for celebratory (e.g., theatrical productions, parties, etc.) and/or emergency purposes (e.g., lifeboat flares). Discarded explosives are managed as ha zardous waste (ADEC, 2002).

Sources: ADEC, 2000 and ADEC, 2002

6-2December 29, 2008

Limited information is available on the amount of hazardous waste that a cruise ship might generate. Table 6-2 presents estimates of th e hazardous waste generated in one week by the Holland America Lines fleet, c onsisting of 11 vessels in 2000, and by the Royal Caribbean Cruises Ltd. fleet, consisting of 17 vessels in 1999. The information provided in Table 6-2 identifies specific hazardous waste materials that result from cruise ship activities. It is possible that these estimates may not be representative of th e cruise ship fleets at this time. According to the U.S. General Accounting Office (GAO) Report (2000), some of the larger cruise ship companies reported taking actions to reduce the amounts of hazardous waste onboard. These cruise ship companies reporte d replacing hazardous chemicals with non-hazardous ones, and implementing procedures to improve the coll ection and disposal of waste from hazardous materials that cannot be replaced and must sti ll be used. Table 6-3 presents more current

estimates of waste measured across all of Ca rnival Corporation’s operating lines and ships according to their reports.

Table 6-2. Estimates of Hazardous Was te Generated Per Week Onboard Cruise Ship Fleets

Holland America

Lines Fleet (11 Vessels) Royal Caribbean

Cruises Ltd Fleet (17 vessels)
Waste Type Amount Generated

in 2000 Amount Generated

in 1999

Photo wastes 2262 gallons/week 1300 gallons/week

Discarded and expired chemicals 1735 lbs/week 2050 lbs/week

Medical Waste 45 lbs/week 80 lbs/week

Batteries 75 lbs/week 580 lbs/week 1

Fluorescent Lights 153 lbs/week 270 lbs/week

Explosives 6 lbs/week 12 lbs/week

Spent paints and thinners 213 gallons/week 225 gallons/week

Source: The information above is the hazardous waste production per week by Holland America Lines Fleet, as reported in their 2000 Environmental Report (ADEC, 2002), and by Royal Caribbean Cruises Ltd as reported in their 1999 Environmental Report “ Save the Waves ” (Royal Caribbean Cruises Ltd, 1999).

1 Total amount of batteries includes alkaline/carbon zinc, alkaline/mercury, lead acid, NiCad, mercury, and lithium.

6-3December 29, 2008

Table 6-3. Estimates of Hazardous Waste and Solid Waste Generated Onboard as Reported by Carnival Cruise Lines

Parameter 2006 Measurement 2005 Measurement Notes

Solid and Hazardous Waste (to shore) 0.0066 tonnes/ALBD 0.0077 tonnes/ALBD (1) and (2)

Solid Waste (to sea or incinerated) 0.0079 tonnes/ALBD 0.0083 tonnes/ALBD (1) and (2)

Source: Carnival Corporation & PLC, Environmental Management Report , Fiscal Year 2006

NOTES: 1. Rather than refer to measurements as Passenger Berth Days to normalize data by ship size/capacity, the more commonly referenced cruise industry indicator ALBD (Available Lower Berth Day) is used to normalize data by ship size/capacity. 2. This parameter measures solid and hazardous waste disposal normalized by ALBD. Hazardous waste disposal is normally less than 1% of total waste disposal. Hazardous waste is landed to shore facilities. There are three methods for solid waste, namely disposal ashore, at sea, or incinerated waste. According to Carnival Cruise Line s, the “at sea” or “incinerated waste” is discharged/disposed in accordance with MARPOL an d applicable laws and regulations; plastic is not disposed at sea. Incinerated waste incl udes dry garbage, food waste, and sludge.

In 2003, the California Environmental Protecti on Agency (Cal/EPA) convened a multi-agency Cruise Ship Environmental Task Force to ev aluate the environmental practices and waste streams of large passenger vessels (cruise ships) . After gathering information from the cruise industry, the Task Force prepared a report to th e California legislature. Regarding hazardous waste implementation issues, the Task Force hi ghlighted the differences between stationary hazardous waste generators operating in Californi a, and cruise ships that can operate in

California but also off-load hazardous waste in ot her states or countries. The Task Force stated that it would be impossible for inspectors to track the disposal path of all onboard-generated hazardous waste without the cooperation of the cr uise line. While the Task Force did not recommend any specific additional requirements for cruise ships related to managing or tracking hazardous waste, they did suggest additional info rmation gathering. The Task Force also said that after such information gathering, it may be necessary to promulgate regulations to clarify that cruise ships operating in California are s ubject to the state hazardous waste management requirements in the same manner as other hazardous waste generators.

