Cruise Ship Pollution

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CRUISE SHIP POLLUTION

No part of this digital document may be reproduced, stored in a retrieval system or transmitted in any form or by any means. The publisher has taken reasonable care in the preparation of this digital document, but makes no expressed or implied warranty of any kind and assumes no responsibility for any errors or omissions. No liability is assumed for incidental or consequential damages in connection with or arising out of information contained herein. This digital document is sold with the clear understanding that the publisher is not engaged in rendering legal, medical or any other professional services.

CRUISE SHIP POLLUTION

OLIVER G. KRENSHAW EDITOR

Nova Science Publishers, Inc. New York

Copyright © 2009 by Nova Science Publishers, Inc. All rights reserved. No part of this book may be reproduced, stored in a retrieval system or transmitted in any form or by any means: electronic, electrostatic, magnetic, tape, mechanical photocopying, recording or otherwise without the written permission of the Publisher. For permission to use material from this book please contact us: Telephone 631-231-7269; Fax 631-231-8175 Web Site: http://www.novapublishers.com NOTICE TO THE READER The Publisher has taken reasonable care in the preparation of this book, but makes no expressed or implied warranty of any kind and assumes no responsibility for any errors or omissions. No liability is assumed for incidental or consequential damages in connection with or arising out of information contained in this book. The Publisher shall not be liable for any special, consequential, or exemplary damages resulting, in whole or in part, from the readers’ use of, or reliance upon, this material. Independent verification should be sought for any data, advice or recommendations contained in this book. In addition, no responsibility is assumed by the publisher for any injury and/or damage to persons or property arising from any methods, products, instructions, ideas or otherwise contained in this publication. This publication is designed to provide accurate and authoritative information with regard to the subject matter covered herein. It is sold with the clear understanding that the Publisher is not engaged in rendering legal or any other professional services. If legal or any other expert assistance is required, the services of a competent person should be sought. FROM A DECLARATION OF PARTICIPANTS JOINTLY ADOPTED BY A COMMITTEE OF THE AMERICAN BAR ASSOCIATION AND A COMMITTEE OF PUBLISHERS. LIBRARY OF CONGRESS CATALOGING-IN-PUBLICATION DATA Available upon request ISBN: 978-1-61728-215-7 (E-Book)

Published by Nova Science Publishers, Inc. New York

CONTENTS Preface

vii

Chapter 1

Draft Cruise Ship Discharge Assessment Report United States Environmental Protection Agency

Chapter 2

Cruise Ship Pollution: Background, Laws and Regulations, and Key Issues Claudia Copeland

Index

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143 177

PREFACE The cruise industry is a significant and growing contributor to the U.S. economy, providing more than $32 billion in benefits annually and generating more than 330,000 U.S. jobs, but also making the environmental impacts of its activities an issue to many. Although cruise ships represent a small fraction of the entire shipping industry worldwide, public attention to their environmental impacts comes in part from the fact that cruise ships are highly visible and in part because of the industry’s desire to promote a positive image. Cruise ships carrying several thousand passengers and crew have been compared to “floating cities,” and the volume of wastes that they produce is comparably large, consisting of sewage; wastewater from sinks, showers, and galleys (graywater); hazardous wastes; solid waste; oily bilge water; ballast water; and air pollution. The waste streams generated by cruise ships are governed by a number of international protocols (especially MARPOL) and U.S. domestic laws (including the Clean Water Act and the Act to Prevent Pollution from Ships), regulations, and standards, but there is no single law or rule. Some cruise ship waste streams appear to be well regulated, such as solid wastes (garbage and plastics) and bilge water. But there is overlap of some areas, and there are gaps in others. Some, such as graywater and ballast water, are not regulated (except in the Great Lakes), and concern is increasing about the impacts of these discharges on public health and the environment. In other areas, regulations apply, but critics argue that they are not stringent enough to address the problem — for example, with respect to standards for sewage discharges. Environmental advocates have raised concerns about the adequacy of existing laws for managing these wastes, and they contend that enforcement is weak. In 2000, Congress enacted legislation restricting cruise ship discharges in U.S. navigable waters within the state of Alaska. California, Alaska, and Maine

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Preface

have enacted state-specific laws concerning cruise ship pollution, and a few other states have entered into voluntary agreements with industry to address management of cruise ship discharges. Meanwhile, the cruise industry has voluntarily undertaken initiatives to improve pollution prevention, by adopting waste management guidelines and procedures and researching new technologies. Concerns about cruise ship pollution raise issues for Congress in three broad areas: adequacy of laws and regulations, research needs, and oversight and enforcement of existing requirements. Legislation to regulate cruise ship discharges of sewage, graywater, and bilge water nationally has been introduced in the 110th Congress (S. 2881). This book describes the several types of waste streams that cruise ships may discharge and emit. It identifies the complex body of international and domestic laws that address pollution from cruise ships. It then describes federal and state legislative activity concerning cruise ships in Alaskan waters and activities in a few other states, as well as current industry initiatives to manage cruise ship pollution. Chapter 1 - 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. Chapter 2 - The cruise industry is a significant and growing contributor to the U.S. economy, providing more than $32 billion in benefits annually and generating more than 330,000 U.S. jobs, but also making the environmental impacts of its activities an issue to many. Although cruise ships represent a small fraction of the entire shipping industry worldwide, public attention to their environmental impacts comes in part from the fact that cruise ships are highly visible and in part because of the industry’s desire to promote a positive image.

In: Cruise Ship Pollution Editor: Oliver G. Krenshaw

ISBN 978-1-60692-655-0 © 2009 Nova Science Publishers, Inc.

Chapter 1

DRAFT CRUISE SHIP DISCHARGE ASSESSMENT REPORT United States Environmental Protection Agency 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 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). As the cruise industry continues to expand, there is an increasing concern about the impacts cruise ships may have on water quality. 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

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United States Environmental Protection Agency

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. This Draft Cruise Ship Discharge Assessment Report (Draft Report) responds in part to the petition from Bluewater Network. The Draft Report examines five primary cruise ship waste streams—sewage, graywater, oily bilge water, solid waste, and hazardous waste. For each waste stream, the Draft 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; and (5) actions by the federal government to address the waste stream. The most significant new analysis provided in this Draft 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 Draft 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), as well as air pollution. This Draft Report does not present an assessment of any of these other waste streams. However, as part of a separate effort, EPA has begun an administrative process to prepare for regulation of discharges incidental to the normal operation of a vessel that, as of September 30, 2008, will no longer be excluded from Clean Water Act permitting requirements by virtue of a recent Court decision, which vacated the EPA regulation that had excluded these discharges from those requirements (see 72 FR 34241, June 21, 2007; notice of intent; request for comments and information). In addition, under the Clean Air Act, EPA established emissions standards for nitrous oxides (NOx) from "Category 3" marine diesel engines, which are very large marine engines used

Draft Cruise Ship Discharge Assessment Report

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primarily for propulsion power on ocean-going vessels such as container ships, tankers, bulk carriers, and cruise ships (68 FR 9746, 9747, Feb. 28, 2003). EPA promulgated those regulations in 40 CFR Part 94. Recently, EPA solicited public comment on the scope of the rules that EPA should propose for a second tier for Category 3 engines (72 FR 69522, Dec. 7, 2007). Finally, EPA has proposed regulations to establish more stringent standards for particulate matter, NOx, and hydrocarbons from Category 2 marine engines (72 FR 15938, April 3, 2007).

1.2. Other EPA Cruise Ship Efforts In addition to developing this Draft 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 U.S. 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), 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 and 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 sewage or graywater discharge plumes behave as predicted by a model developed for Alaska waters. The Cruise Ship Plume Tracking Survey Report can

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be accessed at: www.epa.gov/owow/oceans/cruise_ships/plumerpt2002/plume report.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 urged the Agency’s Regions to 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 ships that operated in Alaska during the


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summer 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 2008. Much of the information and data collected for EPA’s effort under Title XIV are summarized in this Draft Report. 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. Cruise Ship Industry Efforts to Reduce Potential Environmental Impacts The Cruise Lines International Association (CLIA) was formed in 1975 to promote the benefits of cruising. In 2006, CLIA merged with the International Council of Cruise Lines (ICCL), a sister entity created in 1990 to participate in the regulatory and policy development process on behalf of the cruise industry. According to CLIA, it is now the world's largest cruise association, composed of 24 of the major cruise lines serving North America and representing 97% of the cruise capacity marketed from North America. CLIA operates pursuant to an agreement filed with the Federal Maritime Commission under the Shipping Act of 1984 and serves as a non governmental consultative organization to the International Maritime Organization. CLIA members have agreed to adopt mandatory environmental standards for all of their member line cruise ships. Compliance with these standards is a condition of membership in CLIA. All CLIA member cruise ship operators must implement the adopted standards, which address, among others, the following

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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, aluminum and steel cans. Each CLIA member line operating internationally under the Safety of Life at Sea (SOLAS) Convention (a major international convention dealing with maritime safety that covers a wide range of measures to improve vessel safety including design, construction, and equipment standards) has agreed to integrate these industry standards into its Safety Management System (SMS), which is required by the International Safety Management (ISM) Code (a component of SOLAS). CLIA member lines are thus subject to the internal and external audits mandated by the ISM code. SMS Plans frequently employ the use of third party verification companies (also known as classification societies) such as Det Norske Veritas, Lloyds Register, and American Bureau of Shipping to certify compliance with ISM standards. Oversight for compliance with ISM requirements is carried out through ISM audits by the classification societies and by inspections by the flag states and the U.S. Coast Guard. For U.S. flagged cruise vessels that are not required to have SOLAS certificates but who are CLIA members (i.e., a small number of very small river cruisers and coastal operators), the U.S. Coast Guard has direct oversight and inspection authority. Further, CLIA member lines falling into this category have included the industry standards in their company safety management system and undertake equivalent auditing measures as well. In addition, CLIA member cruise lines have committed to these principles (CLIA, 2006): • • •

•

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) and equivalent US laws and regulations, 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 even smaller quantities of waste products ashore;

Draft Cruise Ship Discharge Assessment Report •

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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 International Safety Management Code for the Safe Operation of Ships and for Pollution Prevention (ISM Code).

REFERENCES Bell, Tom. 2007 (September 28). Experts: Mega-berth needed for cruise ships. Portland Press Herald. (www.pressherald.mainetoday.com/story_pf.php?id=137059andac=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 Line International Association (CLIA). 2006. CLIA Industry Standard: Cruise Industry Waste Management Practices and Procedures. Fort Lauderdale, FL. (www.cruising.org/industry/PDF/CLIAWasteManagement Attachment.pdf and www.cruising.org/industry/PDF/CLIAWaste Manage ment.pdf)

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. On some cruise ships, especially many of those traveling to Alaska, sewage and often graywater are treated using Advanced Wastewater Treatment systems that 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

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pollutants, the potential environmental impacts of cruise ship sewage discharges, and federal actions taken to address 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.

Figure 2.1. Per Capita Sewage Generation as Reported in EPA’s 2004 Cruise Ship Survey.


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Figure 2.2. Sewage Generation by Persons Onboard as Reported in EPA’s 2004 Cruise Ship Survey.

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. EPA is not able to independently confirm the accuracy of these estimated rates. 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 22). During EPA’s 2004 sampling of four ships with Advanced Wastewater Treatment systems (AWTs), sewage generation was measured on one ship at 17 gal/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 wastewater treatment sludge, if any, that is removed during wastewater treatment (see subsection 2.3.3 below). Cruise ship capacity to hold untreated 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.

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2.2. What 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, including the territorial seas. CWA section 312 also establishes procedures for the designation of no-discharge zones for vessel sewage. Section 312 is implemented jointly by EPA and the Coast Guard. EPA is responsible for developing performance standards for MSDs and working with states to establish nodischarge zones. The Coast Guard is 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). The Coast Guard and states are vested with authority to enforce the requirements of 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 penalties of up to $5,000 and $2,000, respectively, for each violation. 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 31 2(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 millimeters 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 devices 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


•

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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. However, a Type II MSD may serve as a Type III MSD if the vessel maintains all waste products onboard the vessel and transfers to a shore-side facility or discharges at least three nautical miles offshore.

