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, 2008 
ACKNOWLEDGMENTS 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 bilge water, solid waste, and hazardous waste. For 

each waste stream, the Assessment Report discusses the nature and volume of the waste stream 

generated; existing federal regulations applicable to the waste stream; environmental 

management, including treatment, of the waste stream; potential adverse environmental impacts 

of the waste stream; on-going actions by the federal government to address the waste stream; and 

a wide range of options and alternatives 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’ legal 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.gov
TABLE OF CONTENTS

Section 1: Introduction 

1.1 Overview ....................................................................................................................1-1 

1.2 Other EPA Cruise Ship Efforts ..................................................................................1-2 

1.3 Applicable International Conventions and Related U.S. Laws and Regulations .......1-4 

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

1.5 Cruise Lines International Association’s Commitment to Reduce Potential 

 Environmental Impacts ...............................................................................................1-7 

1.6 Possible Options and Alternatives to Generally 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 associated 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 graywater from cruise ships? .........................................3-4 

3.3 Characterization of Untreated Graywater ...................................................................3-5 

3.4 What are the potential environmental impacts associated with untreated 

 graywater from cruise ships? .....................................................................................3-19 

3.5 What action is the federal government 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 bilge 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 associated with inadequately 

 treated bilge water from cruise ships? .......................................................................4-11 

4.5 What action is the federal government taking to address oily bilge water from 

 cruise ships? ...............................................................................................................4-14 
4.6 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 solid 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 associated with solid waste 

 from cruise ships? ......................................................................................................5-10 

5.5 What action is the federal government taking to address solid waste from 

 cruise ships? ...............................................................................................................5-12 

5.6 Possible Options and Alternatives to Address 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 hazardous waste on cruise 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 associated with hazardous 

 waste from cruise ships? ............................................................................................6-10 

6.5 What action is the federal government 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 .........................................................................................................................6-15 
LIST OF FIGURES, TABLES, AND APPENDICES 

Figure 2-1. Per Capita Sewage Generation 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 Traditional 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 -- Conventional Pollutants and Other 

Common Analytes ............................................................................................................2-9 

Table 2-2. Traditional Type II MSD Effluent Concentrations -- Metals ..............................2-10 

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

Semivolatile Organics .......................................................................................................2-11 

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

to Untreated Domestic Wastewater -- 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 Concentrations and Removals -- Metals .....................................2-18 

Table 2-8. AWT Effluent Concentrations and Removals -- Volatile and Semivolatile 

Organics ............................................................................................................................2-19 

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

Table 2-10. AWT Waste Biomass Concentrations for Selected Analytes ............................2-22 

Table 2-11. Comparison of AWT and Traditional Type II MSD Effluent to 

Wastewater Discharge Standards ......................................................................................2-24 

Table 2-12. National Recommended Water Quality Criteria for Bacteria ...........................2-27 

Table 2-13. Narrative National Recommended Water Quality Criteria for 

Conventional Pollutants and Other Common Analytes ....................................................2-28 

Table 2-14. Seasonal Coastal Water Temperatures in °C Across the United States ............2-30 

Table 2-15. Comparison of Traditional Type II MSD and AWT Effluent to 

Numeric National Recommended Water Quality Criteria for Total Residual 

Chlorine .............................................................................................................................2-31 

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

Quality Criteria for Metals ................................................................................................2-32 

Table 2-17. Comparison of Traditional Type II MSD Effluent to National 

Recommended Water Quality Criteria for Semivolatile and Volatile Organics ...............2-32 

Table 2-18. Comparison of AWT Effluent to National Recommended Water 

Quality Criteria for Semivolatile and Volatile Organics ..................................................2-33 

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

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

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

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

Table 2-21. Hawaii Nutrient Criteria Values Which the Geometric Mean of 

Samples Is Not to Exceed .................................................................................................2-36 
Table 3-1. Graywater Definitions ..........................................................................................3-1 

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

Figure 3-1. Per Capita Graywater Generation as Reported in EPA's 2004 Cruise 

Ship Survey .......................................................................................................................3-3 

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

2004 Cruise Ship Survey ..................................................................................................3-3 

Table 3-3. Comparison of Untreated Graywater Concentrations to Untreated 

Domestic Wastewater -- Pathogen Indicators ...................................................................3-7 

Table 3-4. Comparison of Untreated Graywater Concentrations to Untreated 

Domestic Wastewater -- Conventional Pollutants and Other Common Analytes ............3-9 

Table 3-5. Untreated Graywater Concentrations -- Metals ...................................................3-12 

Table 3-6. Untreated Graywater Concentrations -- Volatile and Semivolatile 

Organics ............................................................................................................................3-16 

Table 3-7. Comparison of Untreated Graywater Concentrations to Untreated 

Domestic Wastewater -- Nutrients ....................................................................................3-18 

Table 3-8. Comparison of Untreated Cruise Ship Graywater to Wastewater 

Discharge Standards ..........................................................................................................3-19 

Table 3-9. National Recommended Water Quality 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 Recommended Water Quality Criteria for 

Conventional Pollutants and Other Common Analytes ....................................................3-22 

Table 3-12. Seasonal Coastal Water Temperatures in °C Across the United 

States .................................................................................................................................3-24 

Table 3-13. Comparison of Untreated Cruise Ship Graywater to Numeric 

National Recommended Water Quality Criteria for Total Residual Chlorine ..................3-25 

Table 3-14. Comparison of Untreated Cruise Ship Graywater to National 

Recommended Water Quality Criteria for Metals ............................................................3-26 

Table 3-15. Comparison of Untreated Cruise Ship Graywater to National 

Recommended Water Quality Criteria for Semivolatile and Volatile Organics ...............3-27 

Table 3-16. Ammonia Concentration in Untreated Graywater .............................................3-28 

Table 3-17. Calculated Ammonia NRWQC for Some Cruise Ship Ports of 

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

Table 4-1. Maximum Daily Volume of Bilge Water Production .........................................4-3 

Table 4-2. Oily Water Separator 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 .................................5-2 
Table 5-3. Estimates of Solid Waste Generated per Person per Day on a Cruise 

Ship ...................................................................................................................................5-3 

Table 5-4. Summary of Garbage Discharge 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 Hazardous 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...................................7-5 
December 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, restaurants, and dry cleaners. As a 

result, cruise ships have the potential to generate wastes similar in volume and character to those 

generated by hotels. 

The cruise industry is one of the world’s fastest growing tourism sectors, with the number of 

cruise ship passengers growing nearly twice as fast as any other travel sector over the last 10 

years (CELB, 2003). In addition, average ship size has been increasing at the rate of roughly 90 

feet every five years over the past two decades (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 more than 8000 passengers. As the cruise industry continues to 

expand, there is an increasing concern about the impacts cruise ships may have on the marine 

environment, including water quality 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, the petition requested an in-depth assessment of the volumes and 

characteristics of cruise ship waste streams; analysis of their potential impact on water quality, 

the marine environment, and human health; examination of existing federal regulations 

governing cruise ship waste streams; and formulation of recommendations on how to better 

control and regulate these waste streams. The petition also included specific requests related to 

sewage, graywater, oily bilge water, solid wastes, and hazardous wastes, as well as monitoring, 

record-keeping, and reporting. In addition, the petition 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 subsequently denied this portion of 

the petition as unnecessary, in light of the Agency’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 bilge 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 waste 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 the future. Though this report includes discussion 

of some proprietary treatment technologies 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 this Assessment Report relates to the generation 

and treatment of sewage and graywater onboard cruise ships. Pursuant to federal legislation 

entitled “Certain Alaskan Cruise Ship Operations” (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 under 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 waste 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 Report does not present an assessment of any of 

these other waste streams. However, as part of a separate effort, on December 19, 2008, EPA 

finalized a Vessel General Permit (VGP) under section 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 shorter than 79 feet from CWA permitting for such 

discharges for a period of two years (during which 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, discharges 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 normal 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 Report, EPA has engaged in a number of activities 

addressing the potential environmental impacts of cruise ships. These efforts are summarized 

below. 

Cruise Ship White Paper, August 2000 

This White Paper provided preliminary information regarding cruise ship discharges and waste 

management practices in response to the petition 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 and other federal agencies, solicited public input 

from industry officials, government agencies, environmental groups, and concerned citizens 

through three regional public information hearings in Los Angeles, CA (September 6, 2000); 

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December 29, 2008 

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_ships/publichearings.html. 

Cruise Ship Plume Tracking Survey, Summer 2001 

EPA conducted a survey to study the dilution of discharges from cruise ships in June 2001. This 

survey tracked plumes of water containing 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 Alaska waters. The Cruise Ship Plume Tracking 

Survey Report can be accessed at: 

www.epa.gov/owow/oceans/cruise_ships/plumerpt2002/plumereport.pdf. 

The Cruise Ship Plume 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 requested 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 (RCRA). RCRA imposes management requirements 

on generators, transporters, and other handlers of hazardous waste. Cruise ships regularly use 

chemicals for operations ranging from routine maintenance to passenger services, such as dry 

cleaning, beauty parlors, and photography labs. Thus, cruise ships 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 tracking numbers by multiple states can result in a 

single ship having several different tracking numbers 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 Graywater Discharges from Cruise Ships in Alaska 

On December 12, 2000, Congress passed HR 4577, “Departments of Labor, Health and Human 

Services, and Education, and Related Agencies 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 established 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 navigable waters of the United States in the State 

of Alaska and within the Kachemak Bay National Estuarine Research Reserve. This law 

authorizes EPA to develop revised and/or additional standards for 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 graywater discharges from large cruise ships 

operating in Alaska are warranted 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 sewage generated onboard and to evaluate the 

performance of various advanced sewage and graywater treatment systems. EPA also distributed 

a “Survey Questionnaire to Determine the Effectiveness, Costs, and Impacts of Sewage and 

Graywater Treatment Devices for Large Cruise Ships Operating in Alaska” to all cruise ships 

authorized to carry 500 or more passengers for hire that operated in Alaska in 2004. The 

information collected by the survey includes general vessel information; sources of graywater 

and sewage; ship-board plumbing systems; data on the effectiveness of sewage and graywater 

treatment systems in removing pollutants; and costs of these systems. 

Using these sampling results, survey responses, and other relevant information, EPA is 

performing environmental, economic, and engineering analyses to determine whether revised or 

additional standards in Alaska are warranted under Title XIV. EPA anticipates announcing its 

determination 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. 

Additionally, as part of this effort, EPA in conjunction with the Alaska Department of 

Environmental Conservation, conducted a scientific survey in July 2008 using EPA’s Ocean 

Survey Vessel Bold to (1) measure the dilution of Advanced Wastewater 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 Analysis 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 nature of maritime commerce, many of the customs, practices, rules, 

and regulations associated with vessel operations including manning, construction, design, 

equipment, safety, and pollution prevention are developed through uniform international 

agreements and conventions. A majority of cruise 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 party. In 1948, the United Nations established the 

predecessor to the International Maritime Organization, which entered into full force in 1958, to 

promote cooperation among governments and the shipping 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 Ships, 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 framework for international objectives. However, 

these Annexes are only in force when ratified and implemented by the flag state. The vast 

majority of cruise lines operating in United States ports are foreign flag vessels. Cruise ships 

flagged under countries that are signatories to MARPOL are subject to its requirements, 

regardless of where they sail, and member nations are responsible for vessels registered under 

their respective nationalities. 

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December 29, 2008 

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 the world, and to all foreign flagged vessels while 

operating in the navigable waters of the United States or while at a port or terminal under the 

jurisdiction of the United States. Additionally, MARPOL Annex V requirements are applicable 

in the exclusive economic zone. The Coast Guard generally has the primary 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 measures to improve vessel safety including design, construction, and equipment 

standards, includes provisions for a vessel to have a pollution prevention 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 documents are developed consistent with the 

International Safety Management (ISM) Code. The functional requirements of the SMS include, 

among other things, procedures for internal audits on the operation of the SMS, as well as 

procedures and processes for management review 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)). Domestically, large passenger vessels that operate internationally are 

required to develop and retain such SMS documents 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 penalty, and if trying 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 personnel 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 vessel 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 major 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 safety, or a serious risk to the environment; it requires 

immediate corrective action. For U.S. vessels, the SMS and DOC certificates are subject to 

revocation for non-compliance (33 U.S.C. § 3205(c)). Though failure to maintain SMS 

documents onboard a vessel is subject to a civil penalty, United States Code does not provide for 

administrative, civil, or criminal penalties, or injunctive remedies, for failure to follow the SMS 

plan. Several cruise ships with robust environmental standards as part of their SMS have been 

criminally prosecuted for deliberate substantive 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 criteria and procedures for third party organizations 

to act on their behalf to perform safety management audits and certification functions that 

otherwise would be conducted by the flag state (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 classification societies) such as Det Norske Veritas, 

Lloyds Register, and the American Bureau of Shipping to certify that SMS documents conform 

with applicable requirements. If a foreign vessel (most cruise ships) has a major non-conformity 

under the ISM Code, the vessel is subject to detention and denial of port entry (33 CFR 96.380). 

1.4 Federal Environmental Enforcement History Regarding Cruise Ships

As part of a wide-ranging vessel pollution initiative begun in 1993, the U.S. Department of 

Justice, in conjunction with the Coast Guard and 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. environmental laws, including those implementing 

international treaties, as well as related criminal violations. Relevant federal environmental 

statutes include CWA, APPS, RCRA, the Ports and Waterways Safety Act, and recent legislation 

addressing Certain Alaskan Cruise Ship Operations, several of which are discussed further in this 

Assessment Report. The federal enforcement effort has resulted in numerous criminal 

convictions of every segment of the maritime industry, including the cruise ship industry, for 

knowing violations of these environmental statutes. 

All large cruise ships calling on U.S. ports are subject to the requirements of MARPOL and 

APPS, and are required to have an SMS addressing pollution prevention. However, the lack of 

enforcement of these requirements by individual cruise 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 deliberate environmental crimes, false statements, 

and obstruction of justice by the largest 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 materially 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 violations of multiple ships in a fleet. Other 

convictions have involved the deliberate discharge of pollutants without a permit within the 

navigable waters of the United States, including specifically, waste oil, plastics, sewage, and 

hazardous chemicals such as dry cleaning solvents, printing solvents, and photochemicals 

discharged through graywater systems in violation of CWA. 

In most cases, environmental violations, including cruise ships with falsified logs and use of 

equipment and procedures to bypass treatment systems, 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 companies 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 serving North America and representing 97% of 

the cruise capacity marketed from North America. CLIA reports that member companies have 

agreed to adopt voluntary CLIA environmental standards for their cruise ships. According to 

CLIA, these environmental standards exceed the requirements of U.S. and international laws 

(CLIA, 2003). CLIA reports that the standards address, among others, the following waste 

streams: graywater and blackwater (sewage) discharges; bilge and oily water residues; 

incinerator ash; hazardous chemical waste such as photo processing fluid and dry-cleaning 

chemicals; unused and outdated pharmaceuticals; used batteries; burned out fluorescent and 

mercury vapor lamps; and glass, cardboard, and aluminum and steel cans. The CLIA standards 

entitled, “Cruise Industry Waste Management Practices and Procedures,” include an attachment 

reflecting a 2006 revision (CLIA, 2006). Implementation of the CLIA membership commitment 

to address these waste streams is intended to occur via incorporation of the CLIA environmental 

protection policies into responsible persons’ SMS documents. 

CLIA has acknowledged violations of environmental laws by cruise lines, and believes that these 

violations have served as an important warning for 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 operating vessels to minimize their impact on the 

environment; 

 Developing improved technologies to exceed current 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 waste minimization procedures to significantly 

reduce shipboard-generated waste; 

 Expanding waste reduction strategies to include reuse and recycling to the maximum 

extent possible, to deposit smaller quantities of waste products ashore; 

 Improving processes and procedures for collection 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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December 29, 2008 

The CLIA environmental standards are designed to increase compliance with regulatory regimes, 

and in some cases incorporate voluntary standards and procedures 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 vessel’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 the cruise ship industry and regulated community 

to improve the environmental compliance by CLIA member lines, and hopes that the waste 

management measures undertaken by the cruise line industry will benefit the environment and 

will set an example for cruise ship operators that are not members of CLIA. 

1.6 Possible Options and Alternatives to Generally Address Cruise Ship Discharges 

Based on the public comments received 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. Identification of any 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 legal authority to implement that option. 

Research 

 Establish a detailed nationwide sampling, testing, and monitoring program to gather data 

on the volume of discharges, concentration of pollutants or effluent, and locations of 

most frequent discharges in terms of volume and/or toxicity. 

 Conduct a programmatic environmental review of the cruise industry 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 health and the effect on the nation’s coastal 

zones and marine protected areas, including analysis of cumulative impacts, from cruise 

ships. 

 Continue research and development on promising 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 geographic 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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December 29, 2008 

impacts of discharges on enclosed and low-flushing environments, 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 activities by alerting authorities. 

 Provide instruction regarding duties, responsibilities, 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 information booklets in crew cabins and crew 

lounges; and 

o regular meetings of ship safety and environmental committees consisting of 

officers and crew from all departments to review methods of improving 

performance, including better and more effective environmental practices. 

 Charge a passenger fee to put a marine engineer onboard cruise ships, especially when 

sailing in pristine waters, to observe ship 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 ship pollution control equipment, in addition 

to Coast Guard inspections. 

 Encourage a uniform national approach for environmental regulations pertaining to cruise 

ship discharges to reduce conflicting regulations 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 immediately 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 trade associations or individual cruise lines to 

further develop waste management practices and procedures to be incorporated into 

Safety Management System plans. Enhanced practice and procedures could include: 

o establishing discharge standards stricter than presently required; 

o setting voluntary standards where none exist now; and 

o regular sharing of information with the public on environmental performance. 

 Encourage cruise line trade associations to develop verification mechanisms that assure 

industry standards, practices, and procedures for pollution abatement are implemented 

faithfully, as well as specify and enforce adverse consequences for inadequate 

implementation of those standards. 

 Offer public recognition to cruise ships that implement environmentally-friendly 

practices beyond what is currently required. The voluntary program could include: 

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December 29, 2008 

o discharge standards stricter than required (for sewage, gray water, oily bilge 

water, and others); 

o setting voluntary standards where none exist now; 

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

o an agreement to prohibit the discharge of any solid waste to the marine 

environment; 

o collection and sharing of data on characteristics and volumes of discharges and 

environmental impacts; 

o independent third-party verification of implementation of waste management 

practices; and 

o a Code of Conduct or incentives program 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 cruise 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 Pollution 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 Federal Advisory Committee Act committee (perhaps 

consisting of EPA, Coast Guard, industry, public interest groups, states, and other 

appropriate shareholders) to develop improved environmental performance by cruise 

ships. 

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December 29, 2008 

 1-11 

References

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

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

Center for Environmental Leadership 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 International Association (CLIA). 2003. ICCL Media Statement on Pending 

California Legislation. ICCL News Release Archives. Arlington, Virginia. 

(http://www.cruising.org/press/press-kits/news/CLIAICCL_archivesArticle.cfm?type=a&pressID=14) 

Cruise Lines International Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry 

Waste Management Practices and Procedures. Fort Lauderdale, FL. 

(www.cruising.org/industry/PDF/CLIAWasteManagementAttachment.pdf and 

www.cruising.org/industry/PDF/CLIAWasteManagement.pdf) 

Macleod, Andrew. 2007. Cruise on down to our dumping ground. 

(http://www.straight.com/article-86446/cruise-on-down-to-our-dumping-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 discharge. Some cruise ships, especially many of those traveling to 

Alaska, have installed Advanced Wastewater Treatment systems (AWTs) to treat sewage and 

often graywater. These AWTs provide higher levels of biological treatment, solids removal, and 

disinfection as compared to traditional marine sanitation devices. 

This section discusses the current state of information about vessel 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 taken to address sewage from cruise ships. The 

conclusion of this section lists a wide range of options 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, medical sink and medical floor drain wastewater is commingled with sewage for 

treatment. 

Cruise ship sewage systems generally use fresh water to reduce corrosion, 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 comparison, the latest water-saving, high-efficiency 

domestic toilets for land-based use typically 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. Sewage 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 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). 

 2-1 
December 29, 2008 

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 equivalent to sewage generation rates. Differences 

between these two rates are attributed 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 treated) sewage varies significantly. According to 

responses to EPA’s 2004 cruise ship survey, sewage holding capacity ranges from 0.5 to 170 

hours, with an average holding 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 (CWA; 33 U.S.C. § 1322) requires that vessels with installed 

toilet facilities be equipped 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 nautical 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 the CWA is implemented jointly by EPA and the 

Coast Guard. EPA is responsible for developing performance standards for MSDs and working 

with states to establish NDZs. EPA established performance standards for MSDs in the mid 

1970s; EPA and states continue to establish NDZs on an on-going basis. The Coast Guard is 

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December 29, 2008 

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 may not adopt or enforce 

any statute or regulation of the state or a political subdivision with respect to the design, 

manufacture, installation or use of MSDs (except on houseboats), but may establish sewage 

NDZs in conjunction with EPA under certain circumstances (see below). The Coast Guard and 

states are vested with authority to enforce the requirements 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, retain, treat, or discharge sewage, and any process to treat such 

sewage. CWA section 312(a)(6) defines sewage as human body waste and the wastes from 

toilets and other receptacles intended to receive or retain body waste. There are three types of 

MSDs recognized by the Coast Guard: 

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

disinfection for treatment of the sewage. Type I devices may be used only on vessels less 

than or equal to 65 feet in length. EPA’s performance 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 treatment devices, generally employing biological 

treatment and disinfection. Some Type II MSDs 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 sewage is stored until it can be properly 

disposed of at a shore-side pumpout facility or out at sea (beyond 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 exclusively. However, a Type II MSD may be equipped 

with installed holding tanks which can be used to store treated sewage until reaching a 

pumpout facility or discharged overboard when 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 criteria (33 CFR Part 159), 

as confirmed by testing conducted at a qualified independent laboratory. After Coast Guard 

review and approval, each MSD model is designated an approval number (“certification”), 

typically valid for five years. MSDs manufactured before the certification expiration date are 

deemed to have met Coast Guard standards and may be installed on vessels; MSDs manufactured 

after the expiration date do not meet Coast Guard approval. Under Coast Guard policy, foreignflagged vessels may use MSDs that have received a compliance test certificate under Annex IV 

of MARPOL (discussed below). During routine inspections, Coast Guard inspectors examine 

the MSD to ensure its operation and condition meet all requirements of 33 CFR Part 159. The 

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December 29, 2008 

Coast Guard inspector verifies that the MSD is in good and serviceable 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 serviceable condition, the 

inspector may require that the vessel owner have the MSD effluent tested by a qualified 

wastewater laboratory, with results 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, whether 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 sewage are reasonably available. States also may 

request that EPA establish NDZs by rulemaking (1) if EPA determines that the protection and 

enhancement of the quality of the waters require such a prohibition, or (2) to prohibit the 

discharge of vessel sewage into a drinking water 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 addressing 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). Although Annex IV was adopted in 1973, it did not 

come into effect until September 2003, after ratification by the requisite number of states (and 

corresponding shipping fleet tonnage). Subsequent amendments entered 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 discharge, a provision for facilities at ports and 

terminals for the reception of sewage, and requirements for survey and certification. Annex IV 

defines sewage as drainage and other wastes from any form of toilets 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 requires ships to be equipped with either a sewage treatment 

plant, a sewage comminuting and disinfecting system, or a sewage holding tank. More 

specifically, the discharge of sewage into the sea is prohibited except when the ship has in 

operation an approved sewage treatment plant or is discharging 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 certain sewage reception facility standards and 

responsibilities for ports. Vessels that comply with Annex IV are issued an International Sewage 

Pollution Prevention Certificate (ISPPC). 