6.2 What federal laws apply to hazardous waste on cruise ships?

6.2.1 Clean Water Act

As noted earlier, the Clean Water Act (CWA) prohibits any person from discharging any pollutant from any point source in to waters of the United States, except in compliance with a National Pollutant Discharge Elimination System (NPDES) permit or otherwise authorized under the Act. The term “point source” is defined to include a “vessel or othe r floating craft.” Under CWA section 502(12)(b), the requ irement for an NPDES permit a pplies to the addition of any pollutant from any point source “o ther than a vessel or other floating craft” in the contiguous zone or the ocean, i.e., outside the territorial seas. Whether a discharge is authorized under an NPDES permit affects applicabil ity of RCRA; dissolved and so lid materials in industrial

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discharges which are point sources subject to NPDES permits are not “solid waste” under the

RCRA statute and thus not “hazardous waste.” Th is only applies to mate rials once they have been discharged. Prior to bei ng discharged pursuant to an NPDES permit, wastes remain subject to RCRA if they are hazardous wastes.

Section 311 of the CWA also proh ibits the discharge of oil or hazardous substances into or upon the navigable waters of the United States, adjoini ng shorelines, or into or upon the waters of the contiguous zone, or in connection with activities under the Outer Continental Shelf Lands Act or the Deepwater Port Act, or which may affect na tural resources belonging to, appertaining to, or under the exclusive management au thority of the United States in such quantities as may be harmful, as determined by the President. In Executive Order Number 11735, the President delegated to EPA the authority to determine thes e quantities. EPA has identified the quantities that may be harmful for hazardous substances in regulations at 40 CFR 117 and for oil in regulations at 40 CFR 110. Section 311(b)(5) of the CWA also requi res the person in charge of a vessel or an onshore facility or an offshore facility to, as soon as he has knowledge of any discharge of oil or a hazardous substance in violation of section 311, immediately notify the National Response Center of the discharge.

6.2.2 Resource Conservation and Recovery Act

The Resource Conservation and Recovery Act (RCRA) imposes management requirements on generators, transporters, and persons who treat or dispose of hazardous waste. Cruise ships regularly use chemicals for operations ranging fro m routine maintenance such as cleaning and painting, to passenger services such as dry cleani ng, beauty parlors, and photography labs. Thus, cruise ships or passenger servic e facilities within cruise ships may be subject to RCRA requirements. Issues the crui se ship industry may face relatin g to RCRA include ensuring the hazardous waste identification is made at the point at which a hazardous waste is considered generated; ensuring that partie s are properly identified as gene rators, storers, treaters, or disposers; and determining the applicability of RCRA requirements to these parties.

RCRA (42 U.S.C. §§ 6901 et seq.) is the federal law that, am ong other things, defines and regulates solid waste and hazardous waste. RCRA is designed to minimize the hazards of waste disposal; conserve resources th rough waste recycling, recovery, and reduction; and ensure waste management practices that are pr otective of human health and the environment. In order to achieve these goals, RCRA established a Solid Waste Program (RCRA Subtitle D) and a Hazardous Waste Program (RCRA Subtitle C). 1 Subtitle C of RCRA establishes a hazardous waste management system that controls hazardous waste from the point of generation until ultimate disposal, also referred to as a “cradle-to-grave” program. As part of this program, RCRA Subtitle C regulates hazardous waste generators . The owner or operator of a cruise ship may be a “generator” of hazar dous waste. EPA regulation ( 40 CFR 260.10 ) defines a generator

to m ean any person, by site, whose act or proces s produces hazardous waste, or whose act first causes a hazardous waste to become subject to regulation.

1 In states with hazardous waste pr ograms authorized by EPA, the auth orized state hazard ous waste program operates in lieu of the federal hazardous waste program. Some states have authorized hazardous waste programs that are more stringent than the federal hazardous waste program.

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As stated previously, the RCRA re gulations contain criteria for id entifying whether a solid waste is a hazardous waste (40 CFR 261, Subparts C and D). There are two basic ways a waste is

defined as hazardous under RCRA -- it is either a waste that appears on one of the four hazardous waste lists (i.e., F-List, K-List, P-List, or U-List), or the waste exhibits at least one of

four hazardous characteristics (ignitability, corrosivity, reactiv ity, or toxicity). EPA’s RCRA regulations at 40 CFR 262.11 require that any person who produces or generates a waste must
determine if that waste is hazardous. Once a wast e is identified as a haza rdous waste, any person who generates or manages the hazardous waste must comply with all applicable federal regulations regarding its ha ndling and management.

Hazardous waste generators are regulated base d on the amount of hazardous waste produced each month. Table 6-4 shows that generators are divided into three cate gories: large quantity generators (LQGs); small quantity generators (SQGs); and conditionally exempt small quantity generators (CESQGs). LQGs are facilities that generate greate r than or equal to 1,000 kg of hazardous waste per month, greater than 1 kg of acutely hazardous waste per month (i.e., any

waste denoted with the hazard code “H” and all P-listed wastes), or greater than 100 kg of acute spill residue or soil per month (i.e., soil, waste, or debris resulting from the cleanup of an acute hazardous waste spill). SQGs are facilities that generate between 100 kg and 1,000 kg of hazardous waste per month. CESQGs are subjec t to significantly reduced requirements for managing hazardous waste. Generators are cl assified as CESQGs if they generate  100 kg of hazardous waste per month. If the hazardous waste being generated is acutely hazardous waste (a more stringently

- regulated category of hazardous waste), then a generator is a CESQG provided they generate  1 kg of acutely hazardous waste per month. In situations where the waste being generated is residue, wa ste, or contaminated soil or debris from cleaning up a spill of acutely hazardous waste, a generator is a CESQG provided they generate  100 kg of this spill

residue.