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, foreign- flagged vessels may use MSDs that have received a compliance test certificate under Annex IV of MARPOL (discussed below). The Coast Guard does not test the effluent from certified MSDs once installed onboard a vessel (except in Alaska under Title XIV; see subsection 2.2.3 below).

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 65 NDZs in the United States covering 113 waterbodies; 62 of these NDZs were established by states.

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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 (also known as MARPOL). Annex IV defines sewage as “drainage from medical premises, toilets, urinals, spaces containing live animals and other waste waters when mixed with sewage waste streams.” Although Annex IV was adopted in 1973, the Annex 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 1 August 2005. Annex IV applies to countries that are a party to the Annex, and all vessels operating under their flags. It generally requires ships to be equipped with either a sewage treatment plant, a sewage comminuting and disinfecting system, or a sewage holding tank. Within three miles of shore, Annex IV requires that sewage discharges be treated by a certified MSD prior to discharge. Sewage discharges made between three and 12 miles of shore must be treated by no less than maceration and chlorination, and sewage discharges beyond 12 miles from shore are unrestricted. In addition, this Annex establishes certain sewage reception facility standards and responsibilities for ports of contracting parties. Annex IV also establishes a model International Sewage Pollution Prevention Certificate. Vessel certification requires that a vessel install (1) a sewage treatment unit that meets IMO standards (MEPC.2(VI), Recommendation on International Effluent Standards and Guidelines for Performance Tests for Sewage Treatment Plants), (2) a holding tank with an established sewage holding capacity and a visual indicator of actual capacity, and (3) a pipeline to the vessel's exterior for sewage discharge into a reception facility at port. The United States is not a party to MARPOL Annex IV. Under Coast Guard policy, however, foreign-flagged vessels operating in the United States may use MSDs that have received a compliance test certificate under Annex IV of MARPOL. For vessels flagged in countries that are party to MARPOL Annex IV, the vessel owner and flag state have the responsibility to ensure that the vessel complies with MARPOL requirements (as well as the other safety and environmental protection requirements of international conventions). The Coast Guard’s responsibility is to verify that the vessel is in substantial compliance with the conventions, a determination that the Coast Guard makes if the treatment unit is in "good and serviceable condition." Because the majority of cruise ships are foreign-flagged, Annex IV certification remains an important aspect of cruise ship inspection activity in U.S. waters.


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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. 2763A315, 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/100ml and not more than 10% of the samples exceed 40 fecal coliforms/100ml) 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 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 marine sanitation devices (no more than 200 fecal coliforms per 100ml and no more than 150 milligrams total suspended solids per liter).

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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 also authorizes Alaska to petition EPA to establish nodischarge zones 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 2008. Much of the information and data collected for EPA’s effort under Title XIV are summarized in this report.

2.2.4. National Marine Sanctuaries Act The National Marine Sanctuaries Act (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, such as coral reefs, sunken historical vessels, or unique habitats, from degradation while facilitating public or private uses compatible with resource protection. The Act authorizes 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 Papahanaumokuakea Marine National Monument. Designated sanctuaries are managed according to site-specific management plans developed by NOAA that typically prohibit the discharge or deposit of most material. Discharges of graywater and treated vessel sewage, however, are sometimes


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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. The Act also provides for civil penalties for violations of its requirements or the permits issued under it.

2.3. How do Cruise Ships Treat Sewage? 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) marine sanitation device (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 members’ 130 ships (which make up twothirds of the world fleet) have installed AWTs, with 10 to 15 more systems added each year (Choi, 2007). 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). The remainder operated traditional Type II MSDs and held the treated sewage and untreated graywater in double-bottom ballast tanks for discharge outside Alaskan waters. 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 wastestream. 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.

16


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 (BOD5) 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).

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 Advanced Wastewater Treatment


17

systems. 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.) ACSI sampling was scheduled randomly at various ports of call on all major cruise routes in Alaska. Individual discharge samples characterized different 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 (TSS), biochemical oxygen demand (BOD5), chemical oxygen demand (COD), pH, fecal coliform, total residual chlorine (TRC), 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 TSS met the MSD standard of 150 mg/l, and only 1 blackwater sample out of 70 samples met both the TSS 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 and 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

18


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 Total Suspended Solids (mg/L)

Average Conc. (± SE) of Concentration in Untreated Cruise Ship Type II MSD Domestic Wastewater2 Effluent1 627 (±94.3) 100 to 350 (21 detects out of 21 samples)

Biochemical Oxygen Demand (5 Day) (mg/L)

133 (±15.2) 110 to 400 (21 detects out of 21 samples)

Chemical Oxygen Demand (mg/L)

1,040 (±27 1) (3 detects out of 3 samples)

pH

90.5% of the pH samples are between between 6.0 and 9.0 6.0 and 9.0 (21 detects out of 21 samples)

Total residual chlorine (jtg/L)

1,070* (±499) No data (12 detects out of 18 samples)

250 to 1,000

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 and 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 wastestream; 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.


19

Table 2.2. Traditional Type II MSD Effluent Concentrations–Metals Analyte

Average Conc. (± SE) of Cruise Ship Type II MSD Effluent'

Cadmium (Total) (gg/L)

0.0624* (±0.0205) (3 detects out of 24 samples)

Chromium (Total) (gg/L)


Copper (Total) (gg/L)

954* (±398) (19 detects out of 24 samples)

Lead (Total) (gg/L)


Mercury (Total) (gg/L)


Nickel (Total) (gg/L)


Silver (Total) (gg/L)


Zinc (Total) (gg/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 effluent for these 16 analytes. Some of the analytes in this table with the highest concentrations are chlorine byproducts, likely generated by sewage chlorination. Table 2.3. Traditional Type II MSD Effluent Concentrations–Volatile and Semivolatile Organics Analyte


1,2-Dichloroethane (gg/L)


1,4-Dichlorobenzene (gg/L)


Bis(2-ethylhexyl) phthalate (gg/L) Bromodichloromethane (gg/L)

2

3.45* (±0.837) (16 detects out of 21 samples) 33.7* (±12.7) (14 detects out of 21 samples)

Bromoform (gg/L) 2


Carbon tetrachloride (gg/L)


20


Table 2.3. Traditional Type II MSD Effluent Concentrations–Volatile and Semivolatile Organics (Continued) Analyte


Chloroform (gg/L) 2


Chloromethane (gg/L) Dibromochloromethane (gg/L)

24.4* (±12.9) (5 detects out of 22 samples) 2


Diethyl phthalate (gg/L)


Di-n-butyl phthalate (gg/L)


Ethylbenzene (gg/L)


Methylene chloride (gg/L)


Phenol (gg/L)


Tetrachloroethylene (jtg/L)


Toluene (jtg/L)

0.620* (±0.077 1) (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 Average Conc. (± SE) of Cruise Ship Concentration in Untreated Traditional Type II MSD Effluent' Domestic Wastewater2 Analyte Ammonia as 145 (±36.7) (21 detects out of 21 12 to 50 Nitrogen (mg/L) 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 Metcalf and Eddy, 1991.


21

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 Advanced Wastewater Treatment systems (AWTs). AWTs generally provide improved screening, biological treatment, solids separation (using filtration or flotation), disinfection (using ultraviolet light), and sludge processing 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. 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 wastestreams 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 wastestreams) while the ROCHEM Bio-Filt® treats wastewater from galley and sewage, as well as the membrane concentrate from the ROCHEM LPRO system (high concentration wastestreams). The ROCHEM LPRO system uses screens to remove fibers and hair, reverse osmosis membranes to remove particulates and dissolved solids, and UV disinfection to destroy pathogens. The ROCHEM BioFilt® 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 destroy pathogens. See EPA, 2006d, for more detailed information on this system. The Zenon Zee Weed® 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,

22


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. 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. 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 for destruction of bacteria and viruses. See EPA, 2006b, for more detailed information on this system. The Hydroxyl CleanSea® system uses aerobic biological oxidation followed by dissolved air flotation and ultraviolet (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 freefloating 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 (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.

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


23

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 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 (monitoring is seldom performed other than for compliance). These data comprise less than 2% of the data summarized below.

24


To date, all available AWT effluent monitoring data are from four AWT systems: Hamworthy Membrane Bioreactor (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. 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.

Table 2.5. AWT Effluent Concentrations and Removals–Pathogen Indicators

Analyte Fecal Coliform

i

Unit CFU 100mL

Average Concentration Average Concentration in after bioreactors but Cruise Ship AWT Influent' before UV Disinfection' / 103,000,000* (61 detects 25,500# (39 detects out out of 62 samples) of 56 samples)

Average Concentration in Cruise Ship AWT Effluent2 14.5* (26 detects out of 285 samples)

Overall AWT Percent Removal'

>99

10.1* (47 detects out of 320 samples)

MPN 100mL

/

E. coli

MPN 100mL

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

>99

Enterococc

MPN 100mL

/ 4,940,000* (63 detects out 97.4# (33 detects out of 1.28* (9 detects out of of 64 samples) 54 samples) 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.

Table 2.6. AWT Effluent Concentrations and Removals–Conventional Pollutants and Other Common Analytes

Conductivity

Average Concentration in Cruise Ship AWT Influent' Unit mg/L CaCO 325 (25 detects out of 25 samples) mg/L 526 (24 detects out of 24 samples) mg/L 1,140 (50 detects out of 50 samples) ig/L 294 (25 detects out of 25 samples) umhos/cm

Hardness

mg/L

Hexane extractable material (HEM) pH

mg/L

Analyte Alkalinity Biochemical Oxygen Demand (5-day) Chemical Oxygen Demand Chloride

SU

Residual Chlorine, Free mg/L Residual Chlorine, Total

mg/L

135 (25 detects out of 25 samples) 95.6 (25 detects out of 25 samples)

Average Conc. (± SE) in Cruise Ship AWT Effluent2 178 (±9.6 1) (127 detects out of 127 samples) 7.99* (±0.798) (358 detects out of 568 samples) 69.4* (±4.03) (139 detects out of 147 samples) 389 (±93.9) (20 detects out of 20 samples)

Percent Removal' 32 to 78 >99 >93 to 97 NC to 16

1,450 (±268) (105 detects out of 105 samples) 120 (±30.5) (20 detects out of 20 samples) 5.74* (±0.154) (13 detects out of 127 >91 to >96 samples) 99.5% of samples within range of 6.0 to 9.0 (921 detects out of 921 samples) 0.249* (±0.0993) (22 detects out of 511 samples) 0.338* (±0.129) (41 detects out of 547 samples)

Analyte

Unit

Salinity

ppt

Silica Gel Treated Hexane Extractable Material (SGT-HEM)

mg/L

Temperature

°C

Total Dissolved Solids mg/L Total Organic Carbon

mg/L

Total Settleable Solids mL/L Total Suspended Solids mg/L Turbidity

NTU

Average Concentration in Cruise Ship AWT Influent'

22.1* (17 detects out of 25 samples)

Average Conc. (± SE) in Cruise Ship AWT Percent Effluent2 Removal' 1.93* (±0.606) (76 detects out of 77 samples) ND (0 detects out of 20 samples) NC to >92

31.3 (±0.198) (403 detects out of 403) 776 (25 detects out of 25 samples) 169 (25 detects out of 25 samples) 33.5* (23 detects out of 24 samples)

819 (±169) (20 detects out of 20 samples)

NC to 34

19.0* (±1.20) (123 detects out of 127 samples) 0.141* (±0.0385) (3 detects out of 83 samples)

86 to 94

545 (50 detects out of 50 samples)


>99 >99


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 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.