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December 29, 2008 

The United States is not a party to MARPOL Annex IV. Under existing Coast Guard policy, 

vessels registered in the United States that engage in international 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 eligible to receive a Coast Guard certificate of 

equivalency. This certificate takes the place of the ISPPC 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 Certificate 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. regulations in 33 CFR Part 159 while operating in 

waters subject to the jurisdiction of the United States. Both Coast Guard policies are currently in 

the process of being updated to reflect the recent changes to MARPOL Annex IV. In any case, 

the Coast Guard is responsible for verifying that a vessel is in substantial 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 Alaska (Departments of Labor, 

Health and Human Services, and Education, and 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 waters”). 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 operating in Alaskan waters, if appropriate. In 

developing revised or additional standards, EPA must take into account the best available 

scientific information on the environmental effects of the regulated discharges and the 

availability of new technologies for wastewater treatment, and ensure that the standards are, at a 

minimum, consistent with all relevant State of Alaska water quality standards. 

Before this law was passed, there was considerable concern about cruise ships discharging 

untreated sewage and graywater into areas within the Alexander Archipelago (a chain of islands 

in Southeast Alaska), but beyond three miles from 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 waters, 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 under six knots meet stringent standards for fecal 

coliform (geometric mean of samples taken during any 30-day period does not exceed 20 fecal 

coliform/100 ml and not more than 10% of the 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 demand, suspended solids, and pH (found at 40 CFR 

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December 29, 2008 

133.102). Title XIV requires that discharges of treated 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 fecal 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 with 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 multi-year project to determine whether revised or 

additional standards for sewage and graywater discharges from large cruise ships operating in 

Alaska are warranted under that legislation. 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 performance of various advanced 

sewage and graywater treatment systems. EPA also distributed a “Survey Questionnaire to 

Determine the Effectiveness, Costs, and Impacts of Sewage and Graywater Treatment Devices 

for Large Cruise Ships Operating in Alaska” to all cruise ships authorized to carry 500 or more 

passengers for hire that operated 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 revised or additional standards in Alaska are 

warranted. EPA anticipates announcing its determination 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 requirements for the discharge of sewage and 

graywater from large (250+ passengers) and small (50-249 passengers) passenger vessels. This 

law also addresses off-loading and/or disposal of non-hazardous solid wastes and hazardous 

wastes in Alaska. In August 2006, Alaskan voters approved a ballot measure that added new 

requirements for cruise ships. The owners/operators of large commercial passenger vessels must 

now obtain a wastewater discharge 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 historical vessels, or unique 

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habitats, from degradation while facilitating public or private uses compatible with resource 

protection.

NMSA authorizes the National Oceanic and Atmospheric Administration (NOAA) to designate 

as National Marine Sanctuaries areas of the marine environment that have special aesthetic, 

ecological, historical, or recreational qualities, and to provide comprehensive and coordinated 

conservation management for such areas. The National Marine Sanctuary Program manages 13 

sanctuaries and the Papahānaumokuākea Marine National Monument (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. 

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 habitat, such as coral. NMSA also provides for civil 

penalties for violations of its requirements 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 Section 3 for more information on graywater). 

One recent estimate by the cruise industry is that roughly 40% of the International Council of 

Cruise Lines (ICCL) members’ 130 ships (which make 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 ships 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 pollutants 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 MSDs, sewage is treated using biological treatment 

and chlorination. Some cruise ships do not treat their sewage biologically, but instead use 

maceration and chlorination. Of the nine large cruise ships with traditional Type II MSDs that 

operated in Alaskan waters in 2004, six used biological treatment and chlorination, and three 

used maceration and chlorination. 

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December 29, 2008 

Biological-chlorination MSDs operate similarly to land-based biological treatment systems for 

municipal wastewater treatment. The treatment system typically includes aerobic biological 

treatment to remove biochemical oxygen demand and some nutrients, clarification and filtration 

to remove solids, and final chlorine disinfection to destroy pathogens (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 Traditional 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 the waste. Chlorine is either 

added (sodium hypochlorite) or generated by mixing the sewage with sea water and then passing 

this solution between electrolytic 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 representative of cruise ships operating in Alaska, which have mostly 

installed AWTs, but they may be indicative of the 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 cruise 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 and 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) sampling was scheduled randomly at various ports of 

call on all major cruise routes in Alaska. Individual discharge samples characterized different 

 2-8 
December 29, 2008 

types of wastewater depending on ship-specific discharge configurations. As a result, individual 

samples characterized one or more graywater sources, treated sewage, or combined graywater 

and treated sewage. 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, and priority pollutants (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 standard 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 suspended solids and fecal coliform standards 

(ADEC, 2001). 

The Coast Guard inspected six of the cruise ships with poor effluent samples and found that five 

out of the six were either operating the MSDs improperly or failing to maintain them (ADEC, 

2000a). 

Pathogen Indicators

Based on data collected by ACSI in 2000, the average fecal coliform concentration in traditional 

Type II MSD effluent was 2,040,000 MPN/100 ml (total of 92 samples, calculation used 

detection limits for nondetected results). The range was from nondetect (detection limit of 2) to 

24,000,000 MPN/100 ml. Of the 92 samples, 51 were 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 wastewater of 10,000 to 100,000 MPN/100 ml 

(Metcalf & Eddy, 1991). Fecal coliform is the only pathogen indicator analyzed by ACSI. As 

mentioned above, these data are primarily for traditional Type II MSDs, but two of the 21 vessels 

sampled were using prototype reverse osmosis treatment systems. 

Conventional Pollutants and Other Common Analytes

Table 2-1 shows ACSI sampling results for some 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 Effluent1

Concentration in Untreated 

Domestic Wastewater2

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

 2-9 
December 29, 2008 

Chemical 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 (μg/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 analytes, of which 8 were detected in greater than 

10% of the Type II MSD effluent samples (less frequent 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 Cruise Ship Type II MSD Effluent1

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

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

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

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

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

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

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

Zinc (Total) (μg/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 semivolatile organic analytes. Of these, 16 were 

detected in at least 10% of effluent samples (less frequent detection of analytes is considered not 

representative of cruise ship effluent; analytes that were detected 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 concentrations are chlorine byproducts, likely generated by 

sewage chlorination. 

 2-10 
December 29, 2008 

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

Organics 

Analyte Average Conc. (± SE) of Cruise Ship Type II MSD Effluent1

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Toluene (μg/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 Effluent1

Concentration in Untreated 

Domestic Wastewater2

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. 

 2-11 
December 29, 2008 

2.3.2 Advanced Wastewater Treatment Systems

How it works 

On some cruise vessels, especially many of those traveling to Alaska (see subsection 2.2.3 

above), sewage and often graywater are treated using AWTs. AWTs generally provide improved 

screening, biological treatment, solids separation (using filtration or flotation), and disinfection 

(using ultraviolet light) as compared to traditional 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 biological 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 sewage. Wastewater is first treated in screen 

presses to remove paper and other 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 through tubular ultrafiltration membranes to remove particulate matter 

and biological mass, which are returned to the bioreactors. In the final stage of treatment, the 

wastewater undergoes UV disinfection to reduce pathogens. See EPA, 2006c, for more detailed 

information on this system. 

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

low concentration waste streams with different processes. One example of this system is in 

operation on the Holland America Line vessel Oosterdam. On this vessel, the ROCHEM LPRO 

part of the system treats wastewater from laundry and accommodations (low concentration waste 

streams) while the ROCHEM Bio-Filt® treats wastewater from galley and sewage, as well as the 

membrane concentrate from the ROCHEM LPRO system (high concentration waste streams). 

The ROCHEM LPRO system uses screens to remove fibers and hair, reverse osmosis 

membranes to remove particulates and dissolved solids, and UV disinfection to reduce 

pathogens. The ROCHEM Bio-Filt® system uses vibratory screens to remove coarse solids, 

bioreactors to biologically oxidize the waste, ultrafiltration membranes to remove particulate 

matter and biological mass (which are 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 biological oxidation followed by ultrafiltration 

and UV disinfection. One example of this system 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 two 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 ZeeWeed® hollow-fiber ultrafiltration membrane 

system under a vacuum. In the final stage of treatment, the combined wastewater from the 

membranes undergoes UV disinfection to reduce pathogens. The Zenon system is the only 

system that EPA sampled that treats all graywater and sewage sources. See EPA, 2006a, for 

more detailed information on this system. 

 2-12 
December 29, 2008 

The Scanship treatment system uses aerobic biological oxidation followed by dissolved air 

flotation and UV disinfection. One example of the Scanship system is in operation on the 

Norwegian Cruise Line vessel Star. 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 coarse drum filter and then through two separate 

aerated bioreactors. Each bioreactor contains free-floating plastic 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 stage 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 followed 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 biological growth without the need 

for recycled biological mass. The wastewater then enters the ACTIVEFLOATTM dissolved air 

flotation units for solids separation. Final treatment 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 the 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 evaluate the performance of the 

Zenon, Hamworthy, Scanship, and ROCHEM AWTs (see EPA, 2006 a-e). EPA also has 

evaluated cruise ship compliance 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 submitted by the cruise industry in response to 

EPA’s 2004 cruise ship survey. 

These sampling results, which are described in greater detail below, indicate that AWTs are very 

effective in removing pathogens, oxygen demanding 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 moderate nutrient removals, likely resulting from 

nutrient uptake by the microorganisms in the bioreactors. 

Data Collection

EPA Sampling: In 2004 and 2005, EPA analyzed the effluent from Zenon, Hamworthy, 

Scanship, and ROCHEM AWTs (see EPA, 2006 a-e) for over 400 analytes, including pathogen 

 2-13 
December 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 for all cruise ships that discharge 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 pollutants. This program is managed by the Alaska 

Department of Environmental Conservation (ADEC). Additionally, the federal law entitled 

“Certain Alaska Cruise Ship Operations” requires 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 discretion 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 representative 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 additional monitoring data collected in Alaska that 

was not previously provided to EPA through ADEC 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 certified for continuous discharge in Alaska 

through 2005. All four of these AWTs treat sewage and at least some graywater sources. 

Therefore, these results apply to graywater treatment as well. 

Pathogen Indicators

EPA analyzed both the influent and the effluent from AWTs (mixed graywater and sewage), as 

well as the influent to UV disinfection, for the pathogen indicators fecal coliform, enterococci, 

and E. coli. Fecal coliform were analyzed for comparison 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 gastrointestinal illnesses associated with swimming (EPA, 1984b, and EPA, 

1983). 

ADEC/Coast Guard analyzed for fecal coliform to assess compliance with the fecal coliform 

discharge standards. EPA also received some fecal coliform data in response to the survey.

Sampling data indicate that AWTs remove pathogen 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 pathogen indicators were generally removed by UV 

disinfection to levels below detection (overall system efficiency >99%). When detected, 

pathogen indicators were generally at levels close to the detection limit. 

 2-14 
December 29, 2008 

Responses to EPA’s 2004 cruise ship survey did not provide sufficient 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 potential impact of holding on AWT effluent. 

Holding treated effluent in tanks for later discharge 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 

Influent1

Average Concentration 

after bioreactors but 

before UV Disinfection1

Average Concentration 

in Cruise Ship AWT 

Effluent2

Overall 

AWT 

Percent 

Removal1

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) 

Fecal >99 

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 2004 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 Analytes

Table 2-6 presents AWT effluent sampling data for various common analytes including 

conventional pollutants (other than fecal coliform), chlorine, and temperature. Each of the three 

data sources (sampling by ADEC/Coast Guard from 2003 to 2005; sampling by EPA in 2004; 

sampling data collected through EPA’s 2004 cruise ship 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 strength: 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 total suspended solids to levels 

at or near detection. 

 2-15 
December 29, 2008 

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

Other Common Analytes 

Analyte Unit 

Average Concentration in 

Cruise Ship AWT Influent1 Average Conc. (± SE) in 

Cruise Ship AWT Effluent2 

Percent 

Removal1

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 μg/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 

 2-16 
December 29, 2008 

Average Concentration in Average Conc. (± SE) in Percent 

Analyte Unit Cruise Ship AWT Influent1 Cruise Ship AWT Effluent2 Removal1

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 because 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 analytes (total and dissolved). Survey respondents provided some 

priority pollutant metals data. 

Table 2-7 presents AWT effluent sampling data for priority pollutant metals that were detected in 

greater than 10% of influent and/or effluent samples (less frequent detection of analytes is 

considered not representative of the waste stream). Copper, nickel, and zinc, which showed the 

highest concentrations, are common components of ship piping. 

Metals are present in both particulate and dissolved forms in the influents to the treatment 

systems. Metals in the effluent are predominantly 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. 

 2-17 
December 29, 2008 

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

Analyte1 Unit 

Average Concentration in 

Cruise Ship AWT Influent2

Average Conc. (± SE) in 

Cruise Ship AWT Effluent3

Percent 

Removal2

Antimony, Total μg/l ND 2.38* (±0.219) 

(15 detects out of 71 samples) 

Antimony, Dissolved μg/l 4.0* 

(1 detect out of 25 samples) 

2.38* (±0.219) 

(11 detects out of 71 samples) 

Arsenic, Total μg/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 μg/l ND 2.28* (±0.166) 

(19 detects out of 71 samples) 

NC 

Cadmium, Total μg/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 μg/l 6.64* 

(24 detects out of 25 samples) 

4.29* (±0.992) 

(27 detects out of 71 samples) 

>44 to 95 

Chromium, Dissolved μg/l 1.51* 

(15 detects out of 25 samples) 

3.71* (±0.786) 

(28 detects out of 71 samples) 

49 to 67 

Copper, Total μg/l 519 

(25 detects out of 25 samples) 

16.6* (±2.74) 

(69 detects out of 71 samples) 

96 to 98 

Copper, Dissolved μg/l 81.5 

(25 detects out of 25 samples) 

13.7* (±2.40) 

(65 detects out of 71 samples) 

62 to 94 

Lead, Total μg/l 9.25* 

(22 detects out of 25 samples) 

1.50* (±0.135) 

(27 detects out of 71 samples) 

42 to >84 

Lead, Dissolved μg/l 2.36* 

(13 detects out of 25 samples) 

1.35* (±0.138) 

(20 detects out of 71 samples) 

NC to >30 

Mercury, Total4 μg/l 0.310* 

(21 detects out of 25 samples) 

0.165* (±0.00895) 

(10 detects out of 70 samples) 

60 to 92 

Mercury, Dissolved4 μg/l 0.120* 

(10 detects out of 25 samples) 

0.176* (±0.00941) 

(10 detects out of 68 samples) 

NC to 32 

Nickel, Total μg/l 22.4 

(25 detects out of 25 samples) 

13.6* (±2.01) 

(70 detects out of 71 samples) 

NC to 48 

Nickel, Dissolved μg/l 17.1 

(25 detects out of 25 samples) 

13.3* (±1.96) 

(69 detects out of 71 samples) 

NC to 32 

Selenium, Total μg/l 9.68* 

(13 detects out of 25 samples) 

5.86* (±1.20) 

(33 detects out of 71 samples) 

12 to 38 

Selenium, Dissolved μg/l 8.39* 

(10 detects out of 25 samples) 

6.14* (±1.48) 

(29 detects out of 71 samples) 

NC to 24 

Silver, Total μg/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 μg/l ND 1.00* (±0.0844) 

(10 detects out of 71 samples) 

NC 

Thallium, Total μg/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 μg/l 986 

(25 detects out of 25 samples) 

198* (±22.7) 

(69 detects out of 71 samples) 

NC to 86 

Zinc, Dissolved μg/l 209 

(25 detects out of 25 samples) 

185* (±21.4) 

(70 detects out of 71 samples) 

NC 

 2-18 
December 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 2004 cruise ship survey. 4

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

sampling onboard ships, there is no way for EPA to determine 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 because 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 analyte list includes 84 volatile and semivolatile 

organics and focuses primarily on priority pollutants. ADEC/Coast Guard’s volatile and 

semivolatile organic analytes include approximately 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 greater than 10% of influent and/or effluent samples (less frequent 

detection of analytes is considered not representative of the waste stream). AWTs generally 

remove volatile and semivolatile organics to below detection limits. 

Table 2-8. AWT Effluent Concentrations and Removals -- Volatile 

and Semivolatile Organics

Analyte1 Unit 

Average Concentration in 

Cruise Ship AWT Influent2

Average Conc. (± SE) in Cruise 

Ship AWT Effluent3

Percent 

Removal2

2,4-Dichlorophenol μg/l ND 8.48* (±1.08) 

(8 detects out of 71 samples) 

Bis(2-ethylhexyl) 

phthalate 

μg/l 46.1* 

(21 detects out of 25 samples) 

6.66* (±0.721) 

(2 detects out of 71 samples) 

>37 to >90 

Chloroform μg/l 10.1* 

(5 detects out of 25 samples) 

3.74* (±0.351) 

(27 detects out of 71 samples) 

NC to >67 

Diethyl phthalate μg/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 μg/l ND 8.32* (±1.07) 

(8 detects out of 71 samples) 

Phenol μg/l 75.0* 

(24 detects out of 25 samples) 

20.7* (±3.00) 

(25 detects out of 71 samples) 

25 to 45 

Tetrachloroethylene μg/l 255* 

(8 detects out of 25 samples) 

5.59* (±1.05) 

(10 detects out of 71 samples) 

>44 to 97 

Toluene μg/l 7.67* 

(5 detects out of 25 samples) 

3.44* (±0.346) 

(10 detects out of 71 samples) 

>1.4 to >17

Trichloroethene μg/l 15.1* 

(5 detects out of 25 samples) 

3.54* (±0.337) 

(1 detects out of 71 samples) 

>75 

 2-19 
December 29, 2008 

1

 Priority pollutant volatile and semivolatile organics 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 2004 cruise ship survey. 

“NC” indicates that percent removal was not calculated because 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 that some of the 2004 results for nitrogen 

compounds were anomalous. Therefore, EPA performed additional nutrient sampling in 2005 

onboard the same four cruise vessels. 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 nitrification, 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 Influent1

Average Conc. (± SE) in Cruise 

Ship AWT Effluent2

Percent 

Removal1

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 because 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 organophosphorus pesticides in AWT influent 

(pesticides were not analyzed for 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 

 2-20 
December 29, 2008 

been used to control broad-leaved weeds and annual grasses in fields, berry fruit, and vegetables. 

Simazine is classified by EPA to be slightly toxic to practically non-toxic. In the past, simazine 

has been used to control algae in swimming pools, hot tubs, and whirlpools. (Extoxnet, 1996). 

ADEC also analyzed for organophosphorus pesticides 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 generated by cruise ships, waste biomass (excess 

biological mass from the bioreactors) is generated in varying amounts by all vessels that use 

biological treatment, including traditional Type II MSDs and AWTs. Waste biomass contains 

organic material, often with high concentrations of bacteria and viruses, unless treated further. 

In biological treatment, microorganisms (e.g., bacteria) consume the biological 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 clarification 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 biological 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 accumulates 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 allow 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 daily or weekly basis. On all four ships 

sampled by EPA in 2004 and 2005, excess waste biomass 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 samples 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, concentrations in the waste biomass exceeded those 

in the influent to treatment, suggesting that these analytes accumulate 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 AWTs are highly efficient in removing particulate 

metals from the effluent and retaining them in the bioreactors. 

 2-21 
December 29, 2008 

Table 2-10. AWT Waste Biomass Concentrations for Selected Analytes 

Analyte Unit 

Average Concentration in 

Cruise Ship AWT Influent1

Average Concentration in 

Cruise Ship AWT Waste 

Biomass1

Average Concentration in 

Cruise Ship AWT 

Screening Solids1

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 μg/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 μg/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 μg/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 μg/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 μg/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 

μg/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 μg/l 75.0* 

(24 detects out of 25 samples)

628 

(2 detects out of 2 samples)

563* 

(2 detects out of 3 samples) 

Tetrachloroethylene μg/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 μg/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. 

 2-22 
December 29, 2008 

Screening Solids

Most sewage treatment systems use coarse screens 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 screening solids. One of these ships 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/day 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 are available to manage sewage from 

cruise ships? 

For ships that do not have AWTs traveling regularly on itineraries beyond territorial coastal 

waters, Cruise Lines International Association (CLIA) 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 operating 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 standards 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 environmental 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) current wastewater discharge standards for ships and land-based 

sewage treatment plants and (2) EPA’s National Recommended Water Quality Criteria. The 

mixing and dilution that occurs following discharge, which is discussed in subsection 2.4.3 

below, also is relevant to an evaluation of potential environmental 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 effluent 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 standards under “Certain Alaskan Cruise Ship 

Operations” (also referred to as “Title XIV”). 

 2-23 
December 29, 2008 

Traditional Type II MSD effluent concentrations 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 discharge 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 required 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 discharge standards presented in Table 2-11, with the exception of total 

residual chlorine. Chlorination is used to disinfect potable water produced underway or 

bunkered in port. From 2003 through 2005, many cruise vessels in Alaska converted from 

chlorine disinfection of treated sewage and graywater to UV disinfection methods during 

treatment system upgrades from traditional Type II MSDs to AWTs. The switch to UV 

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

chlorine in cruise effluent from AWTs. Based on the change in disinfection methods for AWTs, 

the likely source for occasional detection of total residual chlorine in AWT 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 μg/l and the minimum 

detection limit reported by most analytical labs of 100 μg/l. The average concentrations 

presented in Table 2-11 are calculated using the detection limit for 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 the detection limit (which is high relative to the 

standard) for nondetect samples. ADEC uses the 100 μg/l minimum detection level as the 

compliance evaluation level for total residual chlorine. Therefore, cruise ships reporting 

nondetect values with a detection limit of 100 μg/l are considered in compliance with the Title 

XIV continuous discharge standards. Based on this evaluation criterion, effluent concentrations 

from AWT seldom exceed the minimum detection level. 