Generator status is determined on a monthly basi s, so it is possible for a generator’s (e.g., a cruise ship) status to change from one month to the next, depending upon waste generation during that period. If a generator’s status does ch ange, the generator is re quired to comply with the applicable regulatory requirements for that class of generators for the hazardous waste generated in that particular m onth. For example, if a generato r has reached LQG status in a particular month, then bienni al reporting is required, and al l other regulatory requirements applicable to large quantity generators will apply to the waste generated in that month. Accurate counting of the waste is critical, because the regul ations are specific to eac h generator type. EPA regulations (40 CFR 261.5(c) and (d)) specify the types of haza rdous wastes that must be included in a generator's monthly count. EPA regulation (40 CFR 262.34) specifies the threshold quantities for LQGs and SQGs and in cludes limits on the amount of time hazardous waste may be accumulated on site before being sent offsite for further management (e.g., treatment, recycling, disposal, etc.). EPA re gulation (40 CFR 261.5) also specifies threshold quantities for CESQGs, as shown in Table 6-4. There is no accumulation time limit for CESQGs. According to the Congressional Resear ch Service (2007), the ge nerator classification assigned to individual cruise ship s is often unclear. However, once a cruise ship has determined its appropriate generator classification, the cruise ship must follow the appropriate accumulation requirem ents.

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Table 6-4. Classification System and Accumulation Limits

for Hazardous Waste Generators

Source: U.S. Environmental Protection Agency, 2005 Classification

of

Generator Amount of

Hazardous

Waste

Generated

Per Month Amount of Acutely

Hazardous

Waste

Generated

Per Month Amount of Acute Spill

Residue

Generated

Per Month On-site

Accumulation

Time On-site Quantity Limit

Large Quantity

Generators ≥ 1000 kg > 1 kg > 100 kg ≤ 90 days on

site No Limit

Small Quantity

Generators 100 kg < 1000 kg N/A N/A ≤ 180 days on

site or ≤ 270 days if shipped

200 miles or

more 6,000 kg

Conditionally Exempt Small Quantity

Generators ≤ 100 kg ≤ 1 kg ≤ 100 kg N/A 1,000 kg 1kg acute 100 kg residue

Any individual cruise ship that is identified as a large or small generator (i.e., LQG or SQG) is required to have a “Cruise Ship Identification Nu mber” to identify both the type and quantity of hazardous waste onboard (40 CFR 262.12); comply with the manifest system (40 CFR 262, Subpart B); handle wastes properly before ship ment (40 CFR 262, Subpart C); and comply with record-keeping and reporting requi rements (40 CFR 262, Subpart D). The identification number is used to identify a generator and to track wa ste activities, as well as to provide increased coordination between the Coast Guard, EPA, and st ates. The number remains with a vessel, and is used on all hazardous waste manifests, regard less of where the waste is off-loaded in the United States. Upon off-loading hazardous waste, the cruise ship must comply with that particular off-loading state’s RCRA requirements, whether or not that state assigned the ID

number.

The Hazardous Waste Manifest System is a set of forms, reports, and procedures designed to

track hazardous waste from the time it leaves the generator where it was produced, until it reaches the off-site waste facility that will st ore, treat, or dispose of the hazardous waste ( for

more information on the Hazardous Waste Manifest System , see http://www.epa.gov/epaoswer /hazw aste/gener/manifest/ ). The system enables waste generators to verify that their waste has been properly delivered, and that no wa ste has been lost or unaccounted for in the process (40 C FR 262, Subpart B).

EPA’s RCRA regulations (40 CFR 273) also specif y that a number of the hazardous wastes generated aboard cruise ships may be treated as Universal Wastes unde r the Universal Waste Program. The Universal Waste Program was developed under RCRA to streamline collection requirements for certain widely-generated hazard ous wastes to promote waste recycling, and to ease the regulatory burden associated with handling, transportation, and collection. Waste considered to be “widely-generated” include s batteries, pesticides, mercury-containing

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equipment, and lamps with hazardous compone nts (e.g., fluorescent, metal halide, and high pressure sodium). The Universal Waste Rule allows a facility (e.g., a cruise ship) additional time for these wastes to accumulate for recycling or disposal and thereby streamlines requirements

related to hazardous waste not ification, labeling, marking, em ployee training, responses to releases, offsite shipments, tr acking, exports, and transportation.

6.2.3 The Comprehensive Environmental Response, Compensation, and Liability Act

The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA; U.S.C. § 9601 et seq.) regulates the rele ase of “hazardous substances” of which RCRA hazardous wastes are a sub-set. CERCLA provides that any person in charge of a vessel or an offshore or an onshore facility shall, as soon as he has knowledge of any release (other than a “federally permitted release”) of a hazardous substance from such ve ssel or facility in quantities equal to or greater than those de termined pursuant to CERCLA section 9602 , immediately notify the National Response Center of such release. T he National Response Center conveys the notification expeditiously to all appropriate government agen cies. While the universe of CERCLA hazardous substances is larger th an RCRA hazardous wastes (see 40 CFR 302.4 for the complete list of CERCLA hazardous substances), all RCRA hazardous wastes are by

definition CERCLA hazardous substances. Therefore, in addition to the RCRA “cradle-tograve” requirements summarized elsewhere in this section, releases of RCRA hazardous waste in amounts above the regulatory threshold are subject to reporting as a CERCLA hazardous substance unless exempted as a federally permitted release.