Table 2.7. AWT Effluent Concentrations and Removals–Metals

Analyte1 Antimony, Total

Average Concentration in Cruise 2 Unit Ship AWT Influent gg/L ND

Average Conc. (± SE) in Cruise Ship AWT Percent Effluent3 Removal2 2.38* (±0.219) (15 detects out of 71 samples)

Antimony, Dissolved gg/L 4.0* (1 detect out of 25 samples)


Arsenic, Total

gg/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

gg/L ND

2.28* (±0.166) (19 detects out of 71 samples) NC

Cadmium, Total

gg/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

gg/L 6.64* (24 detects out of 25 samples) 4.29* (±0.992) (27 detects out of 71 samples) >44 to 95

Chromium, Dissolved gg/L 1.51* (15 detects out of 25 samples) 3.71* (±0.786) (28 detects out of 71 samples) 49 to 67 Copper, Total Copper, Dissolved Lead, Total Lead, Dissolved Mercury, Total4

gg/L gg/L gg/L gg/L gg/L

Mercury, Dissolved4

gg/L

Nickel, Total Nickel, Dissolved Selenium, Total

gg/L gg/L gg/L

519 (25 detects out of 25 samples) 81.5 (25 detects out of 25 samples) 9.25* (22 detects out of 25 samples) 2.36* (13 detects out of 25 samples) 0.310* (21 detects out of 25 samples) 0.120* (10 detects out of 25 samples) 22.4 (25 detects out of 25 samples) 17.1 (25 detects out of 25 samples) 9.68* (13 detects out of 25 samples)

16.6* (±2.74) (69 detects out of 71 samples) 13.7* (±2.40) (65 detects out of 71 samples) 1.50* (±0.135) (27 detects out of 71 samples) 1.35* (±0.138) (20 detects out of 71 samples) 0.165* (±0.00895) (10 detects out of 70 samples) 0.176* (±0.00941) (10 detects out of 68 samples) 13.6* (±2.01) (70 detects out of 71 samples) 13.3* (±1.96) (69 detects out of 71 samples) 5.86* (±1.20) (33 detects out of 71 samples)

96 to 98 62 to 94 42 to >84 NC to >30 60 to 92 NC to 32 NC to 48 NC to 32 12 to 38

Analyte1 Selenium, Dissolved Silver, Total

Unit Average Concentration in Cruise Ship AWT Influent2 gg/L 8.39* (10 detects out of 25 samples) gg/L 1.70* (14 detects out of 25 samples)

Silver, Dissolved

gg/L ND

Average Conc. (± SE) in Cruise Ship AWT Effluent3 6.14* (±1.48) (29 detects out of 71 samples) 1.15* (±0.109) (17 detects out of 71 samples)

Percent Removal2 NC to 24 >0.5 to >74 NC

Thallium, Total

1.00* (±0.0844) (10 detects out of 71 samples) gg/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

gg/L 986 (25 detects out of 25 samples)


NC to 86

Zinc, Dissolved

gg/L 209 (25 detects out of 25 samples)


NC

Priority pollutant metal analytes detected in at least 10% of AWT influent and/or effluent samples. 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 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. 1 2

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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 wastestream). 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 TSS). Sampling results indicate that AWTs remove 37 to 50% of dissolved metals on average. Table 2.8. AWT Effluent Concentrations and Removals–Volatile and Semivolatile Organics

Analyte1 Unit 2,4-Dichlorophenol jtg/L

Average Concentration in Cruise Ship AWT Influent2 ND

Bis(2-ethylhexyl) phthalate

jtg/L

46.1* (21 detects 6.66* (±0.721) (2 detects out of 25 samples) out of 71 samples)

Chloroform

jtg/L

10.1* (5 detects out 3.74* (±0.351) (27 detects NC to >67 of 25 samples) out of 71 samples)

Diethyl phthalate

jtg/L

13.1* (8 detects out 8.57* (±1.06) (7 detects of 25 samples) out of 71 samples)

Average Conc. (± SE) in Cruise Ship AWT Effluent3

Percent Removal2

8.48* (±1.08) (8 detects out of 71 samples) >37 to >90

NC to >51

Di-n-butyl phthalate jtg/L

ND


Phenol

jtg/L

75.0* (24 detects 20.7* (±3.00) (25 detects out of 25 samples) out of 71 samples)

25 to 45

Tetrachloroethylene jtg/L

255* (8 detects out 5.59* (±1.05) (10 detects of 25 samples) out of 71 samples)

>44 to 97


31

Table 2.8. AWT Effluent Concentrations and Removals–Volatile and Semivolatile Organics (Continued)

Analyte1 Toluene

Unit jtg/L

Trichloroethene

jtg/L

Average Concentration in Cruise Ship AWT Influent2 7.67* (5 detects out of 25 samples)

Average Conc. (± SE) in Cruise Ship AWT Effluent3

Percent Removal2

3.44* (±0.346) (10 detects >1.4 to >17 out of 71 samples)

15.1* (5 detects out 3.54* (±0.337) (1 detects of 25 samples) out of 71 samples)

>75

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 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.

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.

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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 sludge. 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 Ammonia As Nitrogen

Average Concentration in Cruise Ship AWT Unit Influent' mg/L 78.6 (35 detects out of 35 samples)

Average Conc. (± SE) in Cruise Percent Ship AWT Effluent2 Removal ' 36.6* (±5.50) (136 detects out 58 to 74 of 138 samples)

Nitrate/Nitrite as Nitrogen

mg/L 0.325* (26 detects out of 3.32* (±0.653) (66 detects out 50 samples) of 152 samples)

Total Kjeldahl mg/L 111 (50 detects out of 50 32.5* (±3.27) (169 detects out Nitrogen samples) of 170 samples) Total Phosphorus

NC 70 to 76

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

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

1 2

Pesticides EPA analyzed for 121 organohalide and organophosphorus pesticides in AWT influent (pesticides were not analyzed for in AWT effluent). Simazine was


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the only pesticide detected (concentration of 0.96 jtg/L in one sample). EPA lists simazine as a General Use Pesticide (GUP) that has been used to control broadleaved 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. Sewage Sludge Waste Sludge In addition to the treated sewage discharge generated by cruise ships, waste sludge (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 sludge 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 destroy 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, these systems are “desludged” by removing a portion of the contents of the bioreactors. According to responses to EPA’s 2004 cruise ship survey, this waste sludge is discharged without treatment outside 12 nautical miles (nm) from shore. EPA has no sampling data for waste sludge from traditional Type II MSDs.

Table 2.10. AWT Sludge Concentrations for Selected Analytes

Analyte Unit Conventional Pollutants Biochemical mg/L Oxygen Demand (5Day) Chemical Oxygen mg/L Demand Metals Chromium, Total

~g/L

Copper, Total

~g/L

Lead, Total

~g/L

Nickel, Total

~g/L

Zinc, Total

~g/L

Volatile and Semivolatile Organics

Average Concentration in Average Concentration in Cruise Cruise Ship AWT Ship AWT Waste Sludge1 Influent1

Average Concentration in Cruise Ship AWT Screening Solids1


6,610 (1 detect out of 1 sample)

3,870 (1 detect out of 1 sample)

1,140 (50 detects out of 50 9,840 (3 detects out of 3 samples) samples) 6.64* (24 detects out of 25 samples) 519 (25 detects out of 25 samples) 9.25* (22 detects out of 25 samples) 22.4 (25 detects out of 25 samples) 986 (25 detects out of 25 samples)


46,200 (3 detects out of 3 samples)

565 (3 detects out of 3 samples) 10,800 (3 detects out of 3 samples) 22,700 (3 detects out of 3 samples) 177 (3 detects out of 3 samples) 49.9* (2 detects out of 3 samples) 245 (3 detects out of 3 samples) 537 (3 detects out of 3 samples) 19,400 (3 detects out of 3 samples) 33,600 (3 detects out of 3 samples)

5 Table 2.10. AWT Sludge Concentrations for Selected Analytes (Continued) Analyte

Unit

Bis (2-ethylhexyl) phthalate Phenol

~g/L ~g/L

Tetrachloroethylene ~g/L Trichloroethene Nutrients Ammonia as Nitrogen Total Kjeldahl Nitrogen Nitrate/Nitrite as Nitrogen Total Phosphorus 1

~g/L

mg/L mg/L mg/L mg/L

Average Concentration in Cruise Ship AWT 46.1* (21 detects out of 25 samples) 75.0* (24 detects out of 25 samples) 255* (8 detects out of 25 samples) 15.1 * (5 detects out of 25 samples)

Average Concentration in Cruise Ship AWT Waste Sludge1 40.0 (2 detects out of 2 samples)

78.6 (35 detects out of 35 samples) 111 (50 detects out of 50 samples) 0.325* (26 detects out of 50 samples) 18.1 (25 detects out of 25 samples)

58.2 (2 detects out of 2 samples)

628 (2 detects out of 2 samples) 5.83* (2 detects out of 3 samples) 3.74* (1 detect out of 3 samples)

1,030 (3 detects out of 3 samples) 3.5 1* (2 detects out of 3 samples) 173 (3 detects out of 3 samples)

Average Concentration in Cruise Ship AWT 6,250* (2 detects out of 3 samples) 563* (2 detects out of 3 samples) 6.19* (2 detects out of 3 samples) ND (0 detects out of 3 samples) 170 (2 detects out of 2 samples) 740 (3 detects out of 3 samples) 1.24* (2 detects out of 3 samples) 341 (3 detects out of 3 samples)

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

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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 sludge is pumped to a double-bottom holding tank for discharge without treatment outside 12 nm from shore. The volume of sludge discharged by these four ships ranged from 370 to 6,600 gallons/day. EPA collected one-time grab samples of waste sludge from three of the four vessels sampled in 2004 (see Table 2-10). Most of the analytes detected in the sludge also were detected in the influent to treatment. For many analytes, concentrations in the sludge exceeded those in the influent to treatment, suggesting that these analytes accumulate in the system until removed in the waste sludge stream. In particular, there were elevated metals concentrations in the waste sludge. This is expected as the AWTs are highly efficient in removing particulate metals from the effluent and retaining them in the bioreactors.

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 one time grab samples of screening solids from three of the four vessels sampled in 2004 (see Table 2-10). 2.3.4. Cruise Industry Practice Cruise Lines International Association (CLIA) member lines have agreed to incorporate various standards for waste stream management into their Safety Management Systems (see Section 1.3). CLIA members have agreed that all sewage will be processed through a marine sanitation device (MSD), certified in accordance with U.S. or international regulations, prior to discharge (CLIA, 2006). For ships that do not have Advanced Wastewater Treatment systems traveling regularly on itineraries beyond territorial coastal waters, 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


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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 US territorial waters, 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 Marine Sanitation Devices (MSDs) and Advanced Wastewater Treatment systems (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.

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

Traditional Type II MSD effluent concentrations exceeded the EPA standards for discharges from Type II MSDs (see Table 2-1 1). In addition, traditional Type II MSD effluent concentrations exceeded most wastewater discharge standards under Title XIV for continuous discharge and for secondary treatment from landbased 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. In 2003 through 2005, many cruise vessels in Alaska converted from chlorine disinfection of treated sewage and graywater to ultraviolet light (UV) disinfection methods

38


during treatment system upgrades from traditional Type II MSDs to AWT systems. The switch to UV disinfection resulted in a decline in the frequency and magnitude of detected total residual chlorine in cruise effluent from AWTs. Table 2.11. Comparison of AWT and Traditional Type II MSD Effluent to Wastewater Discharge Standards

Average Average Concentration in Concentration in Traditional Type Analyte AWT Effluent1 II MSD Effluent2 Fecal coliform 14.5* 2,040,000*MPN (fecal coliform/ / 100 mL 100 mL) Total residual 338* 1,070* chlorine (jig/L) Biochemical 7.99* oxygen demand (5-day) (mg/L)

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Total suspended solids (mg/L)

4.49*

627

pH

99.5% of pH 90.5% of pH samples between samples between 6.0 and 9.0 6.0 and 9.0

1

Performance Standards for Type II MSDs (33 CFR Part 159 Subpart C) 1 kg

> 100 kg

< 90 days on site No Limit

100 kg < 1000 N/A kg

N/A

Conditionally Exempt Small Quantity Generators

< 100 kg

< 100 kg

< 180 day on site 6,000 kg or < 270 if shipped 200 miles or more N/A 1,000 kg 1kg acute 100 kg residue

< 1 kg

On-site Quantity Limit

Source: EPA, 2005.

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 recordkeeping 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 USCG, 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 offloading state’s RCRA requirements, whether or not that state assigned the ID number.

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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 widelygenerated 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 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-to grave” requirements summarized elsewhere in this section, releases of RCRA hazardous waste in amounts above the regulatory threshold are subject to


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reporting as a CERCLA hazardous substance unless excepted as a federally permitted release.