Table 2-11. Comparison of AWT and Traditional Type II MSD Effluent to Wastewater 

Discharge Standards 

Analyte 

Average 

Concentration 

in AWT 

Effluent1

Average 

Concentration 

in Traditional 

Type II MSD 

Effluent2

Performance 

Standards 

for Type II 

MSDs 

(33 CFR 

Part 159 

Subpart C) 

Secondary 

Treatment 

Discharge 

Standards for 

Sewage 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 <203

Total residual 

chlorine (μg/l) 

338*^ 1,070* <10 

 2-24 
December 29, 2008 

Secondary 

Performance Treatment Title XIV 

Analyte 

Average 

Concentration 

in AWT 

Effluent1

Average 

Concentration 

in Traditional 

Type II MSD 

Effluent2

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 <454 

<305

<454 

<305

Total 

suspended 

solids (mg/l) 

4.49* 627 <150 <454 

<305

<454 

<305

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 2004 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 addition, the 30-day average percent 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 total residual chlorine was generally 100 μg/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 health (for the consumption of 

organisms only), and for pathogen indicators, compared these effluent concentrations to criteria 

for the protection of human health from incidental ingestion during recreational activities (e.g., 

swimming and surfing) and to criteria for consumption 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 

 2-25 
December 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 should be determined that the mixing zone will 

not cause lethality to passing organisms and, considering 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 whether 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 wastewater 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 ship wastewater is less than the NRWQC, the 

wastewater should not cause, have the potential to cause, or contribute 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 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 sources, but in general, greater mixing and dilution 

would be expected for mobile sources. 

Pathogen Indicators

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

hepatitis A and E, and gastro-intestinal viruses (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 waterborne illnesses (Pruss, 1998; Rees, 1993; National 

Research Council, 1993). Shellfish feed by filtering particles from the water, concentrate 

bacteria and viruses from the water column, and pose the risk of disease in consumers when 

eaten raw (National Research Council, 1993; Wu, 1999). 

The NRWQC for pathogen indicators references 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, were used for comparison with cruise ship 

discharge concentrations. 

 2-26 
December 29, 2008 

Table 2-12. 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 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 bacterial 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 traditional 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 collected 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 contribute 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 therefore should not cause, have the potential to cause, 

or contribute to non-attainment of water quality standards in a given receiving water. 

Conventional Pollutants and Other Common Analytes

Conventional pollutants and other common analytes that have a saltwater aquatic life or human 

health (for the consumption of organisms) narrative NRWQC include oil and grease, settleable 

residue, total suspended solids (see Table 2-13), and temperature (see Tables 2-13 and 2-14). In 

addition, the NRWQC include a numeric standard for total residual chlorine (see Table 2-15). 

 2-27 
December 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 oils 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 resulting from artificial sources is 1°C (1.8 °F) during all 

seasons of the year, providing the summer maxima are not exceeded; and daily temperature 

cycles characteristic of the waterbody segment should 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 impacts 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 effluent. 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 unlikely that there would be floating oils in the receiving 

water. (ADEC/Coast Guard did not provide a visual description of their samples to indicate if 

floating oils were observed.) Based on the limited amount of information available, it seems 

unlikely that AWT effluent would cause, have the potential to cause, or contribute to nonattainment of water quality standards in a given receiving water. 

 2-28 
December 29, 2008 

Settleable and Suspended Solids

Levels of solids, either settleable or suspended, in untreated or inadequately treated sewage may 

harm marine organisms by reducing water clarity 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 AWT effluent against the narrative 

NRWQC for settleable and suspended solids because the criterion is based on conditions in a 

specific waterbody. Total suspended solids were detected in traditional Type II MSD effluent at 

levels ranging from 200 to 1,480 mg/l, with an average of 627 mg/l. The detected values are 

substantially higher than the discharge standards for sewage from 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 standards in a given receiving water. 

In contrast, the majority of effluent data from AWTs were nondetect values for both settleable 

solids and total suspended solids. It is unlikely 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 reproduce effectively. Increases in temperature are frequently linked to 

acceleration in the biodegradation 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 AWT effluent against the narrative 

NRWQC for temperature because the criterion is based on conditions in a specific waterbody, 

such as flushing and the factors that influence flushing. The average temperature from AWT 

effluent measured in Alaska was 31.3 °C (temperature data were not available for traditional 

Type II MSD effluent). Local waterbody temperatures 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 given receiving water. Table 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 similar 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, considering the size of coastal waterbodies where 

cruise ships operate, it is unlikely that cruise ship effluent temperatures would cause an increase 

in waterbody temperature that would exceed the NRWQC. 

 2-29 
December 29, 2008 

Table 2-14. Seasonal Coastal Water Temperatures 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 Water Temperature Guide (www.nodc.noaa.gov/dsdt/wtg12.html) 

Total Residual Chlorine

Chlorine is extremely toxic to aquatic organisms. Chlorine concentrations as low as 3 μg/l can 

result in a high mortality rate for some species (EPA, 1984a). In fish, exposure to low levels of 

total residual chlorine (<1,000 μg/l) can cause avoidance behavior, respiratory problems, and 

hemorrhaging (Vetrano, 1998). Fish may recover once 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 shown that continuous chlorination 

can lead to a shift in the composition of phytoplankton communities, 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 would cause, have the potential to cause, or 

contribute to non-attainment of water quality standards in a given receiving water. As discussed 

in subsection 2.4.1 above, this may be less of a concern for AWTs because detection limits for 

these samples are generally higher than the NRWQC (the minimum detection limit reported by 

most analytical labs was 100 μg/l). This may artificially increase the average concentration from 

AWTs because the detection limit was used for nondetect 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 total suspended solids standards by 

killing pathogens in the wastewater.

 2-30 
December 29, 2008 

Table 2-15. Comparison of Traditional Type II MSD and AWT Effluent to Numeric 

National Recommended Water Quality Criteria for Total Residual Chlorine 

Analyte 

Average 

Concentration in 

Traditional Type 

II MSD Effluent1 

Average 

Concentration in 

AWT Effluent2

NRWQC 

Criteria 

Maximum 

Concentration 

(CMC)3

NRWQC 

Criterion 

Continuous 

Concentration 

(CCC)3

Total Residual Chlorine (μg/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 2004 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 total residual chlorine was generally 100 μg/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 concentrations 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, morphological, and behavioral patterns in aquatic organisms. One of 

the key factors in evaluating metal toxicity is the bioavailability of the metal in a waterbody. 

Some metals have a strong tendency to adsorb to suspended organic matter and clay minerals, or 

to precipitate out of solution, thus removing the metal from the water 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 sorbed to particulate matter, then it is likely not in a form that 

organisms can process. Therefore, a high concentration of a metal measured in the total form 

may not be an accurate representation of the toxic potential to aquatic organisms. Accordingly, 

NRWQC for the protection of aquatic 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 use 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 transform all forms of metals to the dissolved phase, 

thus increasing the amount of biologically available metals. 

ACSI did not report any dissolved metal data for traditional Type II MSD effluent. ACSI data 

for total metals in traditional Type II MSD effluent 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 aquatic life. Several dissolved metals that are 

common components of ship piping -- copper, nickel, and zinc -- 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 these discharge concentrations would cause, have the potential to 

cause, or contribute to non-attainment of water quality standards in a given receiving water. 

 2-31 
December 29, 2008 

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 

NRWQC1

Average 

Concentration in 

Cruise Ship AWT 

Effluent2 

NRWQC 

Criteria 

Maximum 

Concentration 

(CMC) 

NRWQC 

Criterion 

Continuous 

Concentration 

(CCC) 

Copper (Dissolved) (μg/l) 13.7* 4.8 3.1 

Nickel (Dissolved) (μg/l) 13.3* 74 8.2 

Zinc (Dissolved) (μg/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 was 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 2004 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 compounds detected in traditional Type II MSD and 

AWT effluent that exceed NRWQC. Note that effluent from traditional Type II MSDs was not 

tested for all organic compounds that have a NRWQC. The magnitude of the exceedances of 

NRWQC for the semivolatile and volatile organic compounds discussed 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 water quality standards in a given receiving water. However, as 

discussed in section 2.4.3 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 2-17. Comparison of Traditional Type II MSD Effluent to National Recommended 

Water Quality Criteria for Semivolatile and Volatile Organics 

Analytes that Exceed One or 

More NRWQC1,2

Average 

Concentration in 

Traditional Type 

II MSD Effluent3 

NRWQC 

Human Health 

(for the 

Consumption of 

Organisms) 

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

Carbon tetrachloride (μg/l) 2.0* 1.6 

Bromodichloromethane (μg/l) 34* 17 

Dibromochloromethane (μg/l) 27* 13 

Tetrachloroethylene (μg/l) 13* 3.3 

 2-32 
December 29, 2008 

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 was 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 NRWQC1

Average 

Concentration in 

Cruise Ship AWT 

Effluent2 

NRWQC 

Human Health 

(for the 

Consumption of 

Organisms) 

Tetrachloroethylene (μg/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 was 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 2004 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 chemical that is commonly added to plastics to 

make them flexible and can be found in a variety 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. Bromodichloromethane and dibromochloromethane are 

chlorine byproducts that are generated 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 and phosphorus, which are important elements for 

aquatic plant and algae growth. The influx of excess nutrients can negatively affect marine 

ecosystems, resulting in diebacks of corals and seagrasses, eutrophication (oxygen-depleted 

“dead” zones), and increases in harmful 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 (NH3) and ionized (NH4

+

) 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 NH3 that are toxic to fish can a cause a loss of equilibrium, 

 2-33 
December 29, 2008 

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 table for ammonia standards based on the pH, 

temperature, and salinity of a waterbody. Table 2-19 presents the average 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 Traditional Type II MSD and AWT Effluent 

Analyte 

Average 

Concentration in 

Traditional Type 

II MSD Effluent1 

Average 

Concentration in 

Cruise Ship 

AWT Effluent2

Ammonia (NH3-N μg/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 2004 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) 

(NH3-N μg/l)4

Ammonia NRWQC 

Criterion Continuous 

Concentration (CCC) 

(NH3-N μg/l)4

Galveston Bay1 TX 8.1 29.0 14.0 2,140 321 

Honolulu Harbor1 HI 8.0 25.5 34.4 4,110 617 

Los Angeles Harbor1 CA 8.1 17.4 32.6 7,110 1,110 

Port of Miami2 FL 8.0 25.3 32.0 4,110 617 

Monterey Harbor1 CA 8.1 15.3 32.9 6,860 1,070 

New York Harbor1 NY 7.5 22.1 22.9 11,500 2,960 

Southeast Alaska3 AK 7.8 12.5 20.0 15,600 2,340 

Portland Harbor1 ME 7.8 19.4 29.6 9,040 1,400 

1

 Data source: EPA’s EMAP National Coastal Database (http://oaspub.epa.gov/coastal/coast.search) 2

 Data source: South Florida Water Management District Monitoring Stations 

(http://glades.sfwmd.gov/pls/dbhydro_pro_plsql/water_quality_interface.main_page) 3

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

Vessel Wastewater Discharge General Permit No. 2007DB0002 

(www.dec.state.ak.us/water/cruise_ships/pdfs/PN%20Version%20LPV%20WWGP%20-%20DRAFT.pdf) 

 2-34 
December 29, 2008 

4

 Ammonia standards were calculated based on pH, temperature, 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 temperature the standard was 

approximated based on the closest value. In addition, the ammonia standards were converted from μg-NH3/l to 

μg-NH3-N/l by multiplying the standard by 0.822. 

Average effluent concentrations of ammonia from traditional Type II MSDs and AWTs exceed 

all of the waterbody ammonia standards presented 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 standard that traditional Type II MSD and AWT 

average effluent concentrations will not exceed. This suggests that 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 these discharge concentrations would cause, have the potential to 

cause, or contribute to non-attainment of water quality standards in a given receiving water. 

In addition to the ammonia standard, EPA has established criteria for the general category of 

nutrients. The NRWQC references EPA’s nutrient 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 criteria in estuarine and marine waters. In the 2001 Nutrient Criteria 

Technical Guidance Manual for Estuarine and Coastal Marine Waters, EPA states that: 

[N]utrient criteria need to be established on an individual 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 another. 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 waters, EPA recommends using a reference 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 analysis of the data are used to establish a criterion for each nutrient (e.g., total 

nitrogen and total phosphorus) to reflect the optimal nutrient condition for the waterbody in the 

absence of cultural impacts. 

Although there are no national standards for nutrient criteria in coastal waters, some states have 

established waterbody-specific or state-wide standards for nutrients based on site-specific 

evaluations. For example, Hawaii has established nutrient criteria for several different categories 

of coastal waters, such as estuaries, embayments, open coastal waters, oceanic waters, and 

specifically for Pearl Harbor. Nutrient criteria in Hawaii include limitations on total nitrogen, 

 2-35 
December 29, 2008 

ammonia, nitrate/nitrite, total phosphorus, chlorophyll, and turbidity. Hawaiian 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 natural variability in nutrient concentrations in the environment. 

Table 2-21 provides a subset of the criteria values for the different waterbody classifications in 

Hawaii. Stakeholders interested in site-specific nutrient criteria should consult their 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 (μg/l) 200 300 2001

1502

1501

1102

50 

Ammonia Nitrogen 

(μg N/l) 

6 10 61

3.52

3.51

22

1 

Nitrate + Nitrite 

 (μg N/l) 

8 15 81

52

51

3.52

1.5 

Total Phosphorus (μg 

p/l) 

25 60 251

202

201

162

10 

Chlorophyll 

 (μg/l) 

2 3.5 1.51

0.52

0.31

0.152

0.06 

Turbidity 

(NTU) 

1.5 4 1.51

0.42

0.51

0.22

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 from 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, the mixing and dilution that occurs following 

discharge also is relevant to an evaluation 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 m3

/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). 

 2-36 
December 29, 2008 

The ADEC modeled the dilution of large cruise ship effluent during stationary discharge under a 

very conservative scenario (a neap tide in Skagway Harbor), using the Visual Plumes model. 

Their modeling showed the dilution factors ranging 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 for a vessel at rest suggests that most of the 

pollutants in traditional Type II MSD effluent that were above NRWQC at the end-of-pipe would 

likely meet NRWQC after initial mixing when the vessel is at rest. However, for three pollutants 

-- fecal coliform (see Table 2-12 and discussion below), 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 these discharge concentrations would cause, have the potential to 

cause, or contribute to non-attainment of water quality standards 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, the 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 artificially increase the average concentration 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 effluent 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 potential 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. Therefore, ammonia from AWTs would likely meet most 

water quality standards after initial mixing when the vessel is at rest, based on the initial dilution 

factors discussed above. 

It is important to note that the initial mixing estimates 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 are not necessarily representative of the dilution 

factors that would be achieved by cruise ships in other ports of call in the United States. Sitespecific and ship-specific calculations would be needed to determine the dilution for ships in 

other locations. 

Dilution Underway

For vessels underway, there is significant additional dilution due to movement of the vessel and 

mixing by ship propellers. In 2001, EPA conducted dye dispersion studies behind four large 

 2-37 
December 29, 2008 

cruise ships while underway off the coast of Miami, Florida. The results of this study indicate 

that dilution of discharges behind cruise ships moving at 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, effluent from traditional Type II MSDs and AWTs would likely 

meet all NRWQC while underway. 

Using this information, the ACSI Science Advisory Panel (ADEC, 2002) determined that the 

dilution for a ship underway is a function of the speed of the cruise ship, the rate of wastewater 

discharge, the beam (i.e., width) of the cruise ship, and the draft (i.e., depth) of the cruise ship, 

according to the following equation: 

Initial Dilution Factor = 4 * (Ship Width [m] • Ship Draft [m] • Ship Speed [m/sec])

for Ships Underway Volume Discharge Rate [m3

/sec] 

For example, using a typical large cruise ship (ship width = 31 m; ship draft = 7.8 m) discharging 

from an AWT (volume discharge rate = 0.00707 m3

/sec or 25 m3/hr) and traveling at 6 knots 

(3.09 m/sec) would result in a dilution factor of 420,000. 

2.4.4 Potential Treatment Technologies in Addition to AWTs 

As part of its assessment of the 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 ships for the treatment of 

sewage or graywater. However, EPA believes these 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 technologies onboard large cruise ships would require 

engineering studies to adapt existing designs and materials selection (e.g., metallurgy, membrane 

and resin selection, loading rates, reliability, space constraints), operating parameters (e.g., 

pressures, temperatures, service and maintenance cycles), and training for operating personnel to 

ensure effective and consistent performance 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: NH4

+

 + 3/2O2  NO2

-

 + 2H+ + H2O 

Step 2: NO2

-

 + 1/2O2  NO3

- 

 2-38 
December 29, 2008 

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 BOD5) as their food source. To enhance ammonia removal in the 

combined carbon oxidation and nitrification process, 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 modifications and operational changes to enhance existing 

AWTs. Possible equipment modifications would include increased hydraulic retention time and 

additional aeration equipment to increase the amount of oxygen transferred to the activated 

sludge process. Possible operational modifications would include longer sludge retention times 

and optimized temperature, pH, and alkalinity control. 

Nitrification converts ammonia to nitrate, but does not reduce 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 through a cylindrical tank containing a weak-acid 

ion exchange resin. Ammonium ions (NH4

+

) 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 regenerated 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 generated from resin regeneration onboard would 

have to be appropriately 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 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 and install the add-on ion exchange technology and 

all necessary ancillary equipment, or rent ion exchange canisters 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 maintenance equipment costs. 

Ion exchange would remove ammonia from the wastewater, thereby reducing total nitrogen in 

the effluent. (This compares to biological nitrification, which does not reduce total nitrogen but 

instead converts one form of nitrogen to another -- relatively toxic ammonia to relatively 

nontoxic nitrate.) This cation exchange technology would not remove other forms of nitrogen, 

such as nitrogen oxyanions and nonionic organic nitrogen. However, these forms are present at 

only low concentrations in AWT effluent. The average nitrate/nitrite concentration in AWT 

 2-39 
December 29, 2008 

effluent is 3.32 mg/l, which is less than one-tenth the concentration of ammonia. 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 treatment plants by one of two methods: enhanced 

biological uptake or chemical precipitation. Since enhanced biological uptake is a complex 

process that would require significant modifications to the existing AWT, EPA instead evaluated 

chemical precipitation. Chemical precipitation of phosphorus is performed at sewage treatment 

plants by adding ferric chloride, ferrous chloride, or aluminum sulfate (alum) to the aeration 

tanks of the activated sludge plants. The precipitated iron or aluminum phosphate is removed 

with the biological sludge. One advantage of ferric or ferrous chloride over alum is that ferric or 

ferrous chloride typically achieves the same removal as alum using a lower dosage. On average, 

phosphorus precipitation at sewage treatment plants reduces total phosphorus levels to 0.8 mg/l 

in the effluent. 

Cruise ships would need to purchase 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 the resin. When the resin is fully saturated with metal ions, it 

could be regenerated onboard with an acid solution. 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 hazardous waste regulations at 40 CFR 262.11 (see 

Section 6 for further discussion). The costs and 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 and install the add-on ion exchange technology and 

all necessary ancillary equipment, or rent ion exchange canisters 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 regeneration solution costs for onboard regeneration (if applicable), 

operating labor, electrical costs, and maintenance equipment costs. 

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December 29, 2008 

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 water through a semipermeable membrane element, which would pass 

the water but reject most of the dissolved materials. This membrane separation process is 

expected to remove more than 90% of copper, nickel, zinc, and mercury from AWT effluent 

(FILMTEC, 1998). Reverse osmosis also would remove other metals and other analytes in 

cruise ship effluent, including other chlorinated solvents, phenol- and benzene-based organic 

compounds, and possibly pharmaceuticals and personal care products. 

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

total influent flow. This concentrate stream would have to be appropriately managed, including 

an assessment against the RCRA hazardous waste regulations at 40 CFR 262.11 (see Section 6 

for further discussion). The costs and potential environmental concerns associated with 

management of this waste would need to be considered as part of the assessment of this 

technology. 

Cruise ships would need to purchase and install the add-on reverse osmosis technology and all 

necessary ancillary equipment. Operating and maintenance would include operating labor, 

electricity, membrane replacement, and membrane cleaning chemicals. 

Temperature Control 

One method of reducing temperature 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 through the heat exchanger to reduce the effluent 

temperature could be provided by either the vessel’s existing chilled water system or by a 

separate chilled water system designed specifically for heat removal from the final effluent. 

Cruise ships would need to purchase 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 for 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 federal government taking to address sewage from cruise ships? 

EPA is evaluating the performance of advanced sewage and graywater treatment systems.

EPA is evaluating the performance of various advanced 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 intensive effort, including sampling four different 

AWTs and a survey questionnaire for all cruise ships operating in Alaska in 2004, are 

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December 29, 2008 

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 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. 

Coast Guard has developed regulations implementing the monitoring requirements of Title XIV.

Under Title XIV, the Coast Guard has implemented an inspection regime that includes sampling 

of cruise ship sewage and graywater discharges in Alaskan waters. In July 2001, the Coast 

Guard published a final rule (33 CFR 159.301-321) that outlines its oversight of cruise ship 

sampling in Alaskan waters. 

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

The Coast Guard has started a review of their 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 Marine Sanctuaries have proposed regulations to 

prohibit the discharge of treated and untreated sewage 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 these proposed rules. The Channel Islands National 

Marine Sanctuary has published a proposed 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 sewage from cruise ships. 

NOAA is currently reviewing the comments on this proposed rule. 

National Park Service manages cruise ship waste streams in Glacier Bay National Park.

The National Park Service (NPS) manages cruise ship waste streams indirectly in Glacier Bay 

National Park through competitively awarded concession contracts. The NPS has jurisdiction 

over the submerged lands and marine waters of Glacier Bay National Park up to 3 miles from the 

mean high tide line and including all of Glacier Bay proper. Glacier Bay is a well known, very 

popular attraction for the cruise ship industry in Alaska. Recent environmental reviews and 

decisions allow up to two cruise ship entries per day into Glacier Bay proper during the primary 

visitor season. Cruise ship operations in the park are authorized under concession contracts, 

which are awarded under a competitive solicitation and prospectus process. Impact on park 

resources is a general standard selection criterion for park concessions. The NPS uses waste 

stream management as one of a number of selection criteria in this regard. In the past, cruise 

ship operators have usually proposed to minimize 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 

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December 29, 2008 

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. 

2.6 Possible Options and Alternatives to Address Sewage from Cruise Ships 

Based on the public comments received on the draft of this report as well as other information 

gathered, listed below are a wide range of options 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 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. 

Prevention & Reduction 

 Establish standards or best management practices for operation, maintenance and/or 

training that will decrease or eliminate the contaminants and/or volume of treated sewage 

effluent, untreated sewage, and/or wastewater residuals. 