6.2.4 National Marine Sanctuaries Act

The National Marine Sanctuaries Act (NMSA; 16 U.S.C. § 1431 et seq.), as amended, established a national program to designate certain areas of marine environments as areas of special national significance that warrant heightened care. The primary purpose of the law is to protect marine resources and ecosystems, such as coral reefs, sunken histor ical vessels, or unique habitats, from degradation while facilitating public or private us es compatible with resource protection.

NMSA authorizes the National Oceanic and At mospheric Administrati on (NOAA) to designate

as National Marine Sanctuaries areas of the marine environment that have special aesthetic, ecological, historical, or recreat ional qualities, and to provide comprehensive and coordinated conservation management for such areas. The National Marine Sanctuary Program manages 13

sanctuaries and the Papah ā naum oku ā kea Marine National Monument (tog ether referred to as “sites”). Designated sites are managed according to site-specific management plans developed by NOAA that typically prohibit by regulation the discharge or depos it of most material. Under NOAA’s implementing regulations for NMSA, discha rging hazardous waste is prohibited at all sites except for the Thunder Bay and the Hawaiia n Islands Humpback Whale National Marine Sanctuaries, where such discharges are pr ohibited under other legi slation or regulation.

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6.3 What practices are available to manage ha zardous wastes generated on cruise ships?

Among the previously noted Cruise Lines Inte rnational Association (CLIA) environmental standards, those applicable to hazardous wastes consist of programs for waste minimization, waste reuse and recycling, and waste stream ma nagement for incorporat ion into the Safety Management Systems (see Section 1.5). Specifi cally, a 2006 update to the CLIA environmental standards describes revised prac tices and procedures for the management of the following: photo processing wastes, including x-ray development fluid wastes; dry-clea ning waste fluids and contaminated materials; print shop waste fluids; photo copying and laser printer cartridges; unused and outdated pharmaceuticals; spent fluo rescent and mercury vapor lamp bulbs; spent batteries; and minimizing the generation and avoiding the hazardous contamination of incinerator ash (CLIA, 2006).

According to California’s Cruise Ship Environm ental Task Force (2003), the information that CLIA and individual cruise ships reported rega rding hazardous waste treatment onboard consists of the following:

 Incineration/burning of used oil, oily sl udge, medical and bio-hazardous waste, and outdated pharmaceuticals;

 Aerosol can crushing and the collection of liquids from the aerosol cans;

 Silver recovery from ph oto and x-ray processing;

 Crushing and sieving of spent fluor escent and mercury vapor bulbs; and

 Separation of oil and water mixtures.

In some cases, the cruise ship industry is in stalling new technologies and design features to minimize hazardous waste generation (ADEC, 2000):

 Effective and efficient digital photo tec hnology to reduce hazardous waste stream generation during photo processing;

 Use of non-toxic printing ink and non-chlo rinated solvents a nd other non-hazardous products to eliminate hazardous wastes in print shops; and

 Alternative dry cleaning processes such as CO 2 and wet (i.e., a water-based alternative to dry cleaning) processes.

According to the CLIA environmental standards, member lines have ag reed to reduce the production of incinerator ash by minimizing the generation of waste and maximizing recycling opportunities. CLIA further notes that incorporating waste str eam segregation practices should prevent the introduction of hazardous materials to the incinerator, thereby directing the use of onboard incinerators primarily for food waste, co ntaminated cardboard, some plastics, trash, and wood. According to the CLIA e nvironmental standards, non-hazardous ash is disposed of at sea

in accordance with MARPOL Annex V. If a ny ash is identified as being hazardous, it is disposed ashore in accordance with RCRA. The CLIA environmental standards provide for testing of incinerator as h at least once quarterly for the fi rst year of operation (in order to establish a baseline), and subse quent annual testing. (CLIA, 2006).

Cruise ships are also directing efforts to haza rdous waste collection and storage prior to offloading for disposal ashore. For hazardous materi als that cannot be re-use d and/or recycled, the

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CLIA environmental standards provide that h azardous waste is to be collected and stored onboard, then landed ashore for disposal in accordance with RCRA requirements or other applicable laws and regulations (CLIA, 2006). The GAO Report (2000 ) states that officials of some of the larger cruise ship companies re ported that hazardous waste from photo labs, dry cleaning operations, and other sour ces are collected, stored in se parate locked rooms, and offloaded in port. Based on several ship board visits accompanied by Coast Guard inspectors and/or cruise ship company officials, GAO observed locked storage areas for hazardous chemicals, reviewed procedures for handling ha zardous waste, and in some instances observed the equipment for collecting hazardous wa stes from photo processing and dry cleaning operations (U.S. General Accounting Office, 2000). Ultimately, when considering the means by which to dispose of the hazardous wastes, the local port infrastructure, availability of services providers, and the quality of di sposal facilitie s are critical.