6.3. How do Cruise Ships Manage Hazardous Waste? Hazardous waste generated onboard cruise ships are stored onboard until the wastes can be offloaded for recycling or disposal. Hazardous waste that is offloaded for disposal is handled in accordance with RCRA requirements, and must be sent to a licensed hazardous waste Treatment, Storage, and Disposal Facility (TSDF). RCRA establishes waste treatment standards for TSDFs that make the hazardous waste safe for land disposal. Cruise Lines International Association (CLIA) member lines have adopted programs of waste minimization, waste reuse and recycling, and waste stream management. In the development of industry practices and procedures for waste management, member lines of CLIA have agreed to incorporate various standards for waste stream management into their Safety Management Systems (see Section 1.3). CLIA member lines have stated that hazardous wastes and waste streams onboard cruise vessels will be identified and segregated for individual handling and management in accordance with appropriate laws and regulations. They have further stated that hazardous wastes will not be discharged overboard, nor be commingled or mixed with other waste streams. With regard to hazardous waste collection and storage onboard ships, CLIA member lines have stated that specific procedures for hazardous waste collection, storage and crew training will be addressed in each ship’s Safety Management System or equivalent onboard instruction in the case of U.S. registry vessels. CLIA members have endorsed the following when treating hazardous waste (CLIA, 2006): −

−

Photo Processing, Including X-Ray Development Fluid Waste -Eliminate the discharge of silver from these sources into the marine environment through the use of best available technology that will reduce the silver content of the waste stream below levels specified by prevailing regulations and land the remaining effluent ashore as industrial waste or by treating all photo processing and x-ray development fluid waste (treated or untreated) as a hazardous waste and landing ashore in accordance with RCRA requirements. Dry-cleaning Waste Fluids and Contaminated Materials -- Prevent the discharge of chlorinated dry-cleaning fluids, sludge, contaminated filter

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−

−

−

materials and other dry-cleaning waste byproducts into the marine environment by treating perchloroethylene (perc) and other chlorinated dry-cleaning fluids, contaminated sludge and filter materials as a hazardous waste and landing ashore in accordance with RCRA requirements. Print Shop Waste Fluids -- Prevent the discharge of hazardous wastes from printing materials (inks) and cleaning chemicals into the marine environment by utilizing, whenever possible, printing methods and printing process chemicals that produce both less volume of waste and less hazardous waste products; training shipboard printers in ways to minimize printing waste generated; and using, whenever possible, alternative printing inks such as soy based, non- chlorinated hydrocarbon based ink products. All print shop waste including waste solvents, cleaners, and cleaning cloths will be treated as hazardous waste, if such waste contains chemical components that may be considered as hazardous by regulatory definitions, and that all other waste may be treated as non-hazardous. Photo Copying and Laser Printer Cartridges -- Initiate procedures so as to maximize the return of photocopying and laser printer cartridges for recycling, and in any event, bring these cartridges ashore; use only inks, toners and printing/copying cartridges that contain non hazardous chemical components, and none of these cartridges or their components should be disposed of by discharge into the marine environment. In recognition of the member lines’ goal of waste minimization, they have further agreed these cartridges should, whenever possible, be returned to the manufacturer for credit, recycling, or for refilling. Unused and Outdated Pharmaceuticals -- Ensure that unused and/or outdated pharmaceuticals are effectively and safely disposed in accordance with legal and environmental requirements by establishing a reverse distribution system for returning unexpired, unopened nonnarcotic pharmaceuticals to the original vendor; appropriately destroying narcotic pharmaceuticals onboard ship in a manner that is witnessed and recorded; landing listed pharmaceuticals in accordance with local regulations (listed pharmaceuticals are a hazardous waste having chemical compositions which prevent them from being incinerated or disposed of through the ship’s sewer system. Listing of such pharmaceuticals may vary from state to state); and disposing of other non-narcotic and non-listed pharmaceuticals through onboard incineration or landing ashore.

Draft Cruise Ship Discharge Assessment Report −

−

−

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Fluorescent and Mercury Vapor Lamp Bulbs -- Prevent the release of mercury into the environment from spent fluorescent and mercury vapor lamps by assuring proper recycling or by using other acceptable disposal methods (disposal of the glass tubes can be accomplished by (1) processing with shipboard lamp crusher units that filter and adsorb the mercury vapor through H.E.P.A. and activated carbon or (2) by keeping the glass tubes intact for recycling ashore. The intact lamps or crushed bulbs are classified as “Universal Waste” when they are shipped to a properly permitted recycling facility; as such, testing is not required. The filters are disposed of as a hazardous waste in accordance with applicable US EPA or other prevailing laws and regulations). Batteries -- Prevent the discharge of spent batteries into the marine environment by isolating discarded batteries from the refuse waste stream to prevent potentially toxic materials from inappropriate disposal. The wet-cell battery-recycling program is kept separate from the dry battery collection process. Unless recycled or reclaimed, batteries are disposed of as hazardous waste. Incinerator Ash -- Reduce the production of incinerator ash by minimizing the generation of waste and maximizing recycling opportunities; prevent the discharge of incinerator ash containing hazardous components through a program of waste segregation and periodic ash testing.

It is possible that during waste management and waste segregation, hazardous waste may be incinerated with solid wastes, resulting in hazardous ash; however, the discharge of incinerator ash containing hazardous components can be prevented through a program of waste segregation and periodic ash testing. According to CLIA (2006), incinerator ash is not normally hazardous because the hazardous waste is separated out from other solid wastes. Proper waste management is necessary to ensure that hazardous materials are not introduced into the incinerator. According to CLIA (2006), this focuses the use of incinerators of CLIA member lines primarily for food waste, contaminated cardboard, some plastics, trash, and wood. With this approach, incinerator ash is not normally a hazardous waste (CLIA, 2006), as the abovementioned waste management strategies call for the removal of items that would cause the ash to be hazardous. Further, those items separated out from the waste stream would then be handled according to accepted hazardous waste protocols.

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Member lines have agreed that incinerator ash will be tested at least once quarterly for the first year of operation to establish a baseline and that testing may then be conducted once a year. The member lines have further agreed that a recognized test procedure will be used to demonstrate that ash is not a hazardous waste. Proper hazardous waste management procedures are to be instituted onboard each ship to assure that waste products which would result in a hazardous ash are not introduced into the incinerator. Non-hazardous incinerator ash is disposed of at sea in accordance with MARPOL Annex V. If any ash is identified as being hazardous, it is to be disposed of ashore in accordance with RCRA. (CLIA, 2006.) The cruise ship industry is also researching and, in some cases, 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. Alternative dry cleaning processes such as CO2 and wet (i.e., a waterbased alternative to dry cleaning) processes. Use of non-toxic printing ink and non-chlorinated solvents and other nonhazardous products to eliminate hazardous wastes in print shops.

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). When hazardous waste generated aboard cruise ships is properly identified, stored, and treated and/or disposed onshore, the risk posed to the 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. To ensure hazardous waste is handled and disposed of properly, adequate operational procedures and employee training and, in some instances, passenger training (e.g., 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. However,


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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.

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 (EPA, 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 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 (EPA, 2001):

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

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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.

ACKNOWLEDGMENTS AND DISCLAIMER Today's Draft Report does not substitute for any statute or regulation, nor is it a regulation itself. The document assesses five primary cruise ship wastestreams, specifically, sewage, graywater, bilge water, solid waste, and hazardous waste. For each wastestream, the Draft Report discusses: the nature and volume of the wastestream generated; existing federal regulations applicable to the wastestream; environmental management, including treatment, of the wastestream; potential adverse environmental impacts of the wastestream; and actions by the federal government to address the wastestream. The Draft Report includes a discussion the existing federal regulations application to each wastestream to illuminate the Agency's current thinking and, among other things, invites public comment. As a draft upon which EPA invites comment, the discussion of existing regulations does not represent the consummation of the Agency's decision-making on the matters discussed. By its terms, the Draft Report itself does not impose binding requirements on any party. The regulations themselves, not the Draft Report, govern parties' legal obligations. The primary contacts regarding questions or comments on this document are: Elizabeth Kim U.S. Environmental Protection Agency Oceans and Coastal Protection Division, OWOW (4504T) 1200 Pennsylvania Avenue, NW Washington, DC 20460 (202) 566-1270 (telephone) (202) 566-1546 (fax) [email protected] Laura Johnson U.S. Environmental Protection Agency Oceans and Coastal Protection Division, OWOW (4504T) 1200 Pennsylvania Avenue, NW Washington, DC 20460 (202) 566-1273 (telephone)


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(202) 566-1546 (fax) [email protected]

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) Cruise Line 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) 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) 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-05-0 11). Washington, DC. (http://www.epa.gov/ epaoswer/hotline/training/gen05 .pdf)

In: Cruise Ship Pollution Editor: Oliver G. Krenshaw

ISBN 978-1-60692-655-0 © 2009 Nova Science Publishers, Inc.

Chapter 2

CRUISE SHIP POLLUTION: BACKGROUND, LAWS AND REGULATIONS, AND KEY ISSUES ∗

Claudia Copeland ABSTRACT The cruise industry is a significant and growing contributor to the U.S. economy, providing more than $32 billion in benefits annually and generating more than 330,000 U.S. jobs, but also making the environmental impacts of its activities an issue to many. Although cruise ships represent a small fraction of the entire shipping industry worldwide, public attention to their environmental impacts comes in part from the fact that cruise ships are highly visible and in part because of the industry’s desire to promote a positive image. Cruise ships carrying several thousand passengers and crew have been compared to “floating cities,” and the volume of wastes that they produce is comparably large, consisting of sewage; wastewater from sinks, showers, and galleys (graywater); hazardous wastes; solid waste; oily bilge water; ballast water; and air pollution. The waste streams generated by cruise ships are governed by a number of international protocols (especially MARPOL) and U.S. domestic laws (including the Clean Water Act and the Act to Prevent Pollution from Ships), regulations, and standards, but there is no single law or rule. Some cruise ship waste streams appear to be well regulated, such as ∗

Excerpted from CRS Report RL32450, dated July 1, 2008.

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Claudia Copeland solid wastes (garbage and plastics) and bilge water. But there is overlap of some areas, and there are gaps in others. Some, such as graywater and ballast water, are not regulated (except in the Great Lakes), and concern is increasing about the impacts of these discharges on public health and the environment. In other areas, regulations apply, but critics argue that they are not stringent enough to address the problem — for example, with respect to standards for sewage discharges. Environmental advocates have raised concerns about the adequacy of existing laws for managing these wastes, and they contend that enforcement is weak. In 2000, Congress enacted legislation restricting cruise ship discharges in U.S. navigable waters within the state of Alaska. California, Alaska, and Maine have enacted state-specific laws concerning cruise ship pollution, and a few other states have entered into voluntary agreements with industry to address management of cruise ship discharges. Meanwhile, the cruise industry has voluntarily undertaken initiatives to improve pollution prevention, by adopting waste management guidelines and procedures and researching new technologies. Concerns about cruise ship pollution raise issues for Congress in three broad areas: adequacy of laws and regulations, research needs, and oversight and enforcement of existing requirements. Legislation to regulate cruise ship discharges of sewage, graywater, and bilge water nationally has been introduced in the 1 10th Congress (S. 2881). This report describes the several types of waste streams that cruise ships may discharge and emit. It identifies the complex body of international and domestic laws that address pollution from cruise ships. It then describes federal and state legislative activity concerning cruise ships in Alaskan waters and activities in a few other states, as well as current industry initiatives to manage cruise ship pollution. Issues for Congress are discussed.