Control: Discharge Standards 

 Revise standards for the discharge of treated 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 effluent standards in MARPOL Annex IV. 

o to require the reduction attainable through application of the best available 

technology economically achievable. 

o to require technology that would eliminate remaining pollutants of concern (i.e., 

reduce to level below concern). 

o to require use of Advanced Wastewater Treatment systems. 

o to apply Title XIV standards (which apply 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 miles from shore, 12 miles from 

shore, 12 nautical miles from the 20-meter contour line). 

o no discharge in or within a certain distance (e.g., 0.5 nautical miles, 4 nautical 

miles) of sensitive areas (e.g., shellfish, ports, coral reefs, bathing beaches, water 

 2-43 
December 29, 2008 

bodies with restricted circulation, flushing or inflow, marine protected areas, 

breeding grounds, near large population centers). 

o shoreside discharge of all treated sewage effluent. 

o withhold discharge when a system upset occurs. 

o establish specific sensitive areas (e.g., Glacier Bay National Park waters) as NDZs 

for large cruise ships pursuant to CWA Section 312. 

 Restrict discharge of untreated sewage, for example, 

o no discharge out to a certain distance (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 wastewater residuals, for example, 

o no discharge out to a certain distance (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 effluent 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 sampling, 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 reporting by cruise ship operators, for example, 

o immediate notification to appropriate agencies in the event of an MSD/AWT 

malfunction or upset. 

o disclosure of implementation or non-implementation 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 agencies of all discharges of treated sewage effluent, 

untreated sewage, and wastewater residuals in U.S. waters. 

o notification of discharges in state waters 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 

 Increase penalties for failure to meet MSD standards, 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. 

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December 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 sensitive areas of the 

marine environment under U.S. jurisdiction. 

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December 29, 2008 

References

Alaska Department of Environmental Conservation (ADEC). 2000a (September 13). Alaska 

Cruise Ship Initiative Interim Report; Memorandum to Governor Tony Knowles. Juneau, 

AK. (www.dec.state.ak.us/water/cruise_ships/pdfs/interimrep.pdf) 

Alaska Department of Environmental Conservation (ADEC). 2000b. Alaska Cruise Ship 

Initiative Part 1 Final Report. Juneau, AK. 

(www.dec.state.ak.us/water/cruise_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/cruise_ships/pdfs/acsireport2.pdf) 

Alaska Department 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/impactofcruiseship.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. 

Choi, Charles. 2007 (March 25). Cruise Ships 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.html?pagewanted=print) 

Cruise Lines International Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry 

Waste Management Practices and Procedures. Fort Lauderdale, FLr. 

(www.cruising.org/industry/PDF/CLIAWasteManagementAttachment.pdf and 

www.cruising.org/industry/PDF/CLIAWasteManagement.pdf) 

Extoxnet. 1996. Pesticide Information Profiles: Simazine. Oregon State University. 

(http://extoxnet.orst.edu/pips/simazine.htm) 

FILMTEC, Dow Chemical Company. 1998 (April). FILMTEC Membranes Fact Sheet: 

Estimated Percent Rejection of Various Solutes by FILMTEC Membranes. Midland, MI. 

(http://www.h2ro.com/_FilmRemo.pdf) 

Hydroxyl Systems, Inc. 2007. Hydroxyl CleanSea® Integrated Shipboard Wastewater Treatment 

Process. Victoria, British Columbia. 

(http://www.hydroxyl.com/_pdfs/literature_cleansea.pdf) 

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December 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 Board, Commission on Engineering and Technical 

Systems. 1993. Managing Wastewater in Coastal Urban Areas. Washington, DC: 

National Academy Press. (http://www.nap.edu/catalog.php?record_id=2049#toc) 

National Research 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 epidemiological 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 chlorine on the species composition of marine 

phytoplankton. In: R.L. Jolley, et al. (Eds.), Water Chlorination: Environmental 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. Environmental 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. Environmental 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. Environmental 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. Environmental Protection Agency. 1986. Quality Criteria for Water (EPA 440/5-86-001). 

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

U.S. Environmental Protection Agency. 1989. Ambient Water Quality Criteria for Ammonia 

(Saltwater)( EPA 440/5-88-004). Washington, DC. 

(http://www.epa.gov/waterscience/pc/ambientwqc/ammoniasalt1989.pdf) 

 

 2-47 
December 29, 2008 

 2-48 

U.S. Environmental Protection Agency. 1991. Technical Support Document for Water Qualitybased Toxics Control (EPA 505-290-001). Washington, DC. 

(http://www.epa.gov/npdes/pubs/owm0264.pdf) 

U.S. Environmental 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/criteria/nutrient/guidance/marine/) 

U.S. Environmental Protection Agency. 2002. Cruise Ship Plume Tracking Survey Report

(EPA842-R-02-001). Washington, DC. 

(http://www.epa.gov/owow/oceans/cruise_ships/plumerpt2002/plumereport.pdf) 

U.S. Environmental Protection Agency. 2004. Survey Questionnaire to Determine the 

Effectiveness, Costs, and Impacts 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. Environmental Protection Agency. 2006a. Sampling Episode Report for Holland America 

Veendam (Sampling Episode 6503). Washington, DC. 

(http://www.epa.gov/owow/oceans/cruise_ships/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_ships/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/cruise_ships/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_ships/Oosterdam/OosterdamFinal.pdf) 

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 

Environmental Corporation. Windsor, CT. 

World Health Organization (WHO). 1986. Ammonia Environmental Health Criteria 54. Geneva, 

Switzerland. (http://www.inchem.org/documents/ehc/ehc/ehc54.htm) 

Wu, R.S.S. 1999. Eutrophication, Water Borne Pathogens and Xenobiotic Compounds: 

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 Treatment systems (AWTs), one or more graywater 

sources are often treated with sewage (see Section 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, the 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 graywater generated on some cruise ships, and how 

well they remove various pollutants, are discussed in Section 2. The conclusion of this section 

lists a wide range of options and alternatives that could be considered 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 for most graywater sources is potable water. Some common 

graywater sources and potential characteristics 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 spaces 
December 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: wastewater 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 floor drains and from sinks in 

restaurants and cafes; wastewater from whirlpools; and wastewater from medical facility sinks 

and medical floor drains. Some of these waste streams do not fall 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 chemicals from photographic processing equipment, solvents 

from print shop operations, as well as other chemicals, pollutants and waste 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 appears to be no relationship between per capita graywater generation 

rates and number of persons onboard (see Figure 3-2). Estimated 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 treated by the AWTs. The Alaska Cruise Ship Initiative (ADEC, 

2000) used a rule of thumb of 50 to 65 gallons of graywater generated per person per day. 

Residential graywater generation has been estimated at about 51 gallons per person per day 

(Mayer and DeOreo, 1998). 

On ships where graywater is treated, treated graywater discharge rates are nearly equivalent to 

graywater generation rates. Differences between these two rates are attributed to the volume of 

wastewater treatment sludge, if any, that is removed during wastewater 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, discharged immediately upon generation, or diverted to 

longer-term storage in one or more double bottom holding tanks for controlled discharge. 

Cruise vessel capacity to hold graywater varies significantly. According to responses to EPA’s 

2004 cruise ship survey, graywater holding capacity ranges from 5 to 90 hours, with an average 

holding capacity of 56 hours. When graywater is discharged untreated, 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 commercial 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). However, 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. from 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 installed toilet facilities be 

equipped with an operable marine sanitation device, 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 statutory 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 Section 2 (subsection 2.2.1). 

3.2.2 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 Alaska (Departments of Labor, 

Health and Human Services, and Education, and 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 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. 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, ecological, historical, or 

recreational qualities, and to provide comprehensive and coordinated conservation management 

for such areas. The National Marine Sanctuary Program manages 13 sanctuaries and the 

Papahānaumokuākea Marine National Monument (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. Discharges of 

graywater and treated vessel sewage, however, are sometimes allowed 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 requirements or the permits issued under it. 
December 29, 2008 

 3-5 

3.3 Characterization of Untreated Graywater

Except in Alaska, graywater from cruise ships currently is not required to be treated before 

discharge. For ships traveling regularly on itineraries beyond the territorial waters of coastal 

states, Cruise Lines International Association (CLIA) environmental standards provide that the 

discharge of graywater should occur only while the ship is underway 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 knots); that graywater should not be discharged 

in port and should not be discharged within four nautical miles from shore or such other distance 

as agreed to with authorities having jurisdiction or provided for by local law except in an 

emergency, or where geographically limited (CLIA, 2006). 

While some cruise ships are using AWTs to treat 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 information on untreated graywater from two sources: 

EPA’s 2004 sampling of cruise ships operating in Alaska and a voluntary sampling effort in 

2000 and 2001 by the Alaska Cruise Ship Initiative (ACSI). 

Data Collection

EPA Sampling: EPA sampled wastewater in 2004 from four 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 AWTs (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, dissolved and total metals, organics, and nutrients. 

In addition, laundry wastewater samples were analyzed for dioxins and furans, and galley 

wastewater samples were analyzed for organohalide and organophosphorus pesticides. 

Alaska Cruise Ship Initiative (ACSI) Sampling: Concerns over cruise ship 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, and 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 compliance monitoring sampling 

programs characterized different types of wastewater depending on ship-specific discharge 

configurations. The ACSI sampling results presented in this section include only those sampling 

points designated as “Mixed Graywater.” Mixed graywater samples were collected either as 

generated or following longer-term storage 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 that the strength of the graywater, in terms of 

biological oxygen demand, chemical oxygen demand and total suspended solids, is variable and 

that it can have high levels of fecal coliform bacteria (ADEC, 2001). 

Pathogen Indicators

EPA analyzed untreated graywater sources for the pathogen indicators fecal coliform, 

enterococci, and E. coli. Table 3-3 presents the graywater sampling data for the individual 

graywater sources. All three pathogen indicators were detected in all four food pulper samples 

and in the majority of galley and accommodations 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 coliform for untreated mixed graywater (see 

Table 3-3). These fecal coliform concentrations are one to three 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 sampling results for some conventional pollutants 

and other common analytes in untreated graywater, as well as typical concentrations in untreated 

domestic wastewater. Key analytes commonly used to assess wastewater strength are 

biochemical oxygen demand, chemical oxygen demand, and total suspended solids. Food pulper 

wastewater is the highest strength graywater source, with key analyte concentrations more than 

an order of magnitude greater than those in other graywater sources. The remaining graywater 

sources in order of decreasing wastewater strength are galley wastewater, accommodations 

wastewater, and laundry wastewater. Average untreated graywater strength is comparable or 

higher in strength than untreated domestic wastewater. 

Metals

EPA sampled for 54 total and dissolved metal analytes (26 of which are priority pollutants) and 

ACSI sampled for 13 priority pollutant total metal analytes in untreated graywater. Table 3-5 

presents graywater sampling data for priority pollutant metals that were detected in greater than 

10% of either the EPA or ACSI/ADEC samples (less frequent detection of analytes is considered 

not representative of the waste stream). Copper, nickel, and zinc, which showed the highest 

concentrations, are common components of ship piping. 
3-7 

Table 3-3. Comparison of Untreated Graywater Concentrations to Untreated Domestic Wastewater -- P

Analyte 

Graywater 

Source Units 

Average 

Concentration1 Range 

Number 

of Results

< 200 

Number of 

Results 

201 to 

< 100,000 

N

1

< 

Accommodations MPN/ 

100 mL 

83,500# ND(1.00) - 1,050,000 

(17 detects out of 21 samples) 6 7 

Laundry MPN/ 

100 mL 

1,930* ND(1.00) - 7,700 

(5 detects out of 21 samples) 19 2 

Galley MPN/ 

100 mL 

935,000# ND(1.00) - >24,200,000 

(21 detects out of 22 samples) 1 10 

Food Pulper MPN/ 

100 mL 

336,000** 17,300 - 2,420,000 

(4 detects out of 4 samples) 0 3 

E. Coli 

Graywater2 MPN/ 

100 mL 

292,000# 

Accommodations MPN/ 

100 mL 

532# ND(1.00) - >2,420 

(16 detects out of 21 samples) 11 10 

Laundry MPN/ 

100 mL 

253# ND(1.00) - >2,420 

(7 detects out of 21 samples) 17 4 

Galley MPN/ 

100 mL 

6,750** 95 – 51,700 

(22 detects out of 22 samples) 3 19 

Food Pulper MPN/ 

100 mL 

411,000** 10,400 – 1,600,000 

(4 detects out of 4 samples) 0 3 

Enterococci 

Graywater2 MPN/ 

100 mL 

8,920# 

Accommodations CFU/ 

100 mL 

36,700,000# 1,500 - 120,000,000 

(18 detects out of 19 samples) 0 7 

Laundry CFU/ 

100 mL 

7,940# ND(2.00) - >60,000 

(11 detects out of 19 samples) 11 8 

Galley CFU/ 

100 mL 

29,100,000** 1,900 - 910,000,000 

(19 detects out of 19 samples) 0 4 

Food Pulper CFU/ 

100 mL 

87,400 29,000 - 170,000 

(4 detects out of 4 samples) 0 2 

Graywater2 CFU/ 

100 mL 

36,000,000# 

Fecal Coliform 

Graywater (ASCI / ADEC Data)

MPN/ 100 mL 

2,950,000#3 ND(2.00) – 32,000,000 

(134 detects out of 156 samples) 36 29 

1 Based on data collected by EPA in 2004 unless otherwise noted. 
3-8 

2 EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater.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. ** Average includes at least one result flagged by the laboratory as not diluted sufficiently; therefore, this average represents a minimu

# Average includes at least one nondetect value (calculation uses detection limits for nondetected results) and at least one result flagged 

diluted sufficiently. 

The “>” symbol indicates that the laboratory flagged the sample as not diluted sufficiently; therefore, this represents a minimum value 
3-9 

Table 3-4. Comparison of Untreated Graywater Concentraions to Untreated Domestic Wastewater -- Conven

Other Common Analytes 

Analyte Unit 

Average 

Concentration 

in Untreated 

Cruise Ship 

Accommodations 

Wastewater 

(EPA Data) 1 

Average 

Concentration 

in Untreated 

Cruise Ship 

Laundry 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Galley 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Food Pulper 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Graywater 

(EPA Data)2

Av

Conce

in Un

Crui

Gra

(ACS

D

Alkalinity mg/l 48.1* 

(11 detects out of 

12 samples) 

71.6 

(12 detects out of 

12 samples) 

57.7* 

(9 detects out of 

12 samples) 

ND(57.5) 

(0 detects out of 4 

samples) 

53.8* 

(32 detects out of 

40 samples) 

5

(4 detec

sam

Biochemical Oxygen Demand (5-Day) 

mg/l 260 

(11 detects out of 

11 samples) 

83.8 

(11 detects out of 

11 samples) 

1,490 

(11 detects out of 

11 samples) 

30,500 

(4 detects out of 4 

samples) 

1,140 

(37 detects out of 

37 samples) 

3

(42 det

42 sa

Chemical Oxygen Demand 

mg/l 723 

(12 detects out of 

12 samples) 

257 

(12 detects out of 

12 samples) 

1,830 

(12 detects out of 

12 samples) 

26,400 

(4 detects out of 4 

samples) 

1,890 

(40 detects out of 

40 samples) 

1

(41 det

41 sa

Chloride mg/l 66.6 

(12 detects out of 

12 samples) 

22.4 

(12 detects out of 

12 samples) 

145 

(12 detects out of 

12 samples) 

1,240 

(4 detects out of 4 

samples) 

125 

(40 detects out of 

40 samples) 

N

Conductivity μS/cm 236 

(43 detects out of 

43 samples) 

74.4 

(43 detects out of 

43 samples) 

647 

(48 detects out of 

48 samples) 

4,060 

(7 detects out of 7 

samples) 

427 

(141 detects out of 

141 samples) 

2

(21 det

21 sa

Free Residual Chlorine μg/l NR NR NR NR NR 0.

(6 dete

43 sa

Hardness mg/l 38.2 

(12 detects out of 

12 samples) 

14.1 

(12 detects out of 

12 samples) 

65.1 

(12 detects out of 

12 samples) 

449 

(3 detects out of 3 

samples) 

54.5 

(39 detects out of 

39 samples) 

N

Hexane Extractable Material 

mg/l 37.6 

(12 detects out of 

12 samples) 

13.4 

(11 detects out of 

11 samples) 

172 

(12 detects out of 

12 samples) 

1,960 

(3 detects out of 3 

samples) 

149 

(38 detects out of 

38 samples) 

7

Oil an

(4 detec

sam

pH 83.3% of pH 

samples are 

between 

6.0 and 9.0 

(35 of 42 samples)

81.8% of pH 

samples are 

between 

6.0 and 9.0 

(36 of 44 samples)

50.0% of pH 

samples are 

between 

6.0 and 9.0 

(24 of 48 samples)

0% of the pH 

samples are 

between 

6.0 and 9.0 

(0 of 8 samples) 

66.9% of pH 

samples are 

between 

6.0 and 9.0 

(95 of 142 samples)

76.7% 

samp

bet

6.0 a

(33 o
3-10 

Analyte Unit 

Average 

Concentration 

in Untreated 

Cruise Ship 

Accommodations 

Wastewater 

(EPA Data) 1 

Average 

Concentration 

in Untreated 

Cruise Ship 

Laundry 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Galley 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Food Pulper 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Graywater 

(EPA Data)2

Av

Conce

in Un

Crui

Gra

(ACS

D

sam

Salinity ppt 1.72* 

(42 detects out of 

43 samples) 

1.26 

 (43 detects out of 

43 samples) 

2.56 

(48 detects out of 

48 samples) 

6.05 

(7 detects out of 7 

samples) 

2.08* 

(140 detects out of 

141 samples) 

N

Settable Residue mg/l 4.43* 

(7 detects out of 

11 samples) 

0.432* 

(3 detects out of 

11 samples) 

18.7 

(11 detects out of 

11 samples) 

728 

(4 detects out of 4 

samples) 

25.6* 

(25 detects out of 

37 samples) 

1

(2 detec

sam

Silica Gel Treated Hexane Extractable Material 

mg/l ND(5.89) 

(0 detects out of 

12 samples) 

ND(5.37) 

(0 detects out of 

11 samples) 

8.39* 

(2 detects out of 

12 samples) 

821* 

(2 detects out of 3 

samples) 

36.6* 

(4 detects out of 38 

samples) 

N

Sulfate mg/l 41.5 

(12 detects out of 

12 samples) 

16.3 

(12 detects out of 

12 samples) 

61.0 

(12 detects out of 

12 samples) 

194 

(4 detects out of 4 

samples) 

49.9 

(40 detects out of 

40 samples) 

N

Temperature °C 34.7 

(42 detects out of 

42 samples) 

48.6 

(44 detects out of 

44 samples) 

41.9 

(48 detects out of 

48 samples) 

66.5 

(8 detects out of 8 

samples) 

39.6 

(142 detects out of 

142 samples) 

N

Total Dissolved Solids mg/l 244 

(12 detects out of 

12 samples) 

191 

(12 detects out of 

12 samples) 

897 

(12 detects out of 

12 samples) 

5,160 

(3 detects out of 3 

samples) 

578 

(39 detects out of 

39 samples) 

N

Total Organic Carbon mg/l 78.9 

(12 detects out of 

12 samples) 

60.2 

(12 detects out of 

12 samples) 

358 

(12 detects out of 

12 samples) 

21,300 

(4 detects out of 4 

samples) 

535 

(40 detects out of 

40 samples) 

4

(4 detec

sam

Total Residual Chlorine mg/l NR NR NR NR NR 0.

(9 dete

43 sa

Total Suspended Solids mg/l 207 

(12 detects out of 

12 samples) 

37.1 

(12 detects out of 

12 samples) 

877 

(12 detects out of 

12 samples) 

16,500 

(3 detects out of 3 

samples) 

704 

(39 detects out of 

39 samples) 

3

(43 det

43 sa

Turbidity NTU 186 

(43 detects out of 

43 samples) 

20.9 

(41 detects out of 

41 samples) 

408 

(33 detects out of 

33 samples) 

NC 224 

(117 detects out of 

117 samples) 

1 Based on data collected by EPA in 2004. 2 EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater.
3-11 

3 Based on data collected by ACSI/ADEC in 2000 and 2001. 4 Metcalf & Eddy, 1991. 

* Average includes at least one nondetect value; this calculation 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 

is subject to interferences; accordingly, field measurements collected for the sole purpose determining sample preservation requireme
3-12 

Table 3-5. Untreated Graywater Concentrations -- Metals 

Analyte Unit 

Average 

Concentration 

in Untreated 

Cruise Ship 

Accommodations 

Wastewater 

(EPA Data) 1 

Average 

Concentration 

in Untreated 

Cruise Ship 

Laundry 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Galley 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Food Pulper 

Wastewater 

(EPA Data) 1

Average 

Concentratio

in Untreated 

Cruise Ship 

Graywater 

(EPA Data)2

Antimony, Total μg/l ND(3.99) 

(0 detects out of 12 

samples) 

ND(3.99) 

(0 detects out of 12 

samples) 

ND(3.99) 

(0 detects out of 12 

samples) 

6.67* 

(3 detects out of 4 

samples) 

4.09* 

(3 detects out of 

samples) 

Arsenic, Total μg/l ND(2.16) 

(0 detects out of 12 

samples) 

ND(2.16) 

(0 detects out of 12 

samples) 

2.44* 

(3 detects out of 12 

samples) 

5.85* 

(1 detect out of 4 

samples) 

2.25* 

(4 detects out of 

samples) 

Beryllium, Total μg/l 0.0688* 

(1 detect out of 12 

samples) 

ND(0.0620) 

(0 detects out of 12 

samples) 

0.116* 

(2 detects out of 12 

samples) 

ND(0.0448) 

(0 detects out of 4 

samples) 

0.0736* 

(3 detects out of 

samples) 

Cadmium, Total μg/l 0.463* 

(1 detect out of 12 

samples) 

0.270* 

(1 detects out of 12 

samples) 

0.391* 

(6 detects out of 12 

samples) 

1.29 

(4 detects out of 4 

samples) 

0.452* 

(12 detects out o

samples) 

Chromium, Total μg/l 22.4* 

(11 detects out of 12 

samples) 

2.25* 

(10 detects out of 12 

samples) 

7.03* 

(10 detects out of 12 

samples) 

16.7 

(4 detects out of 4 

samples) 

16.7* 

(35 detects out o

samples) 

Chromium, Dissolved μg/l 1.49* 

(9 detects out of 12 

samples) 

1.38* 

(6 detects out of 12 

samples) 

2.04* 

(10 detects out of 12 

samples) 

5.16 

(3 detects out of 3 

samples) 

1.70* 

(28 detects out o

samples) 

Copper, Total μg/l 677 

(12 detects out of 12 

samples) 

278 

(12 detects out of 12 

samples) 

383 

(12 detects out of 12 

samples) 

208 

(4 detects out of 4 

samples) 

510 

(40 detects out o

samples) 

Copper, Dissolved μg/l 167 

(12 detects out of 12 

samples) 

253 

(12 detects out of 12 

samples) 

232 

(12 detects out of 12 

samples) 

15.3 

(3 detects out of 3 

samples) 