Additional wastes stored until offloaded ashore for proper disposal are used fuel/oil filters. The Task Force reported that cruise lin es have indicated that “fuel oil from cruise ships’ bunker tanks is run through filters and mechanical separators to remove sludge and water. The used filters are supposed to be disposed of in a hazardous waste du mp.” Cruise lines further indicated that the engine lubrication system uses oil filters to scre en out particulate matter, with the treatment of

the used oil filters to be the same as that fo r the fuel filters just mentioned (Cruise Ship Environmental Task Force, 2003).

6.4 What are the potential environmental impact s associated with hazardous waste from cruise ships?

Although the quantities of hazardous waste generated on cruise ships are small, their toxicity to sensitive marine organisms can be significant (CRS, 2007). The environmental effects of a hazardous waste release would depend on the chemi cal and toxicological characteristics of the particular waste released. Although the Cruise Sh ip Environmental Task Force stated in its 2003 report that they were unaware of any studies conducted on the environmental effects from the illegal discharge of hazardous waste, it could be assumed that the environmental impacts of such a release in port areas would have a far greater impact to the envi ronment than a release far from

shore where dilution effects are more efficient (Cruise Ship Environmental Task Force, 2003). There are a number of possibl e hazardous waste streams produ ced on cruise ships, including perchloroethylene, silver, merc ury, hydrocarbons, heavy metals, a nd corrosives, that could enter the environment and cause harm if not appr opriately managed as required under RCRA.

When hazardous waste generated aboard cruise sh ips is properly identified, stored, and treated and/or disposed onshore, the risk posed to th e marine environment is normally minimized. Hazardous wastes should be properly stored and se gregated from other wastes where required by law (e.g., incompatible hazardous wastes cannot be stored together) and where necessary to ensure proper management. When considering the incineration of waste, the generation and/or discharge of incinerator ash meeting the hazardous waste characteristics can be reduced, if not prevented, through a rigorous program of waste segregation, including ed ucation, and periodic ash testing. To ensure hazardous waste is handled and disposed of properly, adequate operational procedures and employee training an d, in some instances, passenger training (e.g.,

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clear demarcation of the proper locations for the onboard discard of materials that may be hazardous) is necessary.

After three years of sampling and analysis, ADEC (2002) determined that sewage and graywater

waste streams are not used for hazardous waste disposal and that cruise ships screen for hazardous waste prior to incinera tion. If passenger and crew e ducation efforts regarding waste management and waste segregation are not effect ive, waste materials that are hazardous (or

otherwise contain hazard ous constituents) may be comingled and then incinerated with solid wastes, and in some cases, cause the resulti ng incinerator ash to be hazardous. The IMO guidelines for Annex V implementation recognize the potential for air pollu tion associated with incinerator use, and therefore disc ourage the use of incine rators in ports in or near urban areas (Annex V, Appendix B, Section 5.4). The guideli nes further recognize that some disadvantages of incinerators may include the hazardous nature of the ash or vapor, and that when in use, incinerators may not meet ai r pollution regulations imposed in certain harbors (Annex V, Appendix B, Section 5.4.5).

The incineration of plastics requi res special precautions due to the potential environmental and health effects from the combustion of by-products. In these cases, the guid elines suggest that the incineration of plastic wastes comp lying with Annex V are to take pl ace in a safe manner with an incinerator suitable for the incineration of plastics, otherwise the following problems can result:

 Depending on the type of plastic and conditions of combusti on, some toxic gases can be generated in the exhaust str eam, including vaporized hydrochlor ic and hydrocyanic acids. These and other intermediary products of plastic combustion can be extremely dangerous (Annex V, Appendix B, Section 5.4.6.1).

 The ash from the combustion of some plastic products may contain heavy metal or other

residues which can be toxic and should theref ore not be discharged into the sea (Annex V, Appendix B, Section 5.4.6.2). Further, the Parliamentary Commi ssion for the Environment (2003) stat es that a cruise ship solid waste incinerator may produce small amounts of polychlorinated biphe nyls and polycyclic aromatic hydrocarbons.

6.5 What action is the federal government ta king to address hazardous waste from cruise ships?

EPA has brought multiple enforcement actions against cruise ship operators for illegal discharges of hazardous substances and other pollutants to ensure that cruise ships comply with these requirements through environmental management systems developed as conditions of probation in criminal plea agreements.

EPA and states have worked together to de velop a system whereby an EPA hazardous waste identification (ID) number is a ssigned to every cruise ship (U.S. Environmental Protection Agency, 2001). Previously, cruise ships were receiving different numbers from a variety of states upon off-loading hazardous waste. As a result, cruise ships were receiving multiple identification numbers and creating multiple copies of hazardous waste management records. Implementation of this 2001 policy has enabled i ndividual cruise ships to be assigned a single

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EPA hazardous waste identification number for the purposes of identificati on as a generator of hazardous waste under the Resource Conservation and Recovery Act. Under the 2001 policy, the following procedures apply: a) A cruise ship determines its American-based home port state (the state in which it has corporate offices or it s main port of call). b) After determining the home port state, the cruise line notifies the selected state or corresponding EPA regional office of its hazardous waste activities. c) The cruise ship identifies its hazardous waste generator size in accordance with 40 CFR 261.5(c). d) The home port state or EPA regional offi ce issues a hazardous waste identification number for the cruise ship. The number re flects the home port state initials and ten alphanumeric characters.