INTRODUCTION More than 46,000 commercial vessels — tankers, bulk carriers, container ships, barges, and passenger ships — travel the oceans and other waters of the world, carrying cargo and passengers for commerce, transport, and recreation. Their activities are regulated and scrutinized in a number of respects by international protocols and U.S. domestic laws, including those designed to protect against discharges of pollutants that could harm marine resources, other parts of the ambient environment, and human health. However, there are overlaps of some requirements, gaps in other areas, geographic differences in jurisdiction based on differing definitions, and questions about the adequacy of enforcement. Public attention to the environmental impacts of the maritime industry has been especially focused on the cruise industry, in part because its ships are highly

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visible and in part because of the industry’s desire to promote a positive image. It represents a relatively small fraction of the entire shipping industry worldwide. As of January 2008, passenger ships (which include cruise ships and ferries) composed about 12% of the world shipping fleet. [1] The cruise industry is a significant and growing contributor to the U.S. economy, providing more than $32 billion in total benefits annually and generating more than 330,000 U.S. jobs, [2] but also making the environmental impacts of its activities an issue to many. Since 1980, the average annual growth rate in the number of cruise passengers worldwide has been 8.4%, and in 2005, cruises hosted an estimated 11.5 million passengers. Cruises are especially popular in the United States. In 2005, U.S. ports handled 8.6 million cruise embarkations (75% of global passengers), 6.3% more than in 2004. The worldwide cruise ship fleet consists of more than 230 ships, and the majority are foreign- flagged, with Liberia and Panama being the most popular flag countries. [3] Foreign- flag cruise vessels owned by six companies account for nearly 95% of passenger ships operating in U.S. waters. Each year, the industry adds new ships to the total fleet, vessels that are bigger, more elaborate and luxurious, and that carry larger numbers of passengers and crew. Over the past two decades, the average ship size has been increasing at the rate of roughly 90 feet every five years. The average ship entering the market from 2008 to 2011 will be more than 1,050 feet long and will weigh more than 130,000 tons. [4] To the cruise ship industry, a key issue is demonstrating to the public that cruising is safe and healthy for passengers and the tourist communities that are visited by their ships. Cruise ships carrying several thousand passengers and crew have been compared to “floating cities,” in part because the volume of wastes produced and requiring disposal is greater than that of many small cities on land. During a typical one-week voyage, a large cruise ship (with 3,000 passengers and crew) is estimated to generate 210,000 gallons of sewage; 1 million gallons of graywater (wastewater from sinks, showers, and laundries); more than 130 gallons of hazardous wastes; 8 tons of solid waste; and 25,000 gallons of oily bilge water. [5] Those wastes, if not properly treated and disposed of, can pose risks to human health, welfare, and the environment. Environmental advocates have raised concerns about the adequacy of existing laws for managing these wastes, and suggest that enforcement of existing laws is weak. A 2000 General Accounting Office (GAO) report focused attention on problems of cruise vessel compliance with environmental requirements. [6] GAO found that between 1993 and 1998, foreign-flag cruise ships were involved in 87 confirmed illegal discharge cases in U.S. waters. A few of the cases included multiple illegal discharge incidents occurring over the six-year period. GAO

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reviewed three major waste streams (solids, hazardous chemicals, and oily bilge water) and concluded that 83% of the cases involved discharges of oil or oil-based products, the volumes of which ranged from a few drops to hundreds of gallons. The balance of the cases involved discharges of plastic or garbage. GAO judged that 72% of the illegal discharges were accidental, 15% were intentional, and 13% could not be determined. The 87 cruise ship cases represented 4% of the 2,400 illegal discharge cases by foreign-flag ships (including tankers, cargo ships and other commercial vessels, as well as cruise ships) confirmed during the six years studied by GAO. Although cruise ships operating in U.S. waters have been involved in a relatively small number of pollution cases, GAO said, several have been widely publicized and have led to criminal prosecutions and multimilliondollar fines. In 2000, a coalition of 53 environmental advocacy groups petitioned the Environmental Protection Agency (EPA) to take regulatory action to address pollution by cruise ships. [7] The petition called for an investigation of wastewater, oil, and solid waste discharges from cruise ships. In response, EPA agreed to study cruise ship discharges and waste management approaches. As part of that effort, in 2000 EPA issued a background document with preliminary information and recommendations for further assessment through data collection and public information hearings. [8] Subsequently, in December 2007, the agency released a draft cruise ship discharge assessment report as part of its response to the petition. This report summarized findings of recent data collection activities (especially from cruise ships operating in Alaskan waters). EPA expects to issue a completed report by the end of 2008, and at that time will identify a range of options and alternatives to address cruise ship waste streams. [9] This report presents information on issues related to cruise ship pollution. It begins by describing the several types of waste streams and contaminants that cruise ships may generate and release. It identifies the complex body of international and domestic laws that address pollution from cruise ships, as there is no single law in this area. Some wastes are covered by international standards, some are subject to U.S. law, and for some there are gaps in law, regulation, or possibly both. The report then describes federal and state legislative activity concerning cruise ships in Alaskan waters and recent activities in a few other states. Cruise ship companies have taken a number of steps to prevent illegal waste discharges and have adopted waste management plans and practices to improve their environmental operations. Environmental critics acknowledge these initiatives, even as they have petitioned the federal government to strengthen existing regulation of cruise ship wastes. Environmental groups endorsed companion bills in the 109th Congress (the Clean Cruise Ship Act, S. 793/H.R.


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1636) that would have required stricter standards to control wastewater discharges from cruise ships. Congress did not act on either bill. Similar legislation has been introduced in the 1 10th Congress (S. 2881).

CRUISE SHIP WASTE STREAMS Cruise ships generate a number of waste streams that can result in discharges to the marine environment, including sewage, graywater, hazardous wastes, oily bilge water, ballast water, and solid waste. They also emit air pollutants to the air and water. These wastes, if not properly treated and disposed of, can be a significant source of pathogens, nutrients, and toxic substances with the potential to threaten human health and damage aquatic life. It is important, however, to keep these discharges in some perspective, because cruise ships represent a small — although highly visible — portion of the entire international shipping industry, and the waste streams described here are not unique to cruise ships. However, particular types of wastes, such as sewage, graywater, and solid waste, may be of greater concern for cruise ships relative to other seagoing vessels, because of the large numbers of passengers and crew that cruise ships carry and the large volumes of wastes that they produce. Further, because cruise ships tend to concentrate their activities in specific coastal areas and visit the same ports repeatedly (especially Florida, California, New York, Galveston, Seattle, and the waters of Alaska), their cumulative impact on a local scale could be significant, as can impacts of individual large-volume releases (either accidental or intentional). Blackwater is sewage, wastewater from toilets and medical facilities, which can contain harmful bacteria, pathogens, diseases, viruses, intestinal parasites, and harmful nutrients. Discharges of untreated or inadequately treated sewage can cause bacterial and viral contamination of fisheries and shellfish beds, producing risks to public health. Nutrients in sewage, such as nitrogen and phosphorous, promote excessive algal growth, which consumes oxygen in the water and can lead to fish kills and destruction of other aquatic life. A large cruise ship (3,000 passengers and crew) generates an estimated 15,000 to 30,000 gallons per day of blackwater waste. [10] Graywater is wastewater from the sinks, showers, galleys, laundry, and cleaning activities aboard a ship. It can contain a variety of pollutant substances, including fecal coliform bacteria, detergents, oil and grease, metals, organics, petroleum hydrocarbons, nutrients, food waste, and medical and dental waste. Sampling done by EPA and the state of Alaska found that untreated graywater from cruise ships can contain pollutants at variable strengths and that it can

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contain levels of fecal coliform bacteria several times greater than is typically found in untreated domestic wastewater. [11] Graywater has potential to cause adverse environmental effects because of concentrations of nutrients and other oxygen-demanding materials, in particular. Graywater is typically the largest source of liquid waste generated by cruise ships (90%-95% of the total). Estimates of graywater range from 30 to 85 gallons per day per person, or 90,000 to 255,000 gallons per day for a 3,000-person cruise ship.[12] Solid waste generated on a ship includes glass, paper, cardboard, aluminum and steel cans, and plastics. It can be either non-hazardous or hazardous in nature. Solid waste that enters the ocean may become marine debris, and it can then pose a threat to marine organisms, humans, coastal communities, and industries that utilize marine waters. Cruise ships typically manage solid waste by a combination of source reduction, waste minimization, and recycling. However, as much as 75% of solid waste is incinerated on board, and the ash typically is discharged at sea, although some is landed ashore for disposal or recycling. Marine mammals, fish, sea turtles, and birds can be injured or killed from entanglement with plastics and other solid waste that may be released or disposed off of cruise ships. On average, each cruise ship passenger generates at least two pounds of nonhazardous solid waste per day and disposes of two bottles and two cans. [13] With large cruise ships carrying several thousand passengers, the amount of waste generated in a day can be massive. For a large cruise ship, about 8 tons of solid waste are generated during a one-week cruise. [14] It has been estimated that 24% of the solid waste generated by vessels worldwide (by weight) comes from cruise ships. [15] Most cruise ship garbage is treated on board (incinerated, pulped, or ground up) for discharge overboard. When garbage must be off-loaded (for example, because glass and aluminum cannot be incinerated), cruise ships can put a strain on port reception facilities, which are rarely adequate to the task of serving a large passenger vessel (especially at non-North American ports). [16] Cruise ships produce hazardous wastes from a number of on-board activities and processes, including photo processing, dry-cleaning, and equipment cleaning. Types of waste include discarded and expired chemicals, medical waste, batteries, fluorescent lights, and spent paints and thinners, among others. These materials contain a wide range of substances such as hydrocarbons, chlorinated hydrocarbons, heavy metals, paint waste, solvents, fluorescent and mercury vapor light bulbs, various types of batteries, and unused or outdated pharmaceuticals. Although the quantities of hazardous waste generated on cruise ships are small, their toxicity to sensitive marine organisms can be significant. Without careful management, these wastes can find their way into graywater, bilge water, or the solid waste stream.


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On a ship, oil often leaks from engine and machinery spaces or from engine maintenance activities and mixes with water in the bilge, the lowest part of the hull of the ship. Oil, gasoline, and byproducts from the biological breakdown of petroleum products can harm fish and wildlife and pose threats to human health if ingested. Oil in even minute concentrations can kill fish or have various sub-lethal chronic effects. Bilge water also may contain solid wastes and pollutants containing high amounts of oxygen-demanding material, oil and other chemicals. A typical large cruise ship will generate an average of 8 metric tons of oily bilge water for each 24 hours of operation. [17] To maintain ship stability and eliminate potentially hazardous conditions from oil vapors in these areas, the bilge spaces need to be flushed and periodically pumped dry. However, before a bilge can be cleared out and the water discharged, the oil that has been accumulated needs to be extracted from the bilge water, after which the extracted oil can be reused, incinerated, and/or off-loaded in port. If a separator, which is normally used to extract the oil, is faulty or is deliberately bypassed, untreated oily bilge water could be discharged directly into the ocean, where it can damage marine life. A number of cruise lines have been charged with environmental violations related to this issue in recent years. Cruise ships, large tankers, and bulk cargo carriers use a tremendous amount of ballast water to stabilize the vessel during transport. Ballast water is often taken on in the coastal waters in one region after ships discharge wastewater or unload cargo, and discharged at the next port of call, wherever more cargo is loaded, which reduces the need for compensating ballast. Thus, it is essential to the proper functioning of ships (especially cargo ships), because the water that is taken in compensates for changes in the ship’s weight as cargo is loaded or unloaded, and as fuel and supplies are consumed. However, ballast water discharge typically contains a variety of biological materials, including plants, animals, viruses, and bacteria. These materials often include non-native, nuisance, exotic species that can cause extensive ecological and economic damage to aquatic ecosystems. Ballast water discharges are believed to be the leading source of invasive species in U.S. marine waters, thus posing public health and environmental risks, as well as significant economic cost to industries such as water and power utilities, commercial and recreational fisheries, agriculture, and tourism. [18] Studies suggest that the economic cost just from introduction of pest mollusks (zebra mussels, the Asian clam, and others) to U.S. aquatic ecosystems is more than $6 billion per year. [19] These problems are not limited to cruise ships, but there is little cruise-industry specific data on the issue, and further study is needed to determine cruise ships’ role in the overall problem of introduction of non-native species by vessels.