195 

(39 detects out o

samples) 

Lead, Total μg/l 14.8* 

(9 detects out of 12 

samples) 

5.77* 

(9 detects out of 12 

samples) 

21.2* 

(10 detects out of 12 

samples) 

14.1* 

(3 detects out of 4 

samples) 

12.3* 

(31 detects out o

samples) 

Lead, Dissolved μg/l 2.48* 

(5 detects out of 12 

samples) 

3.76* 

(8 detects out of 12 

samples) 

10.2* 

(7 detects out of 12 

samples) 

2.87* 

(1 detects out of 3 

samples) 

4.25* 

(21 detects out o

samples) 
3-13 

Analyte Unit 

Average 

Concentration 

in Untreated 

Cruise Ship 

Accommodations 

Wastewater 

(EPA Data) 1 

Average 

Concentration 

in Untreated 

Cruise Ship 

Laundry 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Galley 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Food Pulper 

Wastewater 

(EPA Data) 1

Average 

Concentratio

in Untreated 

Cruise Ship 

Graywater 

(EPA Data)2

Mercury, Total4 μg/l 0.153* 

(8 detects out of 12 

samples) 

0.0518* 

(7 detects out of 12 

samples) 

0.0703* 

(6 detects out of 12 

samples) 

0.197* 

(2 detects out of 4 

samples) 

0.100* 

(23 detects out o

samples) 

Mercury, Dissolved4 μg/l 0.155* 

(5 detects out of 12 

samples) 

0.0895* 

(6 detects out of 12 

samples) 

0.108* 

(6 detects out of 12 

samples) 

0.143* 

(2 detects out of 3 

samples) 

0.122* 

(19 detects out o

samples) 

Nickel, Total μg/l 34.0 

(12 detects out of 12 

samples) 

6.19 

(12 detects out of 12 

samples) 

29.2 

(12 detects out of 12 

samples) 

22.4 

(4 detects out of 4 

samples) 

29.7 

(40 detects out o

samples) 

Nickel, Dissolved μg/l 17.2 

(12 detects out of 12 

samples) 

4.85 

(12 detects out of 12 

samples) 

26.4 

(12 detects out of 12 

samples) 

31.1 

(3 detects out of 3 

samples) 

18.2 

(39 detects out o

samples) 

Selenium, Total μg/l 1.07* 

(4 detects out of 12 

samples) 

1.26* 

(3 detects out of 12 

samples) 

4.93* 

(9 detects out of 12 

samples) 

26.9 

(4 detects out of 4 

samples) 

3.37* 

(20 detects out o

samples) 

Selenium, Dissolved μg/l 1.05* 

(4 detects out of 12 

samples) 

1.02* 

(4 detects out of 12 

samples) 

4.74* 

(7 detects out of 12 

samples) 

22.1 

(3 detects out of 3 

samples) 

3.04* 

(18 detects out o

samples) 

Silver, Total μg/l 2.07* 

(1 detect out of 12 

samples) 

1.73* 

(6 detects out of 12 

samples) 

1.13* 

(4 detects out of 12 

samples) 

1.04* 

(1 detect out of 4 

samples) 

1.82* 

(12 detects out o

samples) 

Thallium, Total μg/l 1.13* 

(1 detects out of 12 

samples) 

ND(0.765) 

(0 detects out of 12 

samples) 

0.405* 

(2 detects out of 12 

samples) 

0.550* 

(3 detects out of 4 

samples) 

0.930* 

(6 detects out of 

samples) 

Thallium, Dissolved μg/l ND(0.405) 

(0 detects out of 12 

samples) 

0.407* 

(1 detects out of 12 

samples) 

0.405* 

(4 detects out of 12 

samples) 

0.296* 

(1 detects out of 3 

samples) 

0.403* 

(6 detects out of 

samples) 

Zinc, Total μg/l 3,130 

(12 detects out of 12 

samples) 

345 

(12 detects out of 12 

samples) 

1,460 

(12 detects out of 12 

samples) 

6,380 

(4 detects out of 4 

samples) 

2,540 

(40 detects out o

samples) 

Zinc, Dissolved μg/l 792 

(12 detects out of 12 

samples) 

266 

(12 detects out of 12 

samples) 

1,070 

(12 detects out of 12 

samples) 

47,800 

(3 detects out of 3 

samples) 

1,610 

(39 detects out o

samples) 
3-14 

1 Based on data collected by EPA in 2004. 2 EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater. 3 Based on data collected by ACSI/ADEC in 2000 and 2001. 4 Because it was not possible to incorporate “clean” sampling and analysis methodologies for mercury when sampling onboard ships, th

determine whether mercury reported here is present in the graywater or if the mercury was the result of contamination from nearby m

contamination. 

* Average includes at least one nondetect value; this calculation 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 contained the highest average concentration of 10 of the 21 metal 

analytes listed in Table 3-5. Six metal analytes were detected in accommodations wastewater at 

the highest average concentration. Galley and laundry wastewater contained the highest average 

concentration of only three and two metal analytes, respectively. 

Total and dissolved copper, total and dissolved nickel, and total and dissolved zinc were detected 

in all EPA graywater samples. These six metal analytes also were detected at the highest 

average concentrations among the priority metal analytes. Total copper, total nickel, and total 

zinc were also the priority pollutant metal analytes detected at the highest average concentrations 

in ACSI/ADEC graywater samples. 

Volatile and Semivolatile Organics

EPA tested for 84 volatile and semivolatile organics, of which approximately 85% are priority 

pollutants. ACSI/ADEC sampled for almost 140 priority pollutant and non priority pollutant 

volatile and semivolatile organic analytes. Table 3-6 presents untreated graywater sampling data 

for priority pollutant volatile and semivolatile organics 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 plasticizers (phthalates), chlorine byproducts (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 Kjeldahl nitrogen, and total phosphorus concentrations 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 ammonia is indicative of human waste). 
3-16 

Table 3-6. Untreated Graywater Concentrations -- Volatile and Semivolatile Organics 

Analyte Unit 

Average 

Concentration 

in Untreated 

Cruise Ship 

Accommodations 

Wastewater 

(EPA Data) 1 

Average 

Concentration 

in Untreated 

Cruise Ship 

Laundry 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Galley 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Food Pulper 

Wastewater 

(EPA Data) 1

Average 

Concentrati

in Untreate

Cruise Ship 

Graywater 

(EPA Data)

1,2-Dichloroethane μg/l ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

ND(7.37) 

(0 detects out o

samples) 

2,4-Dichlorophenol μg/l ND(11.2) 

(0 detects out of 12 

samples) 

ND(10.1) 

(0 detects out of 12 

samples) 

ND(10.4) 

(0 detects out of 12 

samples) 

ND(80.2) 

(0 detects out of 4 

samples) 

ND(11.9) 

(0 detects out o

samples) 

Bis(2-ethylhexyl) phthalate μg/l 25.3* 

(11 detects out of 

12 samples) 

56.3 

(12 detects out of 

12 samples) 

155* 

(11 detects out of 

12 samples) 

526* 

(2 detects out of 4 

samples) 

71.9* 

(36 detects out 

samples) 

Bromodichloromethane μg/l ND(7.50) 

(0 detects out of 12 

samples) 

7.50* 

(1 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

7.37* 

(1 detects out o

samples) 

Bromoform μg/l ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

ND(7.37) 

(0 detects out o

samples) 

Butyl benzyl phthalate μg/l ND(10.3) 

(0 detects out of 12 

samples) 

ND(10.0) 

(0 detects out of 12 

samples) 

ND(10.0) 

(0 detects out of 12 

samples) 

ND(80.2) 

(0 detects out of 4 

samples) 

ND(11.4) 

(0 detects out o

samples) 

Chloroform μg/l 7.53* 

(1 detect out of 12 

samples) 

48.6* 

(11 detects out of 

12 samples) 

7.99* 

(4 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

13.5* 

(16 detects out 

samples) 

Dibromochloromethane μg/l ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

ND(7.37) 

(0 detects out o

samples) 

Diethyl phthalate μg/l 14.1* 

(5 detects out of 12 

samples) 

10.6* 

(3 detects out of 12 

samples) 

11.1* 

(1 detect out of 

12 samples) 

ND(80.2) 

(0 detects out of 4 

samples) 

14.1* 

(9 detects out o

samples) 

Di-n-butyl phthalate μg/l ND(10.3) 

(0 detects out of 12 

samples) 

ND(10.0) 

(0 detects out of 12 

samples) 

ND(10.0) 

(0 detects out of 12 

samples) 

ND(80.2) 

(0 detects out of 4 

samples) 

ND(11.4) 

(0 detects out o

samples) 
3-17 

Analyte Unit 

Average 

Concentration 

in Untreated 

Cruise Ship 

Accommodations 

Wastewater 

(EPA Data) 1 

Average 

Concentration 

in Untreated 

Cruise Ship 

Laundry 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Galley 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Food Pulper 

Wastewater 

(EPA Data) 1

Average 

Concentrati

in Untreate

Cruise Ship 

Graywater 

(EPA Data)

Di-n-octyl phthalate μg/l ND(10.3) 

(0 detects out of 12 

samples) 

ND(10.0) 

(0 detects out of 12 

samples) 

ND(10.0) 

(0 detects out of 12 

samples) 

ND(80.2) 

(0 detects out of 4 

samples) 

ND(11.4) 

(0 detects out o

samples) 

Ethylbenzene μg/l ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

ND(7.37) 

(0 detects out o

samples) 

Methylene chloride μg/l ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

ND(7.37) 

(0 detects out o

samples) 

Phenol μg/l 46.2* 

(9 detects out of 12 

samples) 

55.3* 

(11 detects out of 

12 samples) 

58.3 

(12 detects out of 

12 samples) 

93.8* 

(2 detects out of 4 

samples) 

52.5* 

(34 detects out 

samples) 

Tetrachloroethylene μg/l 18.1* 

(1 detect out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

11.4* 

(1 detect out o

samples) 

Toluene μg/l 28.0* 

(1 detects out of 12 

samples) 

ND(7.50) 

(0 detects out of 12 

sample) 

9.70* 

(5 detects out of 12 

samples) 

ND(5.24) 

(0 detects out of 4 

samples) 

21.3* 

(6 detects out o

samples) 

Trichloroethene μg/l 10.2* 

(1 detect out of 12 

sample) 

ND(7.50) 

(0 detects out of 12 

sample) 

ND(7.50) 

(0 detects out of 12 

sample) 

ND(5.24) 

(0 detects out of 4 

sample) 

8.40* 

(1 detect out o

samples) 

1 Based on data collected by EPA in 2004. 2 EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater. 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. “ND” indicates that the analyte was not detected (number in parentheses is detection limit). 
3-18 

Table 3-7. Comparison of Untreated Graywater Concetrations to Untreated Domestic Wastewater 

Analyte Unit 

Average 

Concentration 

in Untreated 

Cruise Ship 

Accommodations 

Wastewater 

(EPA Data) 1 

Average 

Concentration 

in Untreated 

Cruise Ship 

Laundry 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Galley 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Food Pulper 

Wastewater 

(EPA Data) 1

Average 

Concentration 

in Untreated 

Cruise Ship 

Graywater 

(EPA Data)2

A

Conc

in U

Cru

Gr

(AC

D

Ammonia - Nitrogen mg-N /l 0.383* 

(6 detects out of 

12 samples) 

0.439* 

(6 detects out of 

12 samples) 

2.93* 

(8 detects out of 

12 samples) 

17.5* 

(3 detects out of 4 

samples) 

2.13* 

(23 detects out of 

40 samples) 

(28 de

30 

Nitrate/Nitrite mg/l 0.0858* 

(9 detects out of 

12 samples) 

0.100 

(12 detects out of 12 samples) 

0.0477* 

(8 detects out of 

12 samples) 

0.335* 

(3 detects out of 

4 samples) 

0.0872* 

(32 detects out of 

40 samples) 

0.

(3 dete

sa

Total Kjeldahl Nitrogen mg/l 15.2 

(12 detects out of 

12 samples) 

4.14* 

(11 detects out of 

12 samples) 

38.8 

(12 detects out of 

12 samples) 

188 

(4 detects out of 4 

samples) 

26.2* 

(39 detects out of 

40 samples) 

(4 dete

sa

Total Phosphorus mg/l 2.20 

(12 detects out of 

12 samples) 

4.31 

(12 detects out of 

12 samples) 

20.0 

(12 detects out of 

12 samples) 

186 

(4 detects out of 4 

samples) 

10.1 

(40 detects out of 

40 samples) 

(4 dete

sa

1 Based on data collected by EPA in 2004. 2 EPA used flow rates for the individual graywater sources to calculate a flow-weighted average to represent untreated graywater. 3 Based on data collected by ACSI/ADEC in 2000 and 2001. 4 Metcalf & Eddy, 1991.* Average includes at least one nondetect value; this calculation 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 environmental 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 standards for ships and land-based sewage treatment 

plants and (2) EPA’s National Recommended Water Quality Criteria (NRWQC). Detailed 

information on treated graywater (that is, the effluent 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 and dilution that occurs following discharge; this 

is discussed in subsection 3.4.3 below. 

3.4.1 Comparison to wastewater discharge standards 

Table 3-8 shows the comparison of average analyte 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 standards 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 suspended solids). In addition, untreated graywater 

concentrations exceeded all wastewater discharge standards under Title XIV for continuous 

discharge from cruise ships in Alaska, and secondary 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 discharges in Alaska waters must 

achieve the Title XIV continuous discharge standards.) 

Table 3-8. Comparison of Untreated Cruise 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 <203

Total residual 

chlorine (μg/l) 

NR 372*^ <10 
December 29, 2008 

 3-20 

Biochemical 

oxygen demand 

(5-day) (mg/l) 

 1,140 354 <454 

<305

<454 

<305

Total suspended 

solids (mg/l) 

704 318 <150 <454 

<305

<454 

<305

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 addition, the 30-day average percent 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 chlorine reported by most analytical labs is 100 μg/l. 

“NR” indicated that this information was not reported; equipment used to measure free and total chlorine is not 

suitable for measuring low levels of chlorine and is subject 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 concentrations 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 saltwater aquatic life and for human health (for the consumption 

of organisms only), and for pathogen indicators, compared these effluent concentrations to 

criteria for the protection of human health from incidental ingestion during recreational activities 

(e.g., swimming and surfing) and to criteria for consumption of shellfish. Analytes that exceed 

the NRWQC are discussed in greater detail in the subsections below. 

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 

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 organisms and, considering likely pathways 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 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 shall use procedures which account for, 

where appropriate, the dilution of the effluent in the receiving water. 
December 29, 2008 

 3-21 

Nevertheless, comparison of cruise ship wastewater 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 ship wastewater is less than the NRWQC, the 

wastewater should not cause, have the potential to cause, or contribute 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 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. It should be noted that such an analysis may be more 

difficult for mobile sources such as vessels, but in general, greater 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 Research 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 water column, and pose the risk of disease in 

consumers when eaten raw (National Research Council, 1993; Wu, 1999). 

The NRWQC for pathogen indicators references 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 used 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 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 bacterial 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 untreated graywater consistently exceed the NRWQC for marine 

water bathing and shellfish harvesting waters (see 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 coliform exceeded the 43 MPN/100 mL standard for 

harvesting shellfish. Given the consistent exceedance of the NRWQC for bacteria, untreated 

graywater may cause, have the potential to cause, or contribute to non-attainment of water 

quality standards; 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. 

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 information was not collected. 

Conventional Pollutants and other Common Analytes

Conventional pollutants and other common analytes that have a saltwater aquatic life or human 

health (for the consumption of organisms) narrative NRWQC include oil and grease, settleable 

residue, total suspended solids (see Table 3-11), and temperature (see Tables 3-11 and 3-12). In 

addition, the NRWQC include a numeric 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 oils 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 resulting from artificial sources is 1°C (1.8 °F) during all 

seasons of the year, providing the summer maxima are not exceeded; and daily temperature 

cycles characteristic of the waterbody segment should 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 impacts 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 graywater that would allow us to directly evaluate 

the narrative NRWQC for oil and grease. Hexane extractable material (HEM) was detected in 

100% of EPA’s untreated graywater samples (38 detects out of 38 samples) with detected 

amounts ranging between 5.6 and 5,010 mg/l. ACSI/ADEC 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 suspended, may harm marine organisms by reducing water clarity 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 cruise ship graywater against the narrative NRWQC for settleable 

and suspended solids because the criterion is based 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 average 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 detected values are substantially higher than the 

discharge standards for sewage from land-based sewage treatment plants (7-day average shall not 
December 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 reproduce effectively. Increases in temperature are frequently linked to 

acceleration in the biodegradation 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 against the narrative NRWQC for 

temperature because the criterion is based on conditions in a specific waterbody, such as flushing 

and the factors that influence flushing. The average temperature from EPA’s untreated 

graywater samples was 39.6 °C (temperature data were not available for ACSI/ADEC’s 

untreated graywater samples). Local waterbody temperatures would be needed to determine if 

the average temperature from untreated graywater would cause, have the potential to cause, or 

contribute to non-attainment of water quality 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 for untreated graywater effluent exceeds the 

temperatures presented in Table 3-12. A site-specific 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 waterbodies where cruise ships operate, it is unlikely 

that cruise ship effluent temperatures would cause an increase in waterbody temperature that 

would exceed the NRWQC.

Table 3-12. Seasonal Coastal Water Temperatures 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 Water Temperature Guide (www.nodc.noaa.gov/dsdt/wtg12.html) 

Total Residual Chlorine

Chlorine is extremely toxic to aquatic organisms. Chlorine concentrations as low as 3 μg/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 μg/l) can cause avoidance behavior, respiratory problems, and 
December 29, 2008 

 3-25 

hemorrhaging (Vetrano, 1998). Fish may recover once 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 shown that continuous chlorination 

can lead to a shift in the composition of phytoplankton communities, thus altering the benthic 

and fish communities that feed on them (Sanders and Ryther, 1980). 

Total residual chlorine concentrations were not available for EPA’s untreated graywater samples. 

The average concentration of total residual chlorine from ACSI/ADEC’s untreated graywater 

sampling data exceeded the NRWQC for total residual chlorine (see Table 3-13). 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. 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 Cruise Ship Graywater to Numeric National 

Recommended Water Quality Criteria 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 (μg/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 chlorine reported by most analytical labs is 100 μg/l. 

Metals

In the aquatic environment, elevated concentrations 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, morphological, and behavioral patterns in aquatic organisms. One of 

the key factors in evaluating metal toxicity is the bioavailability of the metal in a waterbody. 

Some metals have a strong tendency to adsorb to suspended organic matter and clay minerals, or 

to precipitate out of solution, thus removing the metal from the water 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 sorbed to particulate matter, then it is likely not in a form that 

organisms can process. Therefore, a high concentration of a metal measured in the total form 

may not be an accurate representation of the toxic potential to aquatic organisms. Accordingly, 

NRWQC for the protection of aquatic 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 use 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 transform all forms of metals to the dissolved phase, 

thus increasing the amount of biologically available metals. 

 

EPA detected in the untreated graywater samples several dissolved metals that are common 

components of ship piping -- copper, nickel, and zinc -- at levels approximately 2 to 63 times 

above NRWQC for aquatic life (see Table 3-14). Both EPA and ACSI/ADEC detected total 

arsenic in 10% or more of samples with average concentrations exceeding the NRWQC for 

human health (for the consumption of organisms) (see Table 3-14). EPA also detected total 

thallium in untreated graywater at levels exceeding the NRWQC for human health (for the 

consumption of organisms). A site-specific evaluation would determine if these untreated 

graywater concentrations would cause, have the potential to cause, or contribute to nonattainment of water quality standards in a given receiving water. However, as discussed in 

section 3.4.3 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 3-14. Comparison of Untreated Cruise Ship Graywater to National Recommended 

Water Quality Criteria for Metals 

Analytes that 

Exceed One or More 

NRWQC1

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) (μg/l) 2.25* 1.22 0.14 

Copper (Dissolved) (μg/l) 195 NC 4.8 3.1 

Nickel (Dissolved) (μg/l) 18.2 NC 74 8.2 

Thallium (Total) (μg/l) 0.930* ND 0.47 

Zinc (Dissolved) (μg/l) 1,610 NC 90 81 

1

 Analytes are not listed in this table if the number of detects 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 concentration 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 information was not collected. 

“ND” indicates that the analyte was not detected. 

Semivolatile and Volatile Organics

Table 3-15 presents the organic compounds detected in untreated graywater that exceed 

NRWQC. Note that EPA and ACSI/ADEC did not test graywater for all organic compounds that 

have a NRWQC. The magnitude of the exceedances 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 evaluation would determine if these discharge concentrations would 
December 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 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 3-15. Comparison of Untreated Cruise Ship Graywater to National Recommended 

Water Quality Criteria for Semivolatile and Volatile Organics 

Analytes that Exceed One or 

More NRWQC1,2

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 (μg/l) 71.9* 22.4* 2.2 

Tetrachloroethylene (μg/l) 11.4* 10.7* 3.3 

1

 Analytes are not listed in this table if the number of detects 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 concentration was driven by detection limits. 2

 Untreated graywater 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 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 chemical that is commonly added to plastics to 

make them flexible and can be found in a variety of common products such as wall coverings, 

tablecloths, floor tiles, furniture upholstery, and shower curtains. Tetrachloroethylene is widely 

used in dry cleaning and for 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 corals and seagrasses, eutrophication (oxygendepleted “dead” zones), and increases in harmful 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 (NH3) and ionized (NH4

+

) 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 NH3 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 table for ammonia standards based on the pH, 

temperature, and salinity of a waterbody. Table 3-16 presents the average 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 Sampling1 

Average Concentration in ACSI 

Graywater Sampling2

Ammonia (NH3-N μg/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) 

(NH3-N μg/l)4

NRWQC 

Criterion Continuous 

Concentration (CCC) 

(NH3-N μg/l)4

Galveston Bay1 TX 8.1 29.0 14.0 2,140 321 

Honolulu Harbor1 HI 8.0 25.5 34.4 4,110 617 

Los Angeles Harbor1 CA 8.1 17.4 32.6 7,110 1,110 

Port of Miami2 FL 8.0 25.3 32.0 4,110 617 

Monterey Harbor1 CA 8.1 15.3 32.9 6,860 1,070 

New York Harbor1 NY 7.5 22.1 22.9 11,500 2,960 

Southeast Alaska3 AK 7.8 12.5 20.0 15,600 2,340 

Portland Harbor1 ME 7.8 19.4 29.6 9,040 1,400 

1

 Data source: EPA’s EMAP National Coastal Database (http://oaspub.epa.gov/coastal/coast.search) 2

 Data source: South Florida Water Management District Monitoring Stations 

(http://glades.sfwmd.gov/pls/dbhydro_pro_plsql/water_quality_interface.main_page) 3

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

Vessel Wastewater Discharge General 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, temperature, 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 temperature the standard was 

approximated based on the closest value. In addition, the ammonia standards were converted from μg-NH3/l to μgNH3-N/l by multiplying the standard by 0.822. 
December 29, 2008 

 3-29 

Average concentrations of ammonia in untreated graywater exceed most of the NRWQC Criteria 

Continuous Concentration and one of the NRWQC Criteria Maximum Concentration presented 

in Table 3-17. Although ammonia standards can vary from waterbody to waterbody, there is 

only a small range of pH, temperature, and salinity values that result in a chronic ammonia 

standard that untreated graywater concentrations will not exceed. This suggests that ammonia 

concentrations in untreated graywater at the end-of-pipe are likely to exceed chronic NRWQC 

regardless of the receiving water. 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. However, as discussed in section 3.4.3 below, 

ammonia in untreated graywater would likely meet 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 cruise ship untreated graywater exceed some 

NRWQC at the end-of-pipe, the mixing and dilution that occurs following discharge also is 

relevant to an evaluation 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 m3/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 effluent during stationary discharge under a 

very conservative scenario (a neap tide in Skagway Harbor), using the Visual Plumes model. 