After the identification number is assigned, that number remains with the ship, and is used for all hazardous waste manifests, regardless of where the waste is off-loaded in the United States. The assignment of the EPA ID number does not aff ect the applicability of state-specific RCRA requirements; cruise ships must still comply with each state’s RCRA requirements when offloading hazardous waste, regard less of which state assigned the ID number. The ship must provide records to the relevant individual off-loading state, as required by that state’s laws.

The National Park Service (NPS) manages cruise ship waste streams indirectly in Glacier Bay National Park through competitively awarded con cession contracts. The NPS has jurisdiction over the submerged lands and marine waters of Gl acier Bay National Park up to 3 miles from the mean high tide line and including all of Glacier Ba y proper. Glacier Bay is a well known, very popular attraction for the cruise ship industry in Alaska. Rece nt environmental reviews and decisions allow up to two cruise ship entries pe r day into Glacier Bay pr oper during the primary visitor season. Cruise ship operations in the park are authorized under concession contracts, which are awarded under a compet itive solicitation and prospectus process. Impact on park resources is a general standard selection criterion for park co ncessions. The NPS uses waste stream management as one of a number of selecti on criteria in this regard . In the past, cruise ship operators have usually proposed to minimi ze the impact of waste streams by committing to a no-discharge policy while in the park (even when discharge is legal unde r applicable law) for sewage, graywater, ballast water, bilge water, c ooling water, hazardous waste, and solid waste. If awarded a contract, companies must comply with their proposal. Typically cruise ships operate in the park for 8-10 hours and then depart . Cruise ships do not dock or transfer any wastes to shore while in the park.

6.6 Possible Options and Alternatives to Address Hazardous Waste from Cruise Ships

Based on the public comments receiv ed on the draft of this report as well as other information gathered, listed below are a wide range of options and alternatives that address hazardous waste from cruise ships. Identification of a ny particular option does not imply any EPA recommendation or preference for future action, or that EPA has determined that any of these options are necessary or feasible, or that EPA believes a change to the status quo is warranted, or that EPA or any other entity has the le gal authority to implement that option.

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Prevention & Reduction

 Establish standards or best management pr actices for operation, maintenance, and/or training that will decrease the contaminants in hazardous wastes and/or the volume of hazardous waste on cruise ships.

 Resolve issues that may be impeding safe wa ste storage and expanded use of incinerators.

 Foster cruise ship industry haza rdous waste minimization programs.

 Provide education and outreach to the cr uise industry regarding hazardous waste generator requirements, including requirements to:

o identify treatment activities,

o report the locations where treatment takes place, and

o obtain the appropriate hazardous waste permits or authorizations if cruise ships operate treatment units within certain state waters.

 Post waste segregation requirements, as we ll as the legal and environmental concerns, onboard cruise ships via placards and written information for employees and passengers.

 Conduct research on the effects of air quality as a result of incinerating hazardous wastes and materials aboard cruise ships.

 Conduct research to determine the presence of hazardous wastes (other than oil) entering the bilge that will eventually be discharged, given that present treatment processes target

oil.

Control: Discharge Standards

 Review provisions of state laws -- in states with cruise ship port calls -- as they pertain to

the CWA and RCRA to ascertain whether mo re stringent state provisions should be

enacted.

 Ensure that the handling and disposal of ba tteries, special chemical s, etc., are done in accordance with state solid waste regulations.

 Expand training for employees regarding wa ste segregation requirements by including the legal and environmental reasons for those requirements.

 Establish industry practice of regular standardized ash testing before sea disposal.

Control: Geographic Restrictions on Discharge

 EPA should begin a rulemaking to prohibit th e discharge of any hazardous materials or

materials with hazardous charac teristics into U.S. waters out to the 200-mile Exclusive

Economic Zone.

 Expand port reception facilities to accept hazardous waste.

 Prohibit incinerating hazardous waste while in port.

Enforcement & Compliance Assurance: Monitoring

 Establish a requirement for a full accounting of hazardous waste disposal.

 Establish a m andatory incinerator ash testing program to determine whether each batch of incinerator ash is hazardous and pr oceed with dispos al accordingly.

 Develop a means to track the pa th of all onboard generated ha zardous wastes for all states and foreign ports.

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Enforcement & Compliance Assurance: Reporting

 Include in the mandatory inci nerator ash testing program ma intenance of a certified log book documenting test results, dates, volumes, a nd ultimate disposition of ash (based on hazardous waste determination).

Enforcement & Compliance Assurance: Inspections & Enforcement

 Clarify that the cruise industry is subject to hazardous waste generator requirements and inspections by Certified Unified Program Agencies and the Department of Toxic Substances Control at ports where cruise ships take on or discharge passengers.

 Increase inspections and inspection requirement s on cruise ships that received a permit to treat hazardous waste where these permits may exist.

 Increase inspections of authorized hazardous waste facilities that receive cruise ship

hazardous wastes.