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Air pollution from cruise ships is generated by diesel engines that burn high sulfur content fuel, producing sulfur dioxide, nitrogen oxide and particulate matter, in addition to carbon monoxide, carbon dioxide, and hydrocarbons. Diesel exhaust has been classified by EPA as a likely human carcinogen. EPA recognizes that these emissions from marine diesel engines contribute to ozone and carbon monoxide nonattainment (i.e., failure to meet air quality standards), as well as adverse health effects associated with ambient concentrations of particulate matter and visibility, haze, acid deposition, and eutrophication and nitrophication of water. [20] EPA estimates that large marine diesel engines accounted for about 1.6% of mobile source nitrogen oxide emissions and 2.8% of mobile source particulate emissions in the United States in 2000. Contributions of marine diesel engines can be higher on a port-specific basis. One source of environmental pressures on maritime vessels recently has come from states and localities, as they assess the contribution of commercial marine vessels to regional air quality problems when ships are docked in port. For instance, large marine diesel engines are believed to contribute 7% of mobile source nitrogen oxide emissions in Baton Rouge/New Orleans. Ships can also have a significant impact in areas without large commercial ports: they contribute about 37% of total area nitrogen oxide emissions in the Santa Barbara area, and that percentage is expected to increase to 61% by the year 2015. [21] Again, there is little cruise-industry specific data on this issue. They comprise only a small fraction of the world shipping fleet, but cruise ship emissions may exert significant impacts on a local scale in specific coastal areas that are visited repeatedly. Shipboard incinerators also burn large volumes of garbage, plastics, and other waste, producing ash that must be disposed of. Incinerators may release toxic emissions as well.

APPLICABLE LAWS AND REGULATIONS The several waste streams generated by cruise ships are governed by a number of international protocols and U.S. domestic laws, regulations and standards, which are described in this section, but there is no single law or regulation. Moreover, there are overlaps in some areas of coverage, gaps in other areas, and differences in geographic jurisdiction, based on applicable terms and definitions.


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International Legal Regime The International Maritime Organization (IMO), a body of the United Nations, sets international maritime vessel safety and marine pollution standards. It consists of representatives from 152 major maritime nations, including the United States. The IMO implements the 1973 International Convention for the Prevention of Pollution from Ships, as modified by the Protocol of 1978, known as MARPOL 73/78. 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. [22] Six Annexes of the Convention cover the various sources of pollution from ships and provide an overarching framework for international objectives, but they are not sufficient alone to protect the marine environment from waste discharges, without ratification and implementation by sovereign states. • • •

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Annex I deals with regulations for the prevention of pollution by oil. Annex II details the discharge criteria and measures for the control of pollution by noxious liquid substances carried in bulk. Annex III contains general requirements for issuing standards on packing, marking, labeling, and notifications for preventing pollution by harmful substances. Annex IV contains requirements to control pollution of the sea by sewage. Annex V deals with different types of garbage, including plastics, and specifies the distances from land and the manner in which they may be disposed of. Annex VI sets limits on sulfur oxide, nitrogen oxide, and other emissions from marine vessel operations and prohibits deliberate emissions of ozone-depleting substances.

In order for IMO standards to be binding, they must first be ratified by a total number of member countries whose combined gross tonnage represents at least 50% of the world’s gross tonnage, a process that can be lengthy. All six have been ratified by the requisite number of nations; the most recent is Annex VI, which took effect in May 2005. The United States has ratified Annexes I, II, III, and V, and the U.S. Senate also has acceded to the treaty ratifying Annex VI. The United States has taken no action regarding Annex IV. The country where a ship is

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registered (flag state) is responsible for certifying the ship’s compliance with MARPOL’s pollution prevention standards. IMO also has established a large number of other conventions, addressing issues such as ballast water management, and the International Safety Management Code, with guidelines for passenger safety and pollution prevention. Each signatory nation is responsible for enacting domestic laws to implement the convention and effectively pledges to comply with the convention, annexes, and related laws of other nations. In the United States, the Act to Prevent Pollution from Ships (APPS, 33 U.S.C. §§1905-1915) implements the provisions of MARPOL and the annexes to which the United States is a party. The most recent U.S. action concerning MARPOL occurred in April 2006, when the Senate approved Annex VI, which regulates air pollution (Treaty Doc. 108-7, Exec. Rept. 109-13). Following that approval, in March 2007, the House approved legislation to implement the standards in Annex VI (H.R. 802), through regulations to be promulgated by EPA in consultation with the U.S. Coast Guard. In June 2008, the Senate passed an amended version of H.R. 802, different from the provision approved by the House in March 2007. Negotiations to strengthen MARPOL Annex VI also are underway. The United States has participated in these international discussions, but it will lose the ability to vote at the next negotiating session in October 2008, if Congress does not enact legislation to implement existing Annex VI by July 6. [23] APPS applies to all U.S.-flagged ships anywhere in the world and to all foreign- flagged vessels operating in navigable waters of the United States or while at port under U.S. jurisdiction. The Coast Guard has primary responsibility to prescribe and enforce regulations necessary to implement APPS in these waters. The regulatory mechanism established in APPS to implement MARPOL is separate and distinct from the Clean Water Act and other federal environmental laws. One of the difficulties in implementing MARPOL arises from the very international nature of maritime shipping. The country that the ship visits can conduct its own examination to verify a ship’s compliance with international standards and can detain the ship if it finds significant noncompliance. Under the provisions of the Convention, the United States can take direct enforcement action under U.S. laws against foreign-flagged ships when pollution discharge incidents occur within U.S. jurisdiction. When incidents occur outside U.S. jurisdiction or jurisdiction cannot be determined, the United States refers cases to flag states, in accordance with MARPOL. The 2000 GAO report documented that these procedures require substantial coordination between the Coast Guard, the State


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Department, and other flag states and that, even when referrals have been made, the response rate from flag states has been poor. [24]

Domestic Laws and Regulations In the United States, several federal agencies have some jurisdiction over cruise ships in U.S. waters, but no one agency is responsible for or coordinates all of the relevant government functions. The U.S. Coast Guard and EPA have principal regulatory and standard-setting responsibilities, and the Department of Justice prosecutes violations of federal laws. In addition, the Department of State represents the United States at meetings of the IMO and in international treaty negotiations and is responsible for pursuing foreign-flag violations. Other federal agencies have limited roles and responsibilities. For example, the National Oceanic and Atmospheric Administration (NOAA, Department of Commerce) works with the Coast Guard and EPA to report on the effects of marine debris. The Animal and Plant Health Inspection Service (APHIS) is responsible for ensuring quarantine inspection and disposal of food-contaminated garbage (these APHIS responsibilities are part of the Department of Homeland Security). In some cases, states and localities have responsibilities as well. This section describes U.S. laws and regulations that apply to cruise ship discharges. Sewage. The Federal Water Pollution Control Act, or Clean Water Act (CWA), is the principal U.S. law concerned with limiting polluting activity in the nation’s streams, lakes, estuaries, and coastal waters. The act’s primary mechanism for controlling pollutant discharges is the National Pollutant Discharge Elimination System (NPDES) program, authorized in Section 402. In accordance with the NPDES program, pollutant discharges from point sources — a term that includes vessels — are prohibited unless a permit has been obtained. While sewage is defined as a pollutant under the act, sewage from cruise ships and other vessels is exempt from this statutory definition and is therefore exempt from the requirement to obtain an NPDES permit. Further, EPA regulations implementing the NPDES permit program provide that “discharges incidental to the normal operation of vessels” are excluded from regulation and thus from permit requirements (40 C.F.R. § 122.3(a)). However, a 2006 federal court ruling could result in changes to these regulations that would remove the current permitting exemption (see discussion of “Ballast Water” on page 14). Marine Sanitation Devices. Section 312 of the Clean Water Act seeks to address this gap by prohibiting the dumping of untreated or inadequately treated sewage from vessels into the navigable waters of the United States (defined in the

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act as within 3 miles of shore). Cruise ships are subject to this prohibition. It is implemented jointly by EPA and the Coast Guard. Under Section 312, commercial and recreational vessels with installed toilets are required to have marine sanitation devices (MSDs), which are designed to prevent the discharge of untreated sewage. EPA is responsible for developing performance standards for MSDs, and the Coast Guard is responsible for MSD design and operation regulations and for certifying MSD compliance with the EPA rules. MSDs are designed either to hold sewage for shore-based disposal or to treat sewage prior to discharge. Beyond 3 miles, raw sewage can be discharged. The Coast Guard regulations cover three types of MSDs (33 CFR Part 159). Large vessels, including cruise ships, use either Type II or Type III MSDs. In Type II MSDs, the waste is either chemically or biologically treated prior to discharge and must meet limits of no more than 200 fecal coliform per 100 milliliters and no more than 150 milligrams per liter of suspended solids. Type III MSDs store wastes and do not treat them; the waste is pumped out later and treated in an onshore system or discharged outside U.S. waters. Type I MSDs use chemicals to disinfect the raw sewage prior to discharge and must meet a performance standard for fecal coliform bacteria of not greater than 1,000 per 100 milliliters and no visible floating solids. Type I MSDs are generally only found on recreational vessels or others under 65 feet in length. The regulations, which have not been revised since 1976, do not require ship operators to sample, monitor, or report on their effluent discharges. Critics point out a number of deficiencies with this regulatory structure as it affects cruise ships and other large vessels. First, the MSD regulations only cover discharges of bacterial contaminants and suspended solids, while the NPDES permit program for other point sources typically regulates many more pollutants such as chemicals, pesticides, heavy metals, oil, and grease that may be released by cruise ships as well as land-based sources. Second, sources subject to NPDES permits must comply with sampling, monitoring, recordkeeping, and reporting requirements, which do not exist in the MSD rules. In addition, the Coast Guard, responsible for inspecting cruise ships and other vessels for compliance with the MSD rules, has been heavily criticized for poor enforcement of Section 312 requirements. In its 2000 report, the GAO said that Coast Guard inspectors “rarely have time during scheduled ship examinations to inspect sewage treatment equipment or filter systems to see if they are working properly and filtering out potentially harmful contaminants.” GAO reported that a number of factors limit the ability of Coast Guard inspectors to detect violations of environmental law and rules, including the inspectors’ focus on safety, the large size of a cruise ship, limited time and staff for inspections, and the lack of an


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element of surprise concerning inspections. [25] The Coast Guard carries out a wide range of responsibilities that encompass both homeland security (ports, waterways, and coastal security, defense readiness, drug and migrant interdiction) and non-homeland security (search and rescue, marine environmental protection, fisheries enforcement, aids to navigation). Since the September 11 terrorist attacks on the United States, the Coast Guard has focused more of its resources on homeland security activities. [26] One likely result is that less of the Coast Guard’s time and attention are available for vessel inspections for MSD or other environmental compliance. Annex IV of MARPOL was drafted to regulate sewage discharges from vessels. It has entered into force internationally and would apply to cruise ships that are flagged in ratifying countries, but because the United States has not ratified Annex IV, it is not mandatory that ships follow it when in U.S. waters. However, its requirements are minimal, even compared with U.S. rules for MSDs. Annex IV requires that vessels be equipped with a certified sewage treatment system or holding tank, but it prescribes no specific performance standards. Within three miles of shore, Annex IV requires that sewage discharges be treated by a certified MSD prior to discharge. Between three and 12 miles from shore, sewage discharges must be treated by no less than maceration or chlorination; sewage discharges beyond 12 miles from shore are unrestricted. Vessels are permitted to meet alternative, less stringent requirements when they are in the jurisdiction of countries where less stringent requirements apply. In U.S. waters, cruise ships and other vessels must comply with the regulations implementing Section 312 of the Clean Water Act. On some cruise ships, especially many of those that travel in Alaskan waters, sewage is treated using Advanced Wastewater Treatment (AWT) systems that generally provide improved screening, treatment, disinfection, and sludge processing as compared with traditional Type II MSDs. AWTs are believed to be very effective in removing pathogens, oxygen demanding substances, suspended solids, oil and grease, and particulate metals from sewage, but only moderately effective in removing dissolved metals and nutrients (nitrogen and phosphorous).[27] No Discharge Zones. Section 312 has another means of addressing sewage discharges, through establishment of no-discharge zones (NDZs) for vessel sewage. A state may completely prohibit the discharge of both treated and untreated sewage from all vessels with installed toilets into some or all waters over which it has jurisdiction (up to 3 miles from land). To create a no-discharge zone to protect waters from sewage discharges by cruise ships and other vessels, the state must apply to EPA under one of three categories.