Their modeling showed the dilution factors ranging 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 for a vessel at rest would 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 mixing 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 (see 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 the initial mixing estimates discussed above are based on ship and 

waterbody-specific input parameters such as discharge port size, effluent flow, waterbody 

temperature, and salinity. Therefore, they are not necessarily representative 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 calculations would be required to determine the dilution for ships in 

other locations. 

Dilution Underway

For vessels underway, there is significant additional dilution due to movement of the vessel and 

mixing by ship propellers. In 2001, EPA conducted 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 ships 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 likely meet all NRWQC except for fecal coliform 

while underway. 

3.4.4 Potential Treatment Technologies in Addition to AWTs 

As part of its assessment of the cruise ship sewage 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 terms of nutrients, metals, and temperature. See 

Section 2 (subsection 2.4.4) for a discussion of these potential treatment technologies.

3.5 What action is the federal government taking to address graywater waste streams from 

cruise ships? 

EPA is evaluating the performance of advanced sewage and graywater treatment systems.

EPA is evaluating the performance of various advanced 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 intensive effort, including sampling four different 

AWTs and a survey questionnaire for all cruise 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 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. 

EPA is developing a water permit program for pollutant discharges incidental to the normal 

operation of vessels.

Under a U.S. District Court decision, the existing 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 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). 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 Pollutant 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 implemented an inspection regime that includes sampling 

of cruise ship sewage and graywater discharges in Alaskan waters. In July 2001, Coast Guard 

published a final rule (33 CFR 159.301-321) that outlines its oversight 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 their 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 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 Marine 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 these proposed rules. The Channel Islands 

National Marine Sanctuary has published a proposed 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 reviewing the comments on this proposed rule. 

National Park Service manages cruise ship waste streams in Glacier Bay National Park.

The National Park Service (NPS) manages cruise ship waste streams indirectly in Glacier Bay 

National Park through competitively awarded concession contracts. The NPS has jurisdiction 

over the submerged lands and marine waters of Glacier Bay National Park up to 3 miles from the 

mean high tide line and including all of Glacier Bay proper. Glacier Bay is a well known, very 

popular attraction for the cruise ship industry in Alaska. Recent environmental reviews and 

decisions allow up to two cruise ship entries per day into Glacier Bay proper during the primary 

visitor season. Cruise ship operations in the park are authorized under concession contracts, 

which are awarded under a competitive solicitation and prospectus process. Impact on park 

resources is a general standard selection criterion for park concessions. The NPS uses waste 

stream management as one of a number of selection criteria in this regard. In the past, cruise 

ship operators have usually proposed to minimize 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 transfer any 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 received 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 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. 

Prevention & Reduction 

 Establish standards or best management practices for design, operation, maintenance 

and/or training that will decrease 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 reduction attainable through application of the best available 

technology economically achievable. 

o to require technology that would eliminate remaining pollutants of concern (i.e., 

reduce to level below concern). 

o to require use of Advanced Wastewater Treatment systems. 

o to apply Title XIV standards (which apply 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 distance (e.g., 0.5 nautical miles, 4 nautical 

miles) of sensitive areas (e.g., shellfish, ports, coral reefs, bathing beaches, water 

bodies with restricted circulation, flushing or inflow, marine protected areas, 

breeding grounds, near large 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 sampling, 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 reporting by cruise ship operators, for example, 

o immediate notification to appropriate agencies in the event of an treatment system 

malfunction or upset. 

o disclosure of implementation or non-implementation of pollution reduction and 

prevention practices, including but not limited 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 agencies of all discharges of untreated graywater or 

treated graywater effluent in U.S. waters. 

o notification of discharges in state waters 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 treated 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 sensitive 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/cruise_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/cruise_ships/pdfs/acsireport2.pdf) 

Alaska Department 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/impactofcruiseship.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 International Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry 

Waste Management Practices and Procedures. Fort Lauderdale, FL. 

(www.cruising.org/industry/PDF/CLIAWasteManagementAttachment.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. American Water Works Association. 

(www.aquacraft.com/Publications/resident.htm) 

National Research Council (NRC): Committee on Wastewater Management for Coastal Urban 

Areas, Water Science and Technology Board, Commission on Engineering and Technical 

Systems. 1993. Managing Wastewater in Coastal Urban Areas. Washington, DC: 

National Academy Press. (http://www.nap.edu/catalog.php?record_id=2049#toc) 

National Research 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 epidemiological 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: Environmental 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. Environmental Protection Agency. 1986. Quality Criteria for Water (EPA 440/5-86-001). 

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

U.S. Environmental Protection Agency. 1989. Ambient Water Quality Criteria for Ammonia 

(Saltwater)(EPA 440/5-88-004). Washington, DC. 

(http://www.epa.gov/waterscience/pc/ambientwqc/ammoniasalt1989.pdf) 

 

U.S. Environmental Protection Agency. 1991.Technical Support Document for Water Qualitybased Toxics Control (EPA 505-290-001). Washington, DC. 

(http://www.epa.gov/npdes/pubs/owm0264.pdf) 

U.S. Environmental Protection Agency. 2002. Cruise Ship Plume Tracking Survey Report

(EPA842-R-02-001). Washington, DC. 

(http://www.epa.gov/owow/oceans/cruise_ships/plumerpt2002/plumereport.pdf) 

U.S. Environmental Protection Agency. 2004. Survey Questionnaire to Determine the 

Effectiveness, Costs, and Impacts 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. Environmental Protection Agency. 2006a. Sampling Episode Report for Holland America 

Veendam (Sampling Episode 6503). Washington, DC. 

(http://www.epa.gov/owow/oceans/cruise_ships/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_ships/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/cruise_ships/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_ships/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 

Environmental Corporation. Windsor, CT. 

World Health Organization (WHO). 1986. Ammonia Environmental Health Criteria 54. Geneva, 

Switzerland. (http://www.inchem.org/documents/ehc/ehc/ehc54.htm) 

Wu, R.S.S. 1999. Eutrophication, Water Borne Pathogens and Xenobiotic Compounds: 

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 similar 

wastes that accumulate in the lowest part of a vessel 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 machinery 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 discharged overboard in accordance with applicable 

standards and regulations. 

This section discusses the current 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 environmental impacts of cruise ship bilge water, and federal 

actions taken to address bilge water from cruise ships. The conclusion of this section lists a wide 

range of options and alternatives that could be considered 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 fluids, lubricants, cleaning fluids, and other similar 

wastes that accumulate in the lowest part of a vessel from a variety of different sources including 

the main and auxiliary engines; boilers, evaporators and related auxiliary systems; equipment 

and related components; and other mechanical and operational sources 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 these systems. These leaks, 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 coolers, etc.), collect in the bilge. 

Machinery spaces onboard cruise ships are complex 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 onboard are very large and are not too different 

from shore side power plants. Cruise ship machinery 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 leaks develop due to lack of maintenance and repair of failed 

seals, gaskets, pump shaft seals, machinery casing gaskets and other components. The sizes of 

these leaks may vary tremendously and the size 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 pollution from cruise ships (National Association 

of Attorneys General, 2000). 

 4-1 
December 29, 2008 

In addition to containing oil and grease, bilge water may contain solid wastes such as rags, metal 

shavings, paint, glass, and a variety of chemical substances (U.S. Environmental Protection 

Agency, 1997). Bilge water may contain various 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 graywater (see Sections 2 and 3, respectively), are 

typically contained within their own systems and might only be present in bilge water as a result 

of leaks. 

The amount of bilge water that accumulates onboard can vary, and depends on a number of 

factors including the size of the ship, engine room design, preventative maintenance, and the age 

of the components. Accumulation of bilge water 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 mixtures, including fuel oil sludge, lubricating 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 contaminants improves low quality fuels and prevents 

damage to the ship’s engines and highly machined 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 byproducts 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 common 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 oil 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 used 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 concentrations of oil and sludge 

particles. 

 4-2 
December 29, 2008 

The Alaska Department of Environmental Conservation (2000) reported 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 relationship between ship tonnage 

and bilge water produced, many variables exist that can easily cause a smaller vessel to produce 

more bilge wastes than a larger vessel. For example, a vessel with just six small 1/8 inch size 

leaks and four 1⁄4 inch leaks without substantial 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 Prevention of Pollution from Ships (MARPOL)

MARPOL Annex I, Regulations for the Prevention 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 petroleum products, including crude oil, fuel oil, oily waste, oily 

mixtures located in the bilge, and petroleum products 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 applies 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 detention of the vessel in port, denial of port entry, 

or the initiation of civil or criminal enforcement proceedings. 

 4-3 
December 29, 2008 

Applicable Coast Guard regulations

The Coast Guard generally has the primary responsibility to prescribe and enforce the 

regulations necessary to implement APPS in the United States. The following Coast Guard 

regulations pertain to the management of the discharge of oil or oily mixtures into the sea from 

ships1: 

 Coast Guard regulations (33 CFR 151.10) provide that, when within 12 nautical miles 

(nm) of the nearest land, any discharge of oil 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 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 CFR 151.10) provide that, when more than 12 nm from the 

nearest land, any discharge of oil 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 without 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 regulations (33 CFR 151.13) prohibit the 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 regulations (33 CFR 151.10) provide that if the bilge water cannot 

be discharged in compliance with these standards, then it must be retained onboard or 

discharged to a designated reception facility. 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 America or their connecting and 

tributary waters; and 3) a Canadian or U.S. ship being operated exclusively on the internal waters of the United 

States and Canada; or 4) any other ship specifically excluded by MARPOL. 

 4-4 
December 29, 2008 

Emergency discharges or other exceptional discharges must nevertheless be accurately 

recorded in ship records and reported to the nearest port state or Coast Guard Captain of 

the Port. 

 In addition, Coast Guard regulations (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 maintain an Oil Record Book Part II (Cargo/Ballast Operations). 

The Oil Record Book is subject to routine 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 fixed 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 tanker 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, accidental or other exceptional 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 that all the entries in the 

book appropriate to that operation are completed. Each completed operation shall 

be signed by the person or persons in charge 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 such 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 charge of a ship required to keep an Oil 

Record Book shall be responsible for the maintenance of such record. 

 

 4-5 
December 29, 2008 

MARPOL contains additional requirements on what information must be recorded in an Oil 

Record Book, including the details of overboard discharges of “bilge water which has 

accumulated in machinery spaces”2/

 (MARPOL, Annex I, Appendix III(D)). MARPOL also 

requires the logging of any failure of the oil discharge monitoring 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, preparedness, and response capabilities 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, increase penalties for spills, establish Coast Guard 

response organizations (including elements of the National Strike Force, district response 

advisory staff, Coast Guard personnel, and equipment 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 cruise 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 extends 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 Administrator 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 holding 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. 

 4-6 
December 29, 2008 

 cause a film or sheen upon or discoloration 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 historical vessels, or unique 

habitats, from degradation while facilitating public or private uses compatible with resource 

protection.

NMSA authorizes the National Oceanic and Atmospheric Administration (NOAA) to designate 

as National Marine Sanctuaries areas of the marine environment that have special aesthetic, 

ecological, historical, or recreational qualities, and to provide comprehensive and coordinated 

conservation management for such areas. The National Marine Sanctuary Program manages 13 

sanctuaries and the Papahānaumokuākea Marine National Monument (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 regulations for NMSA, regulations 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 manage oily bilge water from cruise ships? 

In order to maintain vessel stability and eliminate potentially hazardous conditions from the 

accumulation of bilge waste, it is necessary to periodically 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 facility on shore; or (2) treated onboard with an 

Oily Water Separator (OWS). The treated bilge water then can be discharged overboard in 

accordance with applicable standards and regulations while the petroleum products extracted by 

the OWS (i.e., oily waste) are retained in a dedicated holding tank onboard (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 concentration of 15 ppm oil or 

less, and, for ships beyond the 12 nm limit, provided that the ship is underway. MARPOL and 

APPS also require that the discharge 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 mixtures 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 water may be discharged 

 4-7 
December 29, 2008 

overboard after processing by an Oily Water Separator and passing through a bilge alarm, more 

commonly known as an Oil Content Monitor that is designed to detect when the effluent exceeds 

an oil content of greater than 15 ppm. The required pollution prevention equipment also includes 

an automatic stopping device (typically a three-way solenoid valve) that when triggered by the 

Oil Content Monitor, will automatically divert the oily water mixture back into a holding tank. 

APPS and MARPOL define machinery space waste as an oily water mixture. 

The amount of machinery space waste, as mentioned 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 medium, water-lubricated propeller shaft bearing systems use 

seawater instead of oil. This substitution can have benefits should a ship experience a shaft 

bearing leak, for instead of potentially leaking oil, seawater would be leaked. Depending on 

where the failure in the propeller shaft bearing 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 ship is en route. Such ship 

equipment allows for compliance with both international regulations (MARPOL) and Coast 

Guard regulations that require the 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. Regulations 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 (Table 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 sufficient size to hold the 

water for several days. 

2) Bilge water is processed by an OWS to extract oil and petroleum products from the bilge 

water. Different cruise ships may use different types of OWS (e.g., centrifugal, filtration, 

and gravity based systems). 

3) The treated bilge water from the OWS is discharged overboard provided that the OWS is 

certified by the Coast Guard, using International Standards Organization 9377-2:2000; 

the discharge does not have an oil content of greater than 15 ppm; and the discharge does 

not leave a visible sheen on the surface of the water. 

4) All oil or oil residues that cannot be discharged in compliance with the abovementioned 

requirements – generally the oily waste collected 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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December 29, 2008 

Table 4-2. Oily Water Separator Technologies 

Description/Capabilities of OWS Devices Processing Capacity 

– Removes oil and grease using naturally-occurring microbes 

– Continuous 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 m3

/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 divert 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 Business (CELB) (2003), several cruise 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 Environmental 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 Environmental Task Force Report (2003) identified the following 

potential problems associated with OWS systems: 

 Data recorders can be manipulated or shut off and not record all discharges; 

 Oil-water interface detectors (oil content monitor) can easily get out of calibration and 

allow more oil to be discharged 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 liquids 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. 

 4-9 
December 29, 2008 

In an attempt to improve the integrity of Oily Water Separators, as of 2007 a number of cruise 

lines have purchased a bilge water processing system “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 discharging overboard. The “White Box” System 

basically includes the pressure control 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 system monitors the oil content in the water from 

the oily water separator or bilge 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 (Marinfloc AB, 2006a): 

 time when the overboard pumping starts; 

 oil content meter level over a discharge cycle; 

 total quantity of water pumped overboard 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 Environmental Management Report (Carnival Corporation and PLC, 

2006), all Carnival ships route all bilge water destined for overboard discharge, including that 

stored in clean bilge water holding tanks, through a bilge water processing system “White Box.” 

The “White Box” is one of many commercially available control technologies designed to make 

bypassing more difficult. Other ideas are relatively simple, such as placing a unique number tag 

on every overboard flange in order to prevent unauthorized discharges or locking the overboard 

valve. Any technological solution to deter deliberate pollution, however, remains subject to 

compromise by an engineer determined to circumvent treatment. Other means to treat oily 

wastes in bilge water that are being explored include electro-chemical flocculation, biological 

digestion, membrane polishing, oil absorption, and incineration (Bryant, 2001). 

A number of cruise lines have purchased equipment that breaks emulsions in oily bilge water 

(Marinfloc AB, 2007b). Cleaning agents, emulsifiers, 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, the 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 breaking bilge water cleaning system can help achieve this. After 

free oil is separated from preheated oily bilge water, the remaining emulsified bilge water is 

directed to a circulation tank where a flocculent and small amount 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 passes through the OWS monitor. Bilge water less 

than 15 ppm can be discharged accordingly; bilge water exceeding 15 ppm is returned to the 

bilge water holding tank or settling/primary tank. (Marinfloc AB, 2006b). 

 4-10 
December 29, 2008 

Under the Cruise Lines International Association (CLIA) member agreement identified earlier, 

bilge and oily water residue should be processed prior 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 cruise 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 specified 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 such 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 the potential to 

create oil pollution through discharges of inadequately treated oily bilge water as a result of a 

faulty or malfunctioning OWS, human error, malfunctioning bilge monitors, or a deliberate 

OWS bypass. 

The impacts from oil pollution can vary depending upon numerous factors. The Port of 

Cordova, Alaska, has produced educational materials for harbor and non-harbor 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 release 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 physical and biological ecosystem 

exposed.” Other factors include the season, weather conditions, and the surrounding 

environment. Consequently, even a small spill 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 grease, 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 and 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 cellular- to the population-level (National Research 

Council, 2003). Recent studies suggest that polycyclic aromatic hydrocarbons (PAHs), even in 

low concentrations, can have a deleterious effect on marine biota. PAHs are known human 

carcinogens and occur in varying proportions in crude oil and refined products (National 

Research Council, 2003). Environment Canada (2006) further indicates that the different 

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December 29, 2008 

physical and chemical properties of crude and refined oils influence the physical and biological 

effects of an oil spill, the behavior of a slick, and the effectiveness 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 may 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 ingestion. Also, heavy oils can sink and create 

prolonged contamination of the sea bed and create tar balls that can scatter along beaches. (U.S. 

Government Accountability Office, 2007). 

Table 4-3 provides a description of oil types and the interactions that occur when such oil types 

are released into the marine environment. This table does not take into account 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 prevention 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 hours. 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, with 

severe 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 ships 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 order to be properly atomized and combusted. The 

California Cruise Ship Environmental Task Force 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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December 29, 2008 

According to the National Research Council (2003), the discharges from bilge water are 

considered to be moderate in terms of their loss by evaporation and dissolution, formation of tar 

balls, and potential for long-distance transport. In addition, vessel discharges pose a low risk of 

vertical mixing because the releases are generally viscous (National Research Council, 2003). 

Oil released into the marine environment immediately begins to move and weather, breaking 

down and changing its physical and chemical properties. Some of these processes occur 

immediately after the spill, while others occur over time. Some of the processes include 

dissolution, sedimentation, movement, bio-degradation, evaporation, weathering, and dispersion. 

As these processes occur, the oil threatens surface resources and a wide range of subsurface 

marine organisms, which are linked in complex food chains. Some organisms 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 sublethal effects, and disrupt the 

structure and function of marine communities and ecosystems. The chemical contaminants in oil 

can poison marine life, disrupt feeding, or cause chronic disease, reproductive failure and 

deformities – ultimately impacting the survival rates 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 surface in sites along U.S. coasts include mortality, malformation, 

and chromosome abnormalities. (Urban Harbor Institute, 2000). 

Exposure of marine organisms to petroleum hydrocarbons can result in mortality due to acute 

toxicity or physical smothering. Additionally, 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), ingestion of oil can kill birds or lead to starvation, 

disease, and predation of these 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 North Sea over the last 10 years showed that over 90% of the oil 

collected was composed of heavy fuel oil mixed with lubricant oil – the type found in bilges of 

large ocean-going vessels. In addition to the strong evidence for the impact of massive 

contamination associated with an oil spill, there is increasing evidence that chronic, low-level 

exposures to hydrocarbons in the sea can have 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 remain 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 impacts 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) further 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 concentrations of oil toxins from 

chronic sources might be lower compared to concentrations following a catastrophic spill in the 

marine environment, chronic pollution can be equally toxic to marine life if sustained over 

extended periods of time.” The Urban Harbors Institute 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 quality problems from chronic sources is equally 

important.” Chronic source contributions from cruise ships (i.e., cruise ships discharge oily bilge 

water treated to 15 ppm) should be considered in the context of cumulative impacts of repeated 

discharges because cruise ships frequently transit an established route and port destinations. In 

fact, the National Research Council (2003) identified that 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 conditions experienced by organisms in polluted 

coastal zones. 

 

4.5 What action is the federal government taking to address oily bilge water from 

cruise ships? 

The federal government’s bilge water management efforts have focused on responding to oil 

spills and developing preventative programs. The Coast Guard is the primary federal agency 

responsible for monitoring and enforcing requirements for cruise ship discharges. In addition to 

monitoring and enforcing standards, the Coast Guard has been working with the IMO to develop 

new international performance standards for oil pollution prevention equipment. 

The National Park Service (NPS) manages cruise ship waste streams indirectly in Glacier Bay 

National Park through competitively awarded concession contracts. The NPS has jurisdiction 

over the submerged lands and marine waters of Glacier Bay National Park up to 3 miles from the 

mean high tide line and including all of Glacier Bay proper. Glacier Bay is a well known, very 

popular attraction for the cruise ship industry in Alaska. Recent environmental reviews and 

decisions allow up to two cruise ship entries per day into Glacier Bay proper during the primary 

visitor season. Cruise ship operations in the park are authorized under concession contracts, 

which are awarded under a competitive solicitation and prospectus process. Impact on park 

resources is a general standard selection criterion for park concessions. The NPS uses waste 

stream management as one of a number of selection criteria in this regard. In the past, cruise 

ship operators have usually proposed to minimize 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. Cruise ships do not dock or transfer any wastes to 

shore while in the park. 

EPA has developed a water permit program for pollutant discharges incidental to the normal 

operation of vessels. Under a U.S. District Court decision, the existing EPA regulations that 

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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 the normal operation of vessels (such as bilge 

water) into waters of the U.S. from cruise ships 79 feet or longer in length will be subject to 

National Pollution Discharge Elimination System permitting. 