 Establish a funding mechanism based on the polluter-pays model that will provide revenues to develop and implement a comprehens ive regulatory scheme specific to cruise ships.

 Impose uniform requirements on all ships as a condition of port entry and within waters under the jurisdiction of the Unite d States consistent with international law, regardless of flag state.

 Expand Coast Guard inspections for environmental compliance to include pollution prevention equipment and practices for hazardous waste management.

 Establish a coordinated inspection program by the Department of Toxic Substances Control or Certified Unified Program Agen cies, along with Coast Guard, to enforce generator reporting to promote cruise ships’ accountability for all off-loaded hazardous wastes, to deter illegal disposal, and to iden tify if additional regulat ions are required to address offshore management of hazardous wastes.

 Prohibit or otherwise restrict noncompliant vessels (and sister ships, depending on the degree of involvement by parent companies) from operating in sens itive areas of the marine environment under U.S. jurisdiction.

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6-15 References

Alaska Department of Environmental Conservation (ADEC). 2000. Alaska Cruise Ship Initiative Part 1 Final Report . Juneau, AK. ( www.dec.state.ak.us/water/cruis e_ships/pdfs/finreportp10808.pdf )

Alaska Departm ent of Environmental Conservation (ADEC). 2002. The Impact of Cruise Ship Wastewater Discharge on Alaska Waters . Juneau, AK. ( www.dec.state.ak.us/water/cruise_ ships/pdfs/im pactofcruiseship.pdf )

Carnival Corporation & PLC. 2006. Environmental Management Report: Fiscal Year 2006

. (http://phx.corporate-ir .net/phoenix.zhtm l?c= 140690&p=irol-hess)

Congressional Research Service (CRS). 2007. Cruise Ship Pollution: Background, Laws and Regulations, and Key Issues (Order Code RL32450). Washington, DC. ( www.ncseonline.org/NLE/CRSreports/07Jul/RL32450.pdf )

Cruise Lines Internationa l Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry Waste Management Practices and Procedures . F ort Lauderdale, FL. ( www.cruising.org/industry/PDF/CLIA W asteManagementAttachment.pdf and www.cruising.org/industry/PDF/ CLIAW asteManagement.pdf )

Cruise Ship Environm ental Task Force. 2003. Report to the Legislatur e: Regulation of Large Passenger Vessels in California

. ( http://www.swrcb.ca.gov/publi cations_forms/publications/legislative/docs/2003/cruisesh iplegrpt.pdf )

Royal Caribbean Cruises Ltd. 1999. Save the Waves . Environmental Report

.

U.S. Environmental Protection Agency. 2001. Memorandum: Cruise Ship Identification Numbers and State Required Annual Reporting Components . Washington, DC. ( www.epa.gov/osw/meeting/pdf02/cruise.pdf )

U.S. Environm ental Protection Agency. 2005. Introduction to Generators (40 CFR Part 262) (EPA530-K-05-011). Washington, DC. ( http://www.epa.gov/epaoswer/hotline/training/gen05.pdf )

U.S. General Accounting Office (GAO) (now the Governm ent Accountability Office). 2000. Marine Pollution: Progress Made to Redu ce Marine Pollution by Cruise Ships, but Important Issues Remain . Report to Congressional Requesters. GAO/RCED-00-48.

### Appendix A. List of Acronyms

ACSI . . . . . . . . . . . Alaska Cruise Ship Initiative

ADEC . . . . . . . . . . . Alaska Department of Environmental Conservation

ALBD . . . . . . . . . . . Available Lower Berth Day

APPS . . . . . . . . . . . Act to Prevent Pollution from Ships

AWT . . . . . . . . . . . Advanced Wastewater Treatment

AWTs . . . . . . . . . . . Advanced Wastewater Treatment systems

BOD

. . . . . . . . . . . . biological oxygen demand

Cal/EPA . . . . . . . . . California Environmental Protection Agency

CCC . . . . . . . . . . . . criterion continuous concentration

CELB . . . . . . . . . . . Center for Environmental Leadership in Business

CERCLA . . . . . . . . Comprehensive Environmental Response, Compensation, and Liability

Act

CESQG . . . . . . . . . conditionally exempt small quantity generator

CFR . . . . . . . . . . . . Code of Federal Regulations

C.L. . . . . . . . . . . . . Confidence Limit

CLIA . . . . . . . . . . . Cruise Lines Intern ational Association

CMC

. . . . . . . . . . . criteria maximum concentration

COA . . . . . . . . . . . . Certificate of Adequacy

COTP . . . . . . . . . . . Captain of the Port

CWA . . . . . . . . . . . Clean Water Act

CRS . . . . . . . . . . Congressional Research Service

DAF . . . . . . . . . . dissolved air flotation

7-1DOC

. . . . . . . . . . Document of Compliance

EPA . . . . . . . . . . U.S. Environmental Protection Agency

EEZ . . . . . . . . . . U.S. Exclusive Economic Zone

FR . . . . . . . . . . Federal Register

gal/day/pers . . . . . gallons per day per person

GAO . . . . . . . . . . U.S. General Accounting Office (now the U.S. Government Accountability Office)