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NDZ based on the need for greater environmental protection, and the state demonstrates that adequate pumpout facilities for safe and sanitary removal and treatment of sewage from all vessels are reasonably available. As of 2008, this category of designation has been used for 61 areas representing part or all of the waters of 26 states, including a number of inland states. NDZ for special waters found to have a particular environmental importance (e.g., to protect environmentally sensitive areas such as shellfish beds or coral reefs); it is not necessary for the state to show pumpout availability. This category of designation has been used twice (state waters within the Florida Keys National Marine Sanctuary and the Boundary Waters Canoe area of Minnesota). NDZ to prohibit the discharge of sewage into waters that are drinking water intake zones; it is not necessary for the state to show pumpout availability. This category of designation has been used to protect part of the Hudson River in New York.

Graywater. Under current federal law, graywater is not defined as a pollutant, nor is it generally considered to be sewage. By regulation, EPA exempts discharges incidental to the normal operation of a vessel, including graywater, from NPDES permit requirements (40 CFR § 122.3); however, a federal court has ordered EPA to set aside this rule (see discussion of Ballast Water, page 16). There are no separate federal effluent standards for graywater discharges. The Clean Water Act only includes graywater in its definition of sewage for the express purpose of regulating commercial vessels in the Great Lakes, under the Section 312 MSD requirements. Thus, currently graywater can be discharged by cruise ships anywhere — except in the Great Lakes, where the Section 312 MSD rules apply, but those rules prescribe limits only for bacterial contaminant content and total suspended solids in graywater. Pursuant to a state law in Alaska, graywater must be treated prior to discharge into that state’s waters (see discussion below, page 20). Solid Waste. Cruise ship discharges of solid waste are governed by two laws. Title I of the Marine Protection, Research and Sanctuaries Act (MPRSA, 33 U.S.C. 1402-1421) applies to cruise ships and other vessels and makes it illegal to transport garbage from the United States for the purpose of dumping it into ocean waters without a permit or to dump any material transported from a location outside the United States into U.S. territorial seas or the contiguous zone (within 12 nautical miles from shore) or ocean waters. EPA is responsible for issuing permits that regulate the disposal of materials at sea (except for dredged material


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disposal, for which the U.S. Army Corps of Engineers is responsible). Beyond waters that are under U.S. jurisdiction, no MPRSA permit is required for a cruise ship to discharge solid waste. The routine discharge of effluent incidental to the propulsion of vessels is explicitly exempted from the definition of dumping in the MPRSA.[28] The Act to Prevent Pollution from Ships (APPS, 33 U.S.C. 1901-1915) and its regulations, which implement U.S.-ratified provisions of MARPOL, also apply to cruise ships. APPS prohibits the discharge of all garbage within 3 nautical miles of shore, certain types of garbage within 12 nautical miles offshore, and plastic anywhere. As described above, it applies to all vessels, whether seagoing or not, regardless of flag, operating in U.S. navigable waters and the Exclusive Economic Zone (EEZ). It is administered by the Coast Guard which carries out inspection programs to insure the adequacy of port facilities to receive offloaded solid waste. Hazardous Waste. The Resource Conservation and Recovery Act (RCRA, 42 U.S.C. 6901-6991k) is the primary federal law that governs hazardous waste management through a “cradle-to-grave” program that controls hazardous waste from the point of generation until ultimate disposal. The act imposes management requirements on generators, transporters, and persons who treat or dispose of hazardous waste. Under this act, a waste is hazardous if it is ignitable, corrosive, reactive, or toxic, or appears on a list of about 100 industrial process waste streams and more than 500 discarded commercial products and chemicals. Treatment, storage, and disposal facilities are required to have permits and comply with operating standards and other EPA regulations. The owner or operator of a cruise ship may be a generator and/or a transporter of hazardous waste, and thus subject to RCRA rules. Issues that the cruise ship industry may face relating to RCRA include ensuring that hazardous waste is identified at the point at which it is considered generated; ensuring that parties are properly identified as generators, storers, treaters, or disposers; and determining the applicability of RCRA requirements to each. Hazardous waste generated onboard cruise ships are stored onboard until the wastes can be offloaded for recycling or disposal in accordance with RCRA. [29] A range of activities on board cruise ships generate hazardous wastes and toxic substances that would ordinarily be presumed to be subject to RCRA. Cruise ships are potentially subject to RCRA requirements to the extent that chemicals used for operations such as ship maintenance and passenger services result in the generation of hazardous wastes. However, it is not entirely clear what regulations apply to the management and disposal of these wastes. [30] RCRA rules that cover small-quantity generators (those that generate more than 100 kilograms but

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less than 1,000 kilograms of hazardous waste per month) are less stringent than those for large- quantity generators (generating more than 1,000 kilograms per month), and it is unclear whether cruise ships are classified as large or small generators of hazardous waste. Moreover, some cruise companies argue that they generate less than 100 kilograms per month and therefore should be classified in a third category, as “conditionally exempt small-quantity generators,” a categorization that allows for less rigorous requirements for notification, recordkeeping, and the like. [31] A release of hazardous substances by a cruise ship or other vessel could also theoretically trigger the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or Superfund, 42 U.S.C. 960 1-9675), but it does not appear to have been used in response to cruise ship releases. CERCLA requires that any person in charge of a vessel shall immediately notify the National Response Center of any release of a hazardous substance (other than discharges in compliance with a federal permit under the Clean Water Act or other environmental law) into waters of the United States or the contiguous zone. Notification is required for releases in amounts determined by EPA that may present substantial danger to the public health, welfare, or the environment. EPA has identified 500 wastes as hazardous substances under these provisions and issued rules on quantities that are reportable, covering releases as small as 1 pound of some substances (40 CFR Part 302). CERCLA authorizes the President (acting through the Coast Guard in coastal waters) to remove and provide for remedial action relating to the release. In addition to RCRA, hazardous waste discharges from cruise ships are subject to Section 311 of the Clean Water Act, which prohibits the discharge of hazardous substances in harmful quantities into or upon the navigable waters of the United States, adjoining shorelines, or into or upon the waters of the contiguous zone. Bilge Water. Section 311 of the Clean Water Act, as amended by the Oil Pollution Act of 1990 (33 U.S.C. 2701-2720), 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. EEZ (extending 200 miles offshore). Coast Guard regulations (33 CFR § 151.10) prohibit discharge of oil within 12 miles from shore, unless passed through a 15-ppm oil water separator, and unless the discharge does not cause a visible sheen. Beyond 12 miles, oil or oily mixtures can be discharged while a vessel is proceeding en route and if the oil content without dilution is less than 100 ppm. Vessels are required to maintain an Oil


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Record Book to record disposal of oily residues and discharges overboard or disposal of bilge water. In addition to Section 311 requirements, the Act to Prevent Pollution from Ships (APPS) implements MARPOL Annex I concerning oil pollution. 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, or while at a port under U.S. jurisdiction. To implement APPS, the Coast Guard has promulgated regulations prohibiting the discharge of oil or oily mixtures into the sea within 12 nautical miles of the nearest land, except under limited conditions. However, because most cruise lines are foreign registered and because APPS only applies to foreign ships within U.S. navigable waters, the APPS regulations have limited applicability to cruise ship operations. In addition, most cruise lines have adopted policies that restrict discharges of machinery space waste within three miles from shore. Ballast Water. Clean Water Act regulations currently exempt ballast water discharges incidental to the normal operation of cruise ships and other vessels from NPDES permit requirements (see above discussions concerning sewage and graywater). Because of the growing problem of introduction of invasive species into U.S. waters via ballast water, in January 1999, a number of conservation organizations, fishing groups, native American tribes, and water agencies petitioned EPA to repeal its 1973 regulation exempting ballast water discharge, arguing that ballast water should be regulated as the “discharge of a pollutant” under the Clean Water Act’s Section 402 permit program. EPA rejected the petition in September 2003, saying that the “normal operation” exclusion is longstanding agency policy, to which Congress has acquiesced twice (in 1979 and 1996) when it considered the issue of aquatic nuisance species in ballast water and did not alter EPA’s CWA interpretation. [32] Further, EPA said that other ongoing federal activities related to control of invasive species in ballast water are likely to be more effective than changing the NPDES rules. [33] Until 2004, these efforts to limit ballast water discharges by cruise ships and other vessels were primarily voluntary, except in the Great Lakes. Since then, all vessels equipped with ballast water tanks must have a ballast water management plan. [34] After the denial of their administrative petition, the environmental groups filed a lawsuit seeking to force EPA to rescind the regulation that exempts ballast water discharges from CWA permitting. In March 2005, a federal district court ruled in favor of the groups, and in September 2006, the court remanded the matter to EPA with an order that the challenged regulation be set aside by September 30, 2008 (Northwest Environmental Advocates v. EPA, No. C 0305760 SI (N.D.Cal, September 18, 2006)). The district court rejected EPA’s

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contention that Congress had previously acquiesced in exempting the “normal operation” of vessels from CWA permitting and disagreed with EPA’s argument that the court’s two-year deadline creates practical difficulties for the agency and the affected industry. Significantly, while the focus of the environmental groups’ challenge was principally to EPA’s permitting exemption for ballast water discharges, the court’s ruling — and its mandate to EPA to rescind the exemption in 40 CFR § 122.3(a) — applies fully to other types of vessel discharges that are covered by the long-standing regulatory exemption, including graywater and bilge water. The government has appealed the district court’s ruling, and the parties are waiting for a ruling from the appeals court. On June 17, while waiting for the court of appeals or Congress to provide relief from the district court’s order, EPA proposed two CWA general permits that it believes could be finalized by September 30. [35] One of these permits (the Vessel General Permit, or VGP) would apply to large recreational and commercial vessels, including cruise ships. The draft VGP proposes that most of the categories of waste streams from the normal operations of these vessels would be controlled by best management practices (BMPs) that are described in the permit, many of which are already practiced or are required by existing regulations. To control ballast water discharges, the draft VGP primarily relies on existing Coast Guard requirements (at 33 CFR Part 151, Subparts C and D), plus certain flushing and ballast exchange practices, especially for vessels in Pacific nearshore areas. To control discharges of bilge water, the draft VGP provides for BMPs, which EPA indicates are consistent with current rules and industry practice. The draft VGP does not include sewage discharges from vessels, as these are already regulated under CWA Section 312. The draft VGP includes a specific provision governing graywater discharges from cruise ships. It would include BMPs as well as numeric limits for fecal coliform and residual chlorine, and it includes operational limits on cruise ship graywater discharges in nutrient-impaired waters, such as Chesapeake Bay or Puget Sound. (The second proposed permit would be for recreational vessels less than 79 feet in length.) The 110th Congress has been considering ballast water discharge issues, specifically legislation to provide a uniform national approach for addressing aquatic nuisance species from ballast water under a program administered by the Coast Guard (S. 1578, ordered reported by the Senate Commerce Committee on September 27, 2007; and H.R. 2830, passed by the House April 28, 2008). Some groups oppose S. 1578 and H.R. 2830, because the legislation would preempt states from enacting ballast water management programs more stringent than Coast Guard requirements, while the CWA does allow states to adopt