In a report produced by the U.S. General Accounting Office (now the Government 

Accountability Office) in 2000, 87 confirmed illegal 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 oil-based products. The report indicated that about 

three-fourths of these cases were accidental, resulting 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 incidents 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, the Coast Guard has a robust enforcement regime involving all vessels 

regarding violations of MARPOL Annex I. The Coast Guard conducts inspections of all cruise 

vessels operating in United States ports and waters quarterly and annually. These inspections 

typically include examination and testing of pollution prevention equipment and review of Oil 

Record Books. The Coast Guard works closely with 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 falsification of Oil Record Books to conceal the deliberate bypassing of 

the OWS entirely or tampering with the monitoring 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 calibration due to poor maintenance (thereby 

allowing bilge water discharges that exceed 15 ppm of oil); 

 Piping systems that are re-routed to bypass the bilge alarms/monitors; and, 

 Improper use of cleaning chemicals and surfactants 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 falsifying the Oil Record Book. Several port states (i.e., the country the 

cruise ship visits) have reacted by increasing their scrutiny of OWS systems and diligence for oil 

record book keeping (OECD, 2003). The U.S. is taking 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 cruise ship companies calling on U.S. ports have 

been convicted of such violations, 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 Address Oily Bilge Water from Cruise Ships 

Based on the public comments received 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 any 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 legal authority to implement that option. 

Prevention & Reduction 

 Establish standards or best management practices for operation, maintenance, and/or 

training that will decrease the contaminants in bilge water and/or the volume of treated 

and/or untreated oily bilge 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-based 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 environmental 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 prohibiting the discharge of any petroleum product into marine or 

fresh waters. 

 Require the highest attainable reduction of oil concentration 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 waste into the bilge area to then be 

managed/treated as oily bilge water. 

 Require more stringent standards in areas frequented by multiple cruise ships in order to 

adequately address cumulative impacts. 

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December 29, 2008 

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 sampling, monitoring, and other 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 signal 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 operators provide advance notification from ships planning to 

discharge in U.S. waters. 

 Require that the cruise ship operators notify all 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 activities they believe to be illegal. 

Enforcement & Compliance Assurance: Inspections & Enforcement 

 Revise current inspection practices to more aggressively identify noncompliant OWS 

equipment and include more detailed inspection of a vessel’s piping system to identify 

rerouting of discharges to circumvent bilge monitors and alarms. 

 Provide states enforcement authority to take actions when discharges occur where 

otherwise prohibited; require substantial penalties for violations of those laws and require 

the full recovery of all costs arising from enforcement of such laws.

 Establish penalties for failure to meet applicable standards and regulations 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 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. 

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December 29, 2008 

 Prohibit or otherwise restrict noncompliant vessels (and sister ships, depending on the 

degree of involvement by parent companies) from operating in sensitive areas of the 

marine environment under U.S. jurisdiction. 

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December 29, 2008 

References

Alaska Department of Environmental Conservation (ADEC). 2000. Alaska Cruise Ship Initiative 

Part 1 Final Report. Juneau, AK. 

(www.dec.state.ak.us/water/cruise_ships/pdfs/finreportp10808.pdf) 

Alfa Laval. accessed December 28, 2008. EcoStream: Oily Water Cleaning System. 

(http://www.alfalaval.com/solution-finder/products/eco-stream/Documents/Ecostream.pdf) 

Bluewater Network. (2000, March 17). Petition to Environmental Protection Agency 

Administrator Carol M. Browner. (www.epa.gov/owow/oceans/cruise_ships/petition.pdf) 

Bryant, Dennis L. 2001. Environmental Compliance in the Cruise Industry. Holland and Knight 

Articles and White Papers. 

(http://www.gsy.fi/id24660/PublicationId3/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 Leadership 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) 

Coffin World Water Systems. accessed December 28, 2008. Ultra-Sep Oily Water Separators. 

(http://www.cworldwater.com/) 

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 International Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry 

Waste Management Practices and Procedures. Fort Lauderdale, FL. 

(www.cruising.org/industry/PDF/CLIAWasteManagementAttachment.pdf and 

www.cruising.org/industry/PDF/CLIAWasteManagement.pdf) 

Cruise Ship Environmental Task Force. 2003. Report to the Legislature: Regulation of Large 

Passenger Vessels in California. 

(http://www.swrcb.ca.gov/publications_forms/publications/legislative/docs/2003/cruisesh

iplegrpt.pdf) 

EnSolve. accessed December 28, 2008a. Petroliminator PL 630M OWS: Product Fact Sheet. 

(http://www.ensolve.com/userfiles/file/Products/PL%20630M%20pds%20rev%201108.pdf)

EnSolve. October, 2008b. EnSolve Biosystems Inc. News – Volume 1, Issue 1. 

(http://www.ensolve.com/userfiles/file/News/EnSolve%20Newsletter%2010-08.pdf) 

 4-19 
December 29, 2008 

Environment Canada. 2006. Oil, Water, and Chocolate Mousse. The Green Lane, Environment 

Canada’s World Wide Website. 

(http://www.ec.gc.ca/ee-ue/default.asp?lang=EN&n=88F67B04) 

Marinfloc AB. 2005. Type Approval Certificate as per Bureau Veritas Classification Rules. 

(http://www.marinfloc.com/?menu=Products&lowerMenu=Marinfloc%20WBS) 

Marinfloc AB. May, 2006a. White Box: Fail Safe System for Discharge of Treated Bilge Water. 

Data Sheet # 50001. 

(http://www.marinfloc.com/upload/files/wbs/50001%20White%20Box%20%20Descripti

on.pdf) 

Marinfloc AB. 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/files/ebbwcs/08%20CD%20Complete%2015%2001%

202008.pdf) 

Marinfloc AB. 2007a. List of References: White Box System – Type WBS. Data Sheet # 50004, 

2007-10-24. (http://www.marinfloc.com) 

Marinfloc AB. 2007b. List of References: Emulsion Breaking Bilge Water Cleaning System – 

Type CD. Data Sheet # 21, 2007-10-24. (http://www.marinfloc.com) 

National Association of Attorneys General. Spring 2002. Floating Cities, Urban Problems: A 

Report by the National Association of the Attorneys General Cruise Ship Workgroup. 

Washington, DC. 

National Research 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) 

Organization for Economic Co-operation and Development (OECD). 2003. Cost Savings 

Stemming from Non-Compliance with International Environmental Regulations in the 

Maritime Sector. Paris, France. (www.oecd.org/dataoecd/4/26/2496757.pdf) 

Peterson, Charles H.; Holland-Bartels, Leslie. 2002. Nearshore vertebrate predators: constraints 

to recovery from oil pollution. Marine Ecology Progress Series 241:235-236. 

Senitec. accessed December 28, 2008. Sludge and Bilge Water System for the Future – Senitec 

SEA. Senitec MB 1000. (http://www.senitecsludge-oilywatertreatment.com/pdf/sea1.0.pdf) 

Senitec 2006. EC Type Examination Certificate: Oil-Filtering Equipment (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) 

 4-20 
December 29, 2008 

 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. 

U.S. Environmental Protection Agency. 1997. Profile of the Water Transportation Industry. 

(EPA/310-R-97-003). Washington, D.C.: Author. 

(http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/wat

ersct.pdf) 

U.S. Environmental Protection Agency. 2006. Effects of Oil Spills. 

(http://epa.gov/oilspill/edueff.htm) 

Wiese, F.K. 2002. Seabirds and Atlantic Canada’s Ship-Source Oil Pollution: Impacts, Trends, 

and Solutions. Prepared for World Wildlife Fund Canada. Toronto, Canada. 

(http://www.wwf.ca/Documents/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, rubbish, 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, waste minimization, and 

recycling. According to the Alaska Department of Environmental Conservation (ADEC) (2001), 

75 to 85% of trash is generally incinerated onboard, and the ash is typically discharged at sea; 

some solid waste is landed ashore for disposal or recycling (CRS, 2007). 

This section discusses the current 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 taken to address solid waste 

from cruise ships. The conclusion of this section lists a wide range of options and alternatives 

that could be considered when addressing 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, rubbish, 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 waste, newspapers, product and machinery parts, 

disposable products, and recyclable products. This section discusses non-hazardous solid waste 

generated on cruise ships. Hazardous waste, however, is a type of solid waste, which, because of 

its quantity, concentration or physical 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 generally contains hazardous 

substances which can be liquids, solids, or contained gases and must 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 cruise ship typically comprises the materials used for packaging 

products for transportation or storage, waste generated by passenger and crew activity, and food 

waste. More specifically, the types of solid waste generated on a ship can include food waste, 

glass, paper, wood, cardboard, incinerator ash, metal cans, and plastics. Table 5-1 identifies 

some types of common solid waste items, including specific examples, generated aboard cruise 

ships. 

 5-1 
 December 29, 2008 

Table 5-1. Some Types and Specific Examples/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 Environmental Report, packaging materials from 

consumables and spare parts for a ship can generate up to 15 tons of waste in a single day. Table 

5-2 presents the estimates of certain types of solid waste generated 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 generated by cruise ships varies from ship to ship, based on the size 

of the vessel, number of passengers and crew, and 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 generates 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 generated 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 seafarers are likely to use packaged prepared foods, 

 5-2 
 December 29, 2008 

supplies, and single use items rather 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 (National Research Council, 1995). 

With large cruise ships carrying several thousand passengers, the amount of waste generated in a 

given day can be considerable. One large cruise ship of 2,500 passengers and 800 crew (total 

3,300 persons onboard) can generate 1 ton of garbage from normal operations in a day (National 

Research Council, 1995). On average, each cruise ship passenger generates 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 (both 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 Generated 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 Caribbean 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 increasing at the rate of roughly 90 ft every 5 years (Bell, 2007). As 

the size and number of passengers these cruise ships 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 Prevention of Pollution from Ships (MARPOL)

MARPOL Annex V regulates the disposal of garbage into the sea, by setting forth prohibitions 

on disposal (e.g., of plastics), to establishing how and where 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 the normal operation of the ship and liable to be disposed of 

continuously or periodically except those substances which are 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 conditions and to the particular 

character of its traffic, the adoption of mandatory methods for the prevention of sea pollution by 

garbage is required.” The special areas identified by Annex V are the Mediterranean Sea, Baltic 

Sea, Black Sea, Red Sea, Gulfs area, North Sea, Antarctic, and Wider Caribbean Region. In 

addition, the Annex requires some ships (i.e., depending on size and passenger load) to maintain 

Garbage Record Books, develop Garbage Management 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 three miles of shore; certain types of 

garbage from 3-25 miles offshore; and plastic anywhere. Vessels are also required to record 

each discharge or incineration of garbage in a Garbage Record Book. Under APPS, the 

definition of “ship” includes fixed or floating platforms. There are separate garbage discharge 

provisions applicable to these units. 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 garbage 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 responsibility to prescribe and enforce the 

regulations necessary to implement APPS in the United States. The following Coast Guard 

regulations pertain to the management of solid waste on ships: 

 Every manned oceangoing ship of 400 gross tons 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 placards outlining disposal 

requirements are placed in prominent locations and in sufficient numbers for both 

passengers and crew (33 CFR 151.59). 

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 December 29, 2008 

 No person onboard any ship may discharge garbage 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 seaward 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 plastic garbage bags. All garbage containing plastics must be 

discharged ashore or incinerated (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 packing materials that float; or (2) 12 nm for 

victual wastes (any spoiled or unspoiled food wastes) and all other garbage including 

paper products, rags, glass, metal, bottles, crockery and similar refuse, except that, such 

garbage may be discharged outside of 3 nm from nearest land after 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 discharges having different disposal or discharge 

requirements, the more stringent requirements shall apply. 

Table 5-4 provides a summary of garbage discharge restrictions per 33 CFR Part 151 for vessels 

operating both in special areas and outside of special areas. 

Table 5-4. Summary of Garbage Discharge Restrictions for Vessels 

All Vessels Except Fixed or Floating Platforms and Associated Vessels 

Garbage Type Outside special areas 

(33 CFR 151.69) 

In special areas2 

(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 ground1

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 waste4 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 

ground1

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 

 5-5 
 December 29, 2008 

Mixed garbage types3 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 through 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 Coast Guard administers the reception facility 

“Certificate of Adequacy” (COA) 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 shore bases, and recreational boating facilities, must have a 

garbage reception facility which meets the regulatory requirements 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 reception 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 direct contact with the open sea and the line marking 

the seaward limit of inland waters, and extending seaward a distance of three miles), except in 

compliance with a National Pollutant Discharge Elimination System (NPDES) permit or as 

otherwise authorized under the Act. The term “point source” is defined to include a “vessel or 

other floating craft.” The term “pollutant” does not include sewage from vessels (within the 

meaning of CWA section 312). Outside the territorial seas, i.e., in the contiguous 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 operates in a capacity other than as a means of 

transportation such as when used as an energy or mining facility, a storage facility or a seafood 

processing facility, or when secured to the bed of the ocean, contiguous zone, or waters of the 

United States for the purpose of mineral or oil exploration or development (40 CFR 122.3(a)). 

In addition, EPA regulations (40 CFR 122.3(a)) have historically excluded discharges incidental 

to the normal operation of a vessel (for example, effluent from properly functioning marine 

engines, laundry, shower, and galley sink wastes) from the requirement of an NPDES permit. 

 5-6 
 December 29, 2008 

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 industrial discharges which are point 

sources subject to NPDES permits are not “solid waste” under the RCRA statute. This only 

applies to materials once they have been discharged. For further information regarding operation 

of the RCRA statute as it applies 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 historical vessels, or unique 

habitats, from degradation while facilitating public or private uses compatible with resource 

protection. NMSA authorizes the National Oceanic and Atmospheric Administration (NOAA) to 

designate as National Marine Sanctuaries areas of the marine environment that have special 

aesthetic, ecological, historical, or recreational qualities, and to provide comprehensive and 

coordinated conservation management for such areas. The National Marine Sanctuary Program 

manages 13 sanctuaries and the Papahānaumokuākea Marine National Monument (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 regulations 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 (RCRA; 42 U.S.C. § 6901 et seq.) is the federal 

law that, among other things, defines and provides for regulation of solid waste and hazardous 

waste. RCRA is designed to minimize the hazards of waste disposal, conserve resources through 

waste recycling, recovery, and reduction, and ensure waste management practices that are 

protective 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

 RCRA Subtitle D encourages environmentally-sound solid waste management 

practices that maximize source reduction, reuse, and recycling efforts, and establishes regulations 

that specify how solid waste disposal facilities (i.e., municipal solid waste landfills) should be 

designed and operated. RCRA provides that solid waste is predominantly regulated by state and 

local governments (U.S. Environmental Protection Agency, 2006). 

 

1

 In states with hazardous waste programs authorized by EPA, the authorized state hazardous 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. 

 5-7 
 December 29, 2008 

5.2.5 Marine Protection, Research, and Sanctuaries Act 

The Marine Protection, Research, 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 waters without a permit; (2) the transportation of any 

material by U.S. agencies or by U.S. flagged vessels or aircraft for the purpose of disposal in 

ocean waters without a permit; and (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 address 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 management of shipboard-generated waste is a challenge not only for cruise ships at sea, but 

also for other commercial vessels, military ships, fishing vessels, and recreational boats. Most 

cruise ship trash is treated 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 discharged 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 cruise ships are often separated from other solid 

wastes and processed separately. 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 holding tanks; the remaining compressed, dehydrated 

food waste is incinerated. Hazardous wastes are separated from other solid wastes because 

onboard incinerators do not operate at the temperatures necessary to properly destroy hazardous 

substances. Therefore, proper waste 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 (including incinerator ash) in accordance with 

applicable state solid waste 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. 

 5-8 
 December 29, 2008 

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 and 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 efficient removal of water by extractors. Removing 

excess water allows food waste to be burned 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) environmental 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 ships report that they 

employ various types of equipment such as glass 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 includes waste minimization, source reduction, and 

recycling, along with waste stream management and periodic ash testing, should be sufficient to 

ensure that incinerator ash does not meet the definition of hazardous waste (e.g., if it exhibits a 

characteristic of hazardous waste as defined 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 onboard 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 identified and segregated for individual handling and management in 

accordance with appropriate laws and regulations. (CLIA, 2006). 

As mentioned above, the CLIA environmental standards call for the testing of incinerator ash at 

least once quarterly for the first year of operation to establish a baseline, and annual testing 

 5-9 
 December 29, 2008 

thereafter. Any incinerator ash that exhibits a characteristic of hazardous waste as defined in 40 

CFR Part 261 Subpart C must be disposed onshore in accordance with RCRA, which may 

include additionally applicable state law requirements specific to the jurisdiction where the ash is 

landed. MARPOL Annex V specifies requirements for the disposal at sea of non-hazardous 

incinerator ash, which alternatively can be landed ashore. 

Some additional reported approaches available to large cruise ship lines to reduce solid waste 

discharges that specifically target the proper handling of plastics include the following (U.S. 

General Accounting Office, 2000; RCCL, 1998): 

 replacing disposable plastic and Styrofoam cups with reusable cups; 

 reducing paper and plastic wrapping; 

 replacing plastic condiment packages with bulk dispensers; 

 eliminating plastic garbage bag liners; 

 replacing disposable plastic plates and cutlery 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 laundry 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 natural materials and were mostly biodegradable. 

Now, much of the non-hazardous waste generated is either not easily 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 kilograms, which consists of food wastes, glass, 

plastics, paper, cans, cardboard, and wood. If cruise ships fail to properly store solid waste that 

is destined for off-loading to port 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 bottles, etc.), there is the 

potential for the introduction of plastics and other solid wastes from cruise ships into the marine 

environment. In such instances, the solid waste introduced into the marine environment becomes 

marine debris. According to NOAA, any persistent solid material that is manufactured or 

processed and directly or indirectly, intentionally 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 careless handling or disposal, intentional or unintentional release 

of materials or as a result of national disasters and storms (Sheavly, 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 containing plastics into any waters, there have been cases when 

unlawful discharges of solid waste and plastics have taken place. From 1993 through 1998, 

federal data indicate that foreign-flagged cruise ships were involved in 6 cases of confirmed 

illegal discharges of garbage or plastic (U.S. General Accounting Office, 2000). Solid waste that 

 5-10 
 December 29, 2008 

enters the ocean directly or indirectly can pose a threat to marine organisms, humans, coastal 

communities, and commercial industries. This marine 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 (especially the density) of the solid and whether the garbage is loose 

or bagged. According to the National Research Council (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 emulsified 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 float 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 being 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 Research Council, 1995). 

Regardless of how materials are predicted to flow in the ocean, wash ups of some types of 

marine debris on beaches seem to defy logical explanation (National Research Council, 1995). 

Not only can beach users be injured by pieces of glass, 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 estimated 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 include (National Research 

Council, 1995): 

 aesthetic degradation of surface waters and beach areas; 

 physical injuries to humans and life-threatening 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, turtles, 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 component 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 organic carbon, diminish water and sediment 

quality, adversely effect marine biota, increase turbidity, and elevate nutrient levels. Polglaze 

(2003) further states that food waste components may be detrimental to fish digestion and health, 

 5-11 
 December 29, 2008 

and have unsuitable nutrient content. Continued disposal of food wastes in restricted 

environments can cause nutrient pollution, if the water is not freely exchanged (Cruise Ship 

Environmental Task Force, 2003). Also, regular and sufficiently large inoculations of food 

waste to an area may cause ecological changes such as perturbations to species behavioral 

patterns and alternation to community species composition and diversity (Polglaze, 2003). An 

additional potential environmental impact of discharged food waste may be the inadvertent 

introduction of food associated plastics. To avoid an unintentional introduction of plastics with 

food wastes to the marine environment, it is critical 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/graywater residuals (e.g., graywater screening solids, 

sewage/graywater screening solids, and sewage/graywater waste biosludge). The International 

Maritime Organization (IMO) guidelines for Annex V implementation recognize the potential 

for air pollution associated with incinerator use and therefore discourage the use of incinerators 

in ports in or near urban areas (Annex V, Appendix B, Section 5.4). The guidelines 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 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 guidelines 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, otherwise the following problems can result: 

 Depending on the type of plastic and conditions of combustion, some toxic gases can be 

generated in the exhaust stream, including vaporized hydrochloric 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 therefore not be discharged into the sea (Annex 

V, Appendix B, Section 5.4.6.2). 

Further, the Parliamentary Commission for the Environment (2003) states that a cruise ship solid 

waste incinerator may produce small amounts of polychlorinated biphenyls and polycyclic 

aromatic hydrocarbons. 

5.5 What action is the federal government taking to address solid waste from cruise ships? 

The Interagency Marine Debris Coordinating Committee, a federal 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 ocean and coastal environment), 

including debris from vessels such as cruise ships. The group provided recommendations for 

research priorities, educational programs, monitoring techniques, and federal agency action in a 

Report to Congress in 2008. This report is required by section 5(c) of the Marine Debris 

Research, Prevention, and Reduction Act (Pub. L. 109-449). 

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According to the IMO (2007), the United Nations General Assembly invited IMO to review 

MARPOL Annex V, in consultation with relevant organizations and bodies, to assess the 

Annex’s effectiveness in addressing sea-based sources of marine debris. Comprehensive review 

of MARPOL Annex V began in February 2006 with the formation of a correspondence group. 

The U.S. Government has been an active participant 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 inspection 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 nearly 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 investigated 7,424 facility deficiencies in calendar 

year 2006, including reception facility deficiencies (up from 2,587 in calendar year 2000). From 

the time period between 2002 and 2006, the Coast Guard has documented a 26% reduction in the 

number of pollution incidents reported at facilities, which demonstrates the Coast Guard’s 

continuing commitment to vigorous implementation of the pollution prevention and 

environmental stewardship missions which have been entrusted to the Coast Guard by Congress. 

This includes the administration of the COA program 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 standardize both Advance Notice Forms generated by 

vessels with respect to their reception facility needs for all wastes 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 2004) 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 regulations, as well as the Coast Guard instructions 

that provide guidance to its field 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 been received and investigated in 2007). Coast 

Guard inspectors will be able to compare Advance Notice records with reception facility receipts 

(which are required to be kept with the vessel garbage log book for a period of two years under 

Section 4.2 of the Appendix to MARPOL Annex V, 2006 Consolidated Edition). Presently, 

reports of inadequate reception facilities are 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 concession contracts. The NPS has jurisdiction 

over the submerged lands and marine waters of Glacier Bay National Park up to 3 miles from the 

mean high tide line and including all of Glacier Bay proper. Glacier Bay is a well known, very 

popular attraction for the cruise ship industry in Alaska. Recent environmental reviews and 

decisions allow up to two cruise ship entries per day into Glacier Bay proper during the primary 

 5-13 
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visitor season. Cruise ship operations in the park are authorized under concession contracts, 

which are awarded under a competitive solicitation and prospectus process. Impact on park 

resources is a general standard selection criterion for park concessions. The NPS uses waste 

stream management as one of a number of selection criteria in this regard. In the past, cruise 

ship operators have usually proposed to minimize 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. Cruise 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 received 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 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. 

Prevention & Reduction 

 Increase use and range of on-board garbage handling and treatment technologies (e.g., 

compactors, pulpers, shredders, and incinerators). 

 Resolve issues that may be impeding safe waste storage and expanded use of compactors 

and incinerators.

 Improve infrastructure to assist in recycling of all glass, paper, 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 practices (further information is available at 

http://www.epa.gov/wastewise/about/overview.htm and 

http://www.epa.gov/osw/conserve/rrr/rogo/index.htm).