HEM . . . . . . . . . hexane extractable material

ICCL . . . . . . . . . International Council of Cruise Lines

IFO . . . . . . . . . . intermediate fuel oil

IMO . . . . . . . . . . . . International Maritime Organization

ISM . . . . . . . . . . . . International Safety Management

ISPPC . . . . . . . . . . . International Sewage Pollution Prevention Certificate

LQG . . . . . . . . . . . . large quantity generator

MARPOL . . . . . . . . . International Convention for the Prevention of Pollution from Ships (MARPOL 73/78)

MBR . . . . . . . . . . . Membrane Bioreactor

MEPC . . . . . . . . . . Marine Environment Protection Committee

MPN . . . . . . . . . . . . most probable number

MPRSA . . . . . . . . . Marine Protection, Research, and Sanctuaries Act

MSD . . . . . . . . . . . . marine sanitation device

NC . . . . . . . . . . . . . not collected

ND . . . . . . . . . . . . . not detected

NDZ . . . . . . . . . . . . no-discharge zone

7-2NH 3 . . . . . . . . . . . . unionized ammonia

NH 4 +

. . . . . . . . . . . . ionized ammonia

nm . . . . . . . . . . . . . nautical mile

NMSA . . . . . . . . . . National Marine Sanctuaries Act

NOAA . . . . . . . . . . National Oceanic and Atmospheric Administration

NOx . . . . . . . . . . . . nitrous oxide

NPS . . . . . . . . . . . . National Park Service

NPDES . . . . . . . . . . National Pollutant Discharge Elimination System

NR

. . . . . . . . . . . . . not recorded

NRC . . . . . . . . . . . . National Research Council

NRWQC . . . . . . . . . National Recommended Water Quality Criteria

OECD . . . . . . . . . . Organization for Economic Co-operation and Development

OPA . . . . . . . . . . . . Oil Pollution Act of 1990

OWS . . . . . . . . . . . . Oily Water Separator

PAH . . . . . . . . . . . . polycyclic aromatic hydrocarbon

POTWs . . . . . . . . . . publicly owned treatment works

ppm . . . . . . . . . . . . parts per million

Pub. L.

. . . . . . . Public Law

RCRA

. . . . . . . . Resource Conservation and Recovery Act

RCCL . . . . . . . . . . . Royal Caribbean Cruises Ltd.

SMS . . . . . . . . . . . . Safety Management System

SOLAS . . . . . . . . . . International Convention for the Safety of Life at Sea

SQG . . . . . . . . . . . . small quantity generator

7-3TOC

. . . . . . . . . . . . total organic carbon

U.S.

. . . . . . . . . . . . United States

USCG

. . . . . . . . . . . United States Coast Guard

UV . . . . . . . . . . . . . ultraviolet

U.S.C. . . . . . . . . . . United States Code

VGP . . . . . . . . . . . . Vessel General Permit

WHO . . . . . . . . . . . World Health Organization

7-47-5 Appendix B. State Efforts to Address Discharges from Cruise Ships

The Cruise Ship Discharge Assessment Report (Assessment Report) pres ents on-going actions by the federal government to address five primar y waste streams from cr uise ships (sewage, graywater, oily bilge water, solid waste, a nd hazardous waste). Ba sed on the public comments

received on the draft of the report, as well as other informati on gathered, a wide range of options

and alternatives is listed for each abovementioned waste stream. Identification of any particular option does not imply EPA recomm endation or preference for futu re action, or that EPA has determined that any of these options are necessary or feasible, or that EPA believes a change to the status quo is warranted, or that EPA or any other entity has the legal authority to implement that option. Nevertheless, the ra nge of options and a lternatives presented in this Assessment Report may be useful to government entities such as state, local, and tribal entities that are interested in addressing cr uise ship waste streams.

There are a number of states (Alaska, Californi a, Florida, Hawaii, Maine, and Washington), as well as Native American Tribes, that have on-goi ng efforts to address th e frequency of cruise ship traffic and the range of issues associated wi th discharges from these vessels. Some states have taken action independent of federal requirements by passing legislation controlling cruise ship discharges, creating industr y partnership programs under which cruise lines voluntarily adopt certain environmental practices, and/or establishing No Discharge Zones where the discharge of sewage from vessels (whether treate d or not) is prohibited. Listed below are some

links to access current state efforts.



### State General Information Regardi ng Cruise Ship Efforts

Connecticut http://www.ctcruiseship.com/

http://www.dep.state.f l.us/secretary/news/2000/00-MOUcruise.htm Florida http://www.dep.state.fl.us/water/wastewater/vessel.htm

http://www.co.maui.hi.us/index.asp?NID=631 http://healthuser.hawaii.gov/health/about/pr/2003/03-94epo.html Hawaii

http://www.epa.gov/owow/oceans/cruise_ships/hawaiimou.pdf

http://www.state.me.us/dep/blwq/topic/vessel/cruiseship/r ule/history.htm http://www.state.me.us/dep/blw q/topic/vessel/LCPV/index.htm Maine

http://www.barharbormaine.gov/xhtml/171/Permalink/363/

Washington http://www.ecy.wa.gov/program s/wq/wastewater/cruise_mou/index.htmlDecember 29, 2008

EPA842-R-07-005