 Employ waste reduction for waste materials and plastics by reducing the amount of 

plastics and other packaging materials brought onboard. 

 Increase efforts to buy in bulk and choose products with less packaging. 

Control: Discharge Standards 

 Expand training for employees regarding waste segregation requirements by including 

the legal and environmental basis for those requirements. 

 Post waste segregation requirements (along with the associated the legal and 

environmental concerns) onboard (via placards and written information) for employees 

and passengers. 

 Initiate rulemaking to provide for stronger waste management plans than the current 

cruise industry practices in order to control solid waste discharges from cruise ships into 

all U.S. waters. 

 5-14 
 December 29, 2008 

 Include adequate port reception facilities as a component of a comprehensive vessel 

garbage management system, and establish a fee system to encourage 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 recyclables only at ports with recycling facilities.

 Establish accountability for both vessel operators and port operators with 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 waste disposal regulations for hospital wastes. 

 Require an analysis and accounting of the contaminants typically found in cruise ship 

incinerator ash to determine whether each batch of ash generated should be categorized 

as a solid waste or hazardous waste to then be managed accordingly. 

 Require standardized incinerator ash testing before each overboard discharge. 

 Establish performance standards for onboard incinerators 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 exist in foreign ports. 

 Expand all port reception facilities to accept solid waste. 

 Require that wherever cruise ships call, receiving ports provide reception facilities for 

solid waste off-loading and have established waste reception plans.

 Prohibit the use of incinerators while in port.

 Require that cruise ships off-load 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 incinerator 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 sanctions for noncompliance, and forwarding noncompliance data to the vessel’s next port of call. 

 5-15 
 December 29, 2008 

Enforcement & Compliance Assurance: Reporting 

 Require that ports provide receipts for garbage off-loaded to their reception facilities; 

compare the receipts to vessel garbage logs for inconsistencies. 

 Assess the need for increased recording/logging of garbage generation onboard cruise 

ships. 

 Require that cruise ships maintain certified 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 citizens to report illegal garbage disposal 

(e.g., passengers on cruise ships who observe any 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 reporting 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 sensitive areas of the 

marine environment under U.S. jurisdiction.

 5-16 
 December 29, 2008 

References 

Alaska Department of Environmental Conservation (ADEC). 2000. Alaska Cruise Ship Initiative 

Part 1 Final Report. Juneau, AK. 

(www.dec.state.ak.us/water/cruise_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/cruise_ships/pdfs/acsireport2.pdf) 

Alaska Department 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/impactofcruiseship.pdf) 

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

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

Center for Environmental Leadership 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). Washington, DC. 

(www.ncseonline.org/NLE/CRSreports/07Jul/RL32450.pdf) 

Cruise Lines International Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry 

Waste Management Practices and Procedures. Fort Lauderdale, FL. 

(www.cruising.org/industry/PDF/CLIAWasteManagementAttachment.pdf and 

www.cruising.org/industry/PDF/CLIAWasteManagement.pdf) 

Cruise Ship Environmental Task Force. 2003. Report to the Legislature: Regulation of Large 

Passenger Vessels in California. 

(http://www.swrcb.ca.gov/publications_forms/publications/legislative/docs/2003/cruiseshiplegrpt.

pdf)

Environmental Resources Limited. 1991. Port Reception and Disposal Facilities for Garbage in 

the Wider Caribbean (Final Report). Prepared for the International Maritime 

Organization, the World Bank. London, England. 

International Maritime Organization (IMO). 2007. Prevention of Pollution by Garbage from 

Ships. London, England. (www.imo.org/Environment/mainframe.asp?topic_id=297) 

 5-17 
 December 29, 2008 

 5-18 

National Oceanic and Atmospheric Administration (NOAA). 2008. Marine Debris 101. 

(http://marinedebris.noaa.gov/marinedebris101/welcome.html) 

National Research Council (NRC). 2008. Tackling Marine Debris in the 21st 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 Commissioner for the Environment. ISBN: 

1-877274-23-2. (http://www.pce.govt.nz/reports/allreports/1_877274_23_2.shtml) 

Polglaze, John. 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&_acct=C000001678&_vers

ion=1&_urlVersion=0&_userid=14684&md5=75901cf546aed19105a093695ad6388e)

Royal Caribbean Cruises Ltd. (RCCL). 1999. Save the Waves. Environmental Report.

Sheavly, S.B. 2007. National Marine Debris Monitoring Program: 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 Reference 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/OCPD/Marine/contents.html) 

U.S. Environmental Protection Agency. 2006. RCRA Orientation Manual 2006: Resource 

Conservation and Recovery Act. EPA530-R-06-003. 

(http://www.epa.gov/epaoswer/general/orientat/rom.pdf) 

U.S. General Accounting Office (GAO) (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. 
December 29, 2008 

Section 6: Hazardous Waste 

Hazardous waste is a subset of “solid waste,” and is a waste that contains hazardous constituents 

that can be liquid, solid, semisolid, or contained gas. On most cruise 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 hazardous waste Treatment, Storage, 

and Disposal Facility. 

This section discusses the current state of information about hazardous 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 subset of “solid waste.” The regulations 

implementing the Resource Conservation Recovery 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 hazardous waste lists (i.e., F-List, K-List, P-List, or 

U-List); or the solid waste exhibits at least one of four hazardous characteristics (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 applicable state and federal 

regulations regarding its management. Hazardous wastes 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, semisolid, or contained gas. The universe of wastes generated as a 

result of daily cruise ship activities is diverse as well. Cruise ship activities such as photo 

processing, dry cleaning, and equipment 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 incinerator ash, fluorescent and mercury 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 are, or may be, hazardous. This is only a list of 

typical wastes, and ultimately it is the responsibility of the person generating the waste (i.e., ship 

owner and/or operator) to make this determination and to comply with all applicable 

environmental requirements. 

 6-1 
December 29, 2008 

Table 6-1. Types of Potentially Hazardous 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 materials recycled to recover economically 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 solvent 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 materials 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/hazwaste/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, rechargeable, and usually six-celled typically 

contain a sponge lead anode, a lead dioxide 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 considered hazardous waste under federal 

regulations, some alkaline batteries might be defined as hazardous waste under some 

authorized states’ more stringent (or broader 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 hazardous waste (ADEC, 2002). 

Sources: ADEC, 2000 and ADEC, 2002 

 6-2 
December 29, 2008 

Limited information is available on the amount of hazardous waste that a cruise ship might 

generate. Table 6-2 presents estimates of the hazardous waste generated in one week by the 

Holland America Lines fleet, consisting 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 the 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 reported replacing hazardous chemicals with non-hazardous ones, and 

implementing procedures to improve the collection and disposal of waste from hazardous 

materials that cannot be replaced and must still be used. Table 6-3 presents more current 

estimates of waste measured across all of Carnival Corporation’s operating lines and ships 

according to their reports. 

Table 6-2. Estimates of Hazardous Waste 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/week1

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. 

 

 6-3 
December 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 Lines, the “at sea” or “incinerated waste” is 

discharged/disposed in accordance with MARPOL and applicable laws and regulations; plastic is 

not disposed at sea. Incinerated waste includes dry garbage, food waste, and sludge. 

In 2003, the California Environmental Protection Agency (Cal/EPA) convened a multi-agency 

Cruise Ship Environmental Task Force to evaluate 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 the California legislature. Regarding hazardous 

waste implementation issues, the Task Force highlighted the differences between stationary 

hazardous waste generators operating in California, and cruise ships that can operate in 

California but also off-load hazardous waste in other 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 cruise 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 information 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 subject 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 into 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 other floating craft.” Under 

CWA section 502(12)(b), the requirement for an NPDES permit applies to the addition of any 

pollutant from any point source “other 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 applicability of RCRA; dissolved and solid materials in industrial 

 6-4 
December 29, 2008 

discharges which are point sources subject to NPDES permits are not “solid waste” under the 

RCRA statute and thus not “hazardous waste.” This only applies to materials once they have 

been discharged. Prior to being discharged pursuant to an NPDES permit, wastes remain subject 

to RCRA if they are hazardous wastes. 

 

Section 311 of the CWA also prohibits the discharge of oil or hazardous substances into or upon 

the navigable waters of the United States, adjoining 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 natural resources belonging to, appertaining to, or 

under the exclusive management authority 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 these 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 requires 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 from routine maintenance such as cleaning and 

painting, to passenger services such as dry cleaning, beauty parlors, and photography labs. Thus, 

cruise ships or passenger service facilities within cruise ships may be subject to RCRA 

requirements. Issues the cruise ship industry may face relating to RCRA include ensuring the 

hazardous waste identification is made at the point at which a hazardous waste is considered 

generated; ensuring that parties are properly identified as generators, 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, among other things, defines and 

regulates solid waste and hazardous waste. RCRA is designed to minimize the hazards of waste 

disposal; conserve resources through waste recycling, recovery, and reduction; and ensure waste 

management practices that are protective 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 hazardous waste. EPA regulation (40 CFR 260.10) defines a generator 

to mean any person, by site, whose act or process produces hazardous waste, or whose act first 

causes a hazardous waste to become subject to regulation. 

 

1

 In states with hazardous waste programs authorized by EPA, the authorized state hazardous 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. 

 6-5 
December 29, 2008 

As stated previously, the RCRA regulations contain criteria for identifying 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, reactivity, 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 waste is identified as a hazardous waste, any person 

who generates or manages the hazardous waste must comply with all applicable federal 

regulations regarding its handling and management. 

Hazardous waste generators are regulated based on the amount of hazardous waste produced 

each month. Table 6-4 shows that generators are divided into three categories: large quantity 

generators (LQGs); small quantity generators (SQGs); and conditionally exempt small quantity 

generators (CESQGs). LQGs are facilities that generate greater 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 subject to significantly reduced requirements for 

managing hazardous waste. Generators are classified 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, waste, 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 basis, 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 change, the generator is required to comply with 

the applicable regulatory requirements for that class of generators for the hazardous waste 

generated in that particular month. For example, if a generator has reached LQG status in a 

particular month, then biennial reporting is required, and all 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 regulations are specific to each generator type. EPA 

regulations (40 CFR 261.5(c) and (d)) specify the types of hazardous 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 includes 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 regulation (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 Research Service (2007), the generator classification 

assigned to individual cruise ships is often unclear. However, once a cruise ship has determined 

its appropriate generator classification, the cruise ship must follow the appropriate accumulation 

requirements. 

 6-6 
December 29, 2008 

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 Number” 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 shipment (40 CFR 262, Subpart C); and comply with 

record-keeping and reporting requirements (40 CFR 262, Subpart D). The identification number 

is used to identify a generator and to track waste activities, as well as to provide increased 

coordination between the Coast Guard, EPA, and states. The number remains with a vessel, and 

is used on all hazardous waste manifests, regardless 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 store, treat, or dispose of the hazardous waste (for 

more information on the Hazardous Waste Manifest System, see 

http://www.epa.gov/epaoswer/hazwaste/gener/manifest/). The system enables waste generators 

to verify that their waste has been properly delivered, and that no waste has been lost or 

unaccounted for in the process (40 CFR 262, Subpart B). 

EPA’s RCRA regulations (40 CFR 273) also specify that a number of the hazardous wastes 

generated aboard cruise ships may be treated as Universal Wastes under the Universal Waste 

Program. The Universal Waste Program was developed under RCRA to streamline collection 

requirements for certain widely-generated hazardous wastes to promote waste recycling, and to 

ease the regulatory burden associated with handling, transportation, and collection. Waste 

considered to be “widely-generated” includes batteries, pesticides, mercury-containing 

 6-7 
December 29, 2008 

equipment, and lamps with hazardous components (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 notification, labeling, marking, employee training, responses to 

releases, offsite shipments, tracking, 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 release 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 vessel or facility in quantities 

equal to or greater than those determined pursuant to CERCLA section 9602, immediately notify 

the National Response Center of such release. The National Response Center conveys the 

notification expeditiously to all appropriate government agencies. While the universe of 

CERCLA hazardous substances is larger than 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 historical vessels, or unique 

habitats, from degradation while facilitating public or private uses compatible with resource 

protection.

NMSA authorizes the National Oceanic and Atmospheric Administration (NOAA) to designate 

as National Marine Sanctuaries areas of the marine environment that have special aesthetic, 

ecological, historical, or recreational qualities, and to provide comprehensive and coordinated 

conservation management for such areas. The National Marine Sanctuary Program manages 13 

sanctuaries and the Papahānaumokuākea Marine National Monument (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 regulations for NMSA, discharging hazardous waste is prohibited at all 

sites except for the Thunder Bay and the Hawaiian Islands Humpback Whale National Marine 

Sanctuaries, where such discharges are prohibited under other legislation or regulation.

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December 29, 2008 

6.3 What practices are available to manage hazardous wastes generated on cruise ships? 

Among the previously noted Cruise Lines International Association (CLIA) environmental 

standards, those applicable to hazardous wastes consist of programs for waste minimization, 

waste reuse and recycling, and waste stream management for incorporation into the Safety 

Management Systems (see Section 1.5). Specifically, a 2006 update to the CLIA environmental 

standards describes revised practices and procedures for the management of the following: photo 

processing wastes, including x-ray development fluid wastes; dry-cleaning waste fluids and 

contaminated materials; print shop waste fluids; photo copying and laser printer cartridges; 

unused and outdated pharmaceuticals; spent fluorescent 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 Environmental Task Force (2003), the information that 

CLIA and individual cruise ships reported regarding hazardous waste treatment onboard consists 

of the following: 

 Incineration/burning of used oil, oily sludge, medical and bio-hazardous waste, and 

outdated pharmaceuticals; 

 Aerosol can crushing and the collection of liquids from the aerosol cans; 

 Silver recovery from photo and x-ray processing; 

 Crushing and sieving of spent fluorescent and mercury vapor bulbs; and 

 Separation of oil and water mixtures. 

In some cases, the cruise ship industry is installing new technologies and design features to 

minimize hazardous waste generation (ADEC, 2000): 

 Effective and efficient digital photo technology to reduce hazardous waste stream 

generation during photo processing; 

 Use of non-toxic printing ink and non-chlorinated solvents and other non-hazardous 

products to eliminate hazardous wastes in print shops; and 

 Alternative dry cleaning processes such as CO2 and wet (i.e., a water-based alternative to 

dry cleaning) processes. 

According to the CLIA environmental standards, member lines have agreed to reduce the 

production of incinerator ash by minimizing the generation of waste and maximizing recycling 

opportunities. CLIA further notes that incorporating waste stream segregation practices should 

prevent the introduction of hazardous materials to the incinerator, thereby directing the use of 

onboard incinerators primarily for food waste, contaminated cardboard, some plastics, trash, and 

wood. According to the CLIA environmental standards, non-hazardous ash is disposed of at sea 

in accordance with MARPOL Annex V. If any ash is identified as being hazardous, it is 

disposed ashore in accordance with RCRA. The CLIA environmental standards provide for 

testing of incinerator ash at least once quarterly for the first year of operation (in order to 

establish a baseline), and subsequent annual testing. (CLIA, 2006). 

Cruise ships are also directing efforts to hazardous waste collection and storage prior to offloading for disposal ashore. For hazardous materials that cannot be re-used and/or recycled, the 

 6-9 
December 29, 2008 

CLIA environmental standards provide that hazardous 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 reported that hazardous waste from photo labs, dry 

cleaning operations, and other sources are collected, stored in separate 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 hazardous waste, and in some instances observed 

the equipment for collecting hazardous wastes 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 disposal facilities are critical. 

Additional wastes stored until offloaded ashore for proper disposal are used fuel/oil filters. The 

Task Force reported that cruise lines 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 dump.” Cruise lines further indicated that the 

engine lubrication system uses oil filters to screen out particulate matter, with the treatment of 

the used oil filters to be the same as that for the fuel filters just mentioned (Cruise Ship 

Environmental Task Force, 2003). 

6.4 What are the potential environmental impacts 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 chemical and toxicological characteristics of the 

particular waste released. Although the Cruise Ship 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 environment than a release far from 

shore where dilution effects are more efficient (Cruise Ship Environmental Task Force, 2003). 

There are a number of possible hazardous waste streams produced on cruise ships, including 

perchloroethylene, silver, mercury, hydrocarbons, heavy metals, and corrosives, that could enter 

the environment and cause harm if not appropriately managed as required under RCRA. 

When hazardous waste generated aboard cruise ships is properly identified, stored, and treated 

and/or disposed onshore, the risk posed to the marine environment is normally minimized. 

Hazardous wastes should be properly stored and segregated 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 education, and periodic 

ash testing. To ensure hazardous waste is handled and disposed of properly, adequate 

operational procedures and employee training and, in some instances, passenger training (e.g., 

 6-10 
December 29, 2008 

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 incineration. If passenger and crew education efforts regarding waste 

management and waste segregation are not effective, waste materials that are hazardous (or 

otherwise contain hazardous constituents) may be comingled and then incinerated with solid 

wastes, and in some cases, cause the resulting incinerator ash to be hazardous. The IMO 

guidelines for Annex V implementation recognize the potential for air pollution associated with 

incinerator use, and therefore discourage the use of incinerators in ports in or near urban areas 

(Annex V, Appendix B, Section 5.4). The guidelines 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 air pollution regulations imposed in certain harbors (Annex V, 

Appendix B, Section 5.4.5). 

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 guidelines suggest that the 

incineration of plastic wastes complying with Annex V are to take place 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 combustion, some toxic gases can be 

generated in the exhaust stream, including vaporized hydrochloric 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 therefore not be discharged into the sea (Annex 

V, Appendix B, Section 5.4.6.2). 

Further, the Parliamentary Commission for the Environment (2003) states that a cruise ship solid 

waste incinerator may produce small amounts of polychlorinated biphenyls and polycyclic 

aromatic hydrocarbons. 

6.5 What action is the federal government taking 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 develop a system whereby an EPA hazardous waste 

identification (ID) number is assigned 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 individual cruise ships to be assigned a single 

 6-11 
December 29, 2008 

EPA hazardous waste identification number for the purposes of identification 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 its 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 office issues a hazardous waste identification 

number for the cruise ship. The number reflects 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 affect the applicability of state-specific RCRA 

requirements; cruise ships must still comply with each state’s RCRA requirements when offloading hazardous waste, regardless 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 concession contracts. The NPS has jurisdiction 

over the submerged lands and marine waters of Glacier Bay National Park up to 3 miles from the 

mean high tide line and including all of Glacier Bay proper. Glacier Bay is a well known, very 

popular attraction for the cruise ship industry in Alaska. Recent environmental reviews and 

decisions allow up to two cruise ship entries per day into Glacier Bay proper during the primary 

visitor season. Cruise ship operations in the park are authorized under concession contracts, 

which are awarded under a competitive solicitation and prospectus process. Impact on park 

resources is a general standard selection criterion for park concessions. The NPS uses waste 

stream management as one of a number of selection criteria in this regard. In the past, cruise 

ship operators have usually proposed to minimize the impact of waste streams by committing to 

a no-discharge policy while in the park (even when discharge is 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. 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 received 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 any 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 legal authority to implement that option. 

 6-12 
December 29, 2008 

Prevention & Reduction 

 Establish standards or best management practices 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 waste storage and expanded use of incinerators. 

 Foster cruise ship industry hazardous waste minimization programs. 

 Provide education and outreach to the cruise 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 well 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 more stringent state provisions should be 

enacted. 

 Ensure that the handling and disposal of batteries, special chemicals, etc., are done in 

accordance with state solid waste regulations. 

 Expand training for employees regarding waste 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 the discharge of any hazardous materials or 

materials with hazardous characteristics 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 mandatory incinerator ash testing program to determine whether each batch of 

incinerator ash is hazardous and proceed with disposal accordingly. 

 Develop a means to track the path of all onboard generated hazardous wastes for all states 

and foreign ports. 

 6-13 
December 29, 2008 

Enforcement & Compliance Assurance: Reporting 

 Include in the mandatory incinerator ash testing program maintenance of a certified log 

book documenting test results, dates, volumes, and 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 requirements 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 comprehensive 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 United 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 Agencies, 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 identify if additional regulations 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 sensitive areas of the 

marine environment under U.S. jurisdiction. 

 6-14 
December 29, 2008 

 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/cruise_ships/pdfs/finreportp10808.pdf) 

Alaska Department 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/impactofcruiseship.pdf) 

Carnival Corporation & PLC. 2006. Environmental Management Report: Fiscal Year 2006. 

(http://phx.corporate-ir.net/phoenix.zhtml?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 International Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry 

Waste Management Practices and Procedures. Fort Lauderdale, FL. 

(www.cruising.org/industry/PDF/CLIAWasteManagementAttachment.pdf and 

www.cruising.org/industry/PDF/CLIAWasteManagement.pdf) 

Cruise Ship Environmental Task Force. 2003. Report to the Legislature: Regulation of Large 

Passenger Vessels in California. 

(http://www.swrcb.ca.gov/publications_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. Environmental 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 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. 
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 International 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 

7-1 
DOC . . . . . . . . . . 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 

7-2 
NH3 . . . . . . . . . . . . unionized ammonia 

NH4

+

 . . . . . . . . . . . . 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 

7-3 
TOC . . . . . . . . . . . . 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 

7-4 
7-5 

Appendix B. State Efforts to Address Discharges from Cruise Ships 

The Cruise Ship Discharge Assessment Report (Assessment Report) presents on-going actions 

by the federal government to address five primary waste streams from cruise ships (sewage, 

graywater, oily bilge water, solid waste, and hazardous waste). Based on the public comments 

received on the draft of the report, as well as other information gathered, a wide range of options 

and alternatives is listed for each abovementioned waste stream. Identification of any particular 

option does not imply 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 legal authority to implement 

that option. Nevertheless, the range of options and alternatives presented in this Assessment 

Report may be useful to government entities such as state, local, and tribal entities that are 

interested in addressing cruise ship waste streams. 

There are a number of states (Alaska, California, Florida, Hawaii, Maine, and Washington), as 

well as Native American Tribes, that have on-going efforts to address the frequency of cruise 

ship traffic and the range of issues associated with discharges from these vessels. Some states 

have taken action independent of federal requirements by passing legislation controlling cruise 

ship discharges, creating industry 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 treated or not) is prohibited. Listed below are some 

links to access current state efforts. 

State General Information Regarding Cruise Ship Efforts 

Connecticut http://www.ctcruiseship.com/ 

Florida http://www.dep.state.fl.us/secretary/news/2000/00-MOUcruise.htm 

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/rule/history.htm 

http://www.state.me.us/dep/blwq/topic/vessel/LCPV/index.htm 

Maine 

http://www.barharbormaine.gov/xhtml/171/Permalink/363/ 

Washington http://www.ecy.wa.gov/programs/wq/wastewater/cruise_mou/index.html 
December 29, 2008 

EPA842-R-07-005