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requirements more stringent than in federal rules. Also, while the CWA permits citizen suits to enforce the law, the pending legislation includes no citizen suit provisions. Air Pollution. The Clean Air Act (42 U.S.C. 7401 et seq.) is the principal federal law that addresses air quality concerns. It requires EPA to set health-based standards for ambient air quality, sets standards for the achievement of those standards, and sets national emission standards for large and ubiquitous sources of air pollution, including mobile sources. Cruise ships emissions were not regulated until February 2003. At that time, EPA promulgated emission standards for new marine diesel engines on large vessels (called Category 3 marine engines) such as container ships, tankers, bulk carriers, and cruise ships flagged or registered in the United States. [36] The 2003 rule resulted from settlement of litigation brought by the environmental group Bluewater Network after it had petitioned EPA to issue stringent emission standards for large vessels and cruise ships. [37] Standards in the rule are equivalent to internationally negotiated standards set in Annex VI of the MARPOL protocol for nitrogen oxides, which engine manufacturers currently meet, according to EPA. [38] Emissions from these large, primarily ocean-going vessels (including container ships, tankers, bulk carriers, as well as cruise ships) had not previously been subject to EPA regulation. The rule is one of several EPA regulations establishing emissions standards for nonroad engines and vehicles, under Section 213(a) of the Clean Air Act. Smaller marine diesel engines are regulated under rules issued in 1996 and 1999. In the 2003 rule, EPA announced that over the next two years it would continue to review issues and technology related to emissions from large marine vessel engines in order to promulgate additional, more stringent emission standards for very large marine engines and vessels by April 2007. Addressing long-term standards in a future rulemaking, EPA said, could facilitate international efforts through the IMO (since the majority of ships used in international commerce are flagged in other nations), while also permitting the United States to proceed, if international standards are not adopted in a timely manner. Environmental groups criticized EPA for excluding foreign-flagged vessels that enter U.S. ports from the marine diesel engine rules and challenged the 2003 rules in federal court. The rules were upheld in a ruling issued June 22, 2004. [39] EPA said that it will consider including foreign vessels in the future rulemaking to consider more stringent standards. In April 2007, EPA announced an extension of the deadline that had been announced in 2003 for new Category 3 marine diesel engine standards — until December 17, 2009. EPA explained that more time was needed to assess advanced emission control technologies and to coordinate with the IMO. Most

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recently, EPA published an Advance Notice of Proposed Rulemaking seeking public comment on the scope of the rules that the agency should propose for a second tier of Category 3 engines. [40] Some groups are displeased with EPA’s delay, and in response, legislation has been introduced in the 1 10th Congress that would set specific standards and deadlines to limit the sulfur content of fuel used by U.S. and foreign-flagged marine vessels when they enter or leave U.S. ports, and to require advanced pollution controls for other air emissions from such marine vessels (S. 1499/H.R. 2548). As noted previously (see discussion of MARPOL, page 8), the 1 10th Congress is considering legislation to implement MARPOL Annex VI, concerning standards to control air pollution from vessels. EPA also is participating in international discussions to strengthen the requirements of Annex VI. Considerations of Geographic Jurisdiction. The various laws and regulations described here apply to different geographic areas, depending on the terminology used. For example, the Clean Water Act treats navigable waters, the contiguous zone, and the ocean as distinct entities. The term “navigable waters” is defined to mean the waters of the United States, including the territorial seas (33 U.S.C. § 1362(7)). In turn, the territorial seas are defined in that act as extending a distance of 3 miles seaward from the baseline (33 U.S.C. §1362(8)); the baseline generally means the land or shore. In 1988, President Reagan signed a proclamation (Proc. No. 5928, December 27, 1988, 54 Federal Register 777) providing that the territorial sea of the United States extends to 12 nautical miles from the U.S. baseline. However, that proclamation had no effect on the geographic reach of the Clean Water Act. The contiguous zone is defined in the CWA to mean the entire zone established by the United States under Article 24 of the Convention of the Territorial Sea and the Contiguous Zone (33 U.S.C. § 1362(9)). That convention defines “contiguous zone” as extending from the baseline from which the territorial sea is measured to not beyond 12 miles. In 1999, President Clinton signed a proclamation (Proc. No. 7219 of August 2, 1999, 64 Federal Register 48701) giving U.S. authorities the right to enforce customs, immigration, or sanitary laws at sea within 24 nautical miles from the baseline, doubling the traditional 12-mile width of the contiguous zone. As with the 1988 presidential proclamation, this proclamation did not amend any statutory definitions (as a general matter, a presidential proclamation cannot amend a statute). Thus, for purposes of the Clean Water Act, the territorial sea remains 3 miles wide, and the contiguous zone extends from 3 to 12 miles. Under CERCLA, “navigable waters” means waters of the United States, including the territorial seas (42 U.S.C.


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§9601(15)), and that law incorporates the Clean Water Act’s definitions of “territorial seas” and “contiguous zone” (42 U.S.C. §9601(30)). The CWA defines the “ocean” as any portion of the high seas beyond the contiguous zone (33 U.S.C. §1362(10)). In contrast, the MPRSA defines “ocean waters” as the open seas lying seaward beyond the baseline from which the territorial sea is measured, as provided for in the Convention of the Territorial Sea and the Contiguous Zone (33 U.S.C. §1402(b)). Limits of jurisdiction are important because they define the areas where specific laws and rules apply. For example, the Clean Water Act MSD standards apply to sewage discharges from vessels into or upon the navigable waters, and Section 402 NPDES permits are required for point source discharges (excluding vessels) into the navigable waters. Section 311 of the CWA, as amended by the Oil Pollution Act, addresses discharges of oil or hazardous substances into or upon the navigable waters of the United States or the waters of the contiguous zone. Provisions of the Act to Prevent Pollution from Ships (APPS, 33 U.S .C. § § 1901-1915) concerning discharges of oil and noxious substances apply to navigable waters. Other provisions of that same act concerning garbage and plastics apply to navigable waters or the EEZ, but the term “navigable waters” is not defined in APPS. The MPRSA regulates ocean dumping within the area extending 12 nautical miles seaward from the baseline and regulates transport of material by U.S.-flagged vessels for dumping into ocean waters. Further complicating jurisdictional considerations is the fact that the Clean Water Act refers to these distances from shore in terms of miles, without other qualification, which is generally interpreted to mean an international mile or statute mile. APPS, the MPRSA, and the two presidential proclamations refer to distances in terms of nautical miles from the baseline. These two measures are not identical: a nautical mile is a unit of distance used primarily at sea and in aviation; it equals 6,080 feet and is 15% longer than an international or statute mile. [41]

Alaskan Activities In Alaska, where tourism and commercial fisheries are key contributors to the economy, cruise ship pollution has received significant attention. After the state experienced a three-fold increase in the number of cruise ship passengers visits during the 1990s, [42] concern by Alaska Natives and other groups over impacts of cruise ship pollution on marine resources began to increase. In one prominent example of environmental violations, in July 1999, Royal Caribbean Cruise Lines entered a federal criminal plea agreement involving total penalties of $6.5 million

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for violations in Alaska, including knowingly discharging oil and hazardous substances (including dry-cleaning and photo processing chemicals). The company admitted to a fleet-wide practice of discharging oil-contaminated bilge water. The Alaska penalties were part of a larger $18 million total federal plea agreement involving environmental violations in multiple locations, including Florida, New York, and California. Public concern about the Royal Caribbean violations led the state to initiate a program in December 1999 to identify cruise ship waste streams. Voluntary sampling of large cruise ships in 2000 indicated that waste treatment systems on most ships did not function well and discharges greatly exceeded applicable U.S. Coast Guard standards for Type II MSDs. Fecal coliform levels sampled during that period averaged 12.8 million colonies per 100 milliliters in blackwater and 1.2 million in graywater, far in excess of the Coast Guard standard of 200 fecal coliforms per 100 milliliters. Federal Legislation. Concurrent with growing regional interest in these problems, attention to the Alaska issues led to passage of federal legislation in December 2000 (Certain Alaskan Cruise Ship Operations, Division B, Title XIV of the Miscellaneous Appropriations Bill, H.R. 5666, in the Consolidated Appropriations Act, 2001 (P.L. 106-554); 33 U.S.C. 1901 Note). This law established standards for vessels with 500 or more overnight passengers and generally prohibited discharge of untreated sewage and graywater in navigable waters of the United States within the state of Alaska. It authorized EPA to promulgate standards for sewage and graywater discharges from cruise ships in these waters. [43] Until such time as EPA issues regulations, cruise ships may discharge treated sewage wastes in Alaska waters only while traveling at least 6 knots and while at least 1 nautical mile from shore, provided that the discharge contains no more than 200 fecal coliforms per 100 ml and no more than 150 mg/l total suspended solids (the same limits prescribed in federal regulations for Type II MSDs). The law also allows for discharges of treated sewage and graywater inside of one mile from shore and at speeds less than 6 knots (thus including stationary discharges while a ship is at anchor) for vessels with systems that can treat sewage and graywater to a much stricter standard. Such vessels must meet these minimum effluent standards: no more than 20 fecal coliforms per 100 ml, no more than 30 mg/l of total suspended solids, and total residual chlorine concentrations not to exceed 10 mg/l. The legislation requires sampling, data collection, and recordkeeping by vessel operators to facilitate Coast Guard oversight and enforcement. Regulations to implement the federal law were issued by the U.S. Coast Guard in July 2001 and became effective immediately upon publication.


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[44] The regulations stipulate minimum sampling and testing procedures and provide for administrative and criminal penalties for violations of the law, as provided in the legislation. Pursuant to Title IV, EPA 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. In particular, EPA sampled wastewater from four cruise ships that operated in Alaska during the summers of 2004 and 2005 to characterize graywater and sewage generated onboard and to evaluate the performance of various treatment systems. Much of the information collected through this effort is summarized in the 2007 Draft Cruise Ship Discharge Assessment Report. In the 109th Congress, the House approved legislation, H.R. 5681, with a provision (Section 410) directing the Coast Guard to conduct a demonstration project on the methods and best practices of the use of smokestack scrubbers on cruise ships that operate in the Alaska cruise trade. The Senate did not act on H.R. 5681 before the 109th Congress adjourned in December 2006. Alaska State Legislation and Initiatives. Building on the federal legislation enacted in 2000, the state of Alaska enacted its own law in June 2001 (AS 46.03.460-AS 46.03.490). The state law sets standards and sampling requirements for the underway discharge of blackwater in Alaska that are identical to the blackwater/sewage standards in the federal law. However, because of the high fecal coliform counts detected in graywater in 2000, the state law also extends the effluent standards to discharges of graywater. Sampling requirements for all ships took effect in 2001, as did effluent standards for blackwater discharges by large cruise ships (defined as providing overnight accommodations to 250 or more). Effluent standards for graywater discharges by large vessels took effect in 2003. Small ships (defined as providing overnight accommodations for 50 to 249 passengers) were allowed three years to come into compliance with all effluent standards. The law also established a scientific advisory panel to evaluate the effectiveness of the law’s implementation and to advise the state on scientific matters related to cruise ship impacts on the Alaskan environment and public health. In February 2004, the state reported on compliance with the federal and state requirements for the years 200 1-2003. [45] According to the state, the federal and state standards have prompted large ships to either install advanced wastewater treatment systems that meet the effluent standards or to manage wastes by holding all of their wastewater for discharge outside of Alaskan waters (beyond 3 miles from shore). As of 2003, the majority of large ships (56%) had installed advanced technology (compared with 8% that had done so in 2001), while the remaining

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44% discharge outside of Alaska waters. As a result, the quality of wastewater discharged from large ships has improved dramatically, according to the state: the majority of conventional and toxic pollutants that ships must sample for were not detected, and test results indicate that wastewater from large ships with advanced wastewater treatment systems does not pose a risk to aquatic organisms or to human health, even during stationary discharge. Small ships, however, had not installed new wastewater treatment systems, and the effluent quality has remained relatively constant, with discharge levels for several pollutants regularly exceeding state water quality standards. In particular, test results indicated that concentrations of free chlorine, fecal coliform, copper, and zinc from stationary smaller vessels pose some risk to aquatic life and also to human health in areas where aquatic life is harvested for raw consumption. In addition to the state’s 2001 action, in August 2006 Alaska voters approved a citizen initiative requiring cruise lines to pay the state a $50 head tax for each passenger and a corporate income tax, increasing fines for wastewater violations, and mandating new environmental regulations for cruise ships (such as a state permit for all discharges of treated wastewater). Revenues from the taxes will go to local communities affected by tourism and into public services and facilities used by cruise ships. Supporters of the initiative contend that the cruise industry does not pay enough in taxes to compensate for its environmental harm to the state and for the services it uses. Opponents argued that the initiative would hurt Alaska’s competitiveness for tourism.

Other State Activities Activity to regulate or prohibit cruise ship discharges also has occurred in several other states. In April 2004, the state of Maine enacted legislation governing discharges of graywater or mixed blackwater/graywater into coastal waters of the state (Maine LD. 1158). The legislation applies to large cruise ships (with overnight accommodations for 250 or more passengers) and allows such vessels into state waters after January 1, 2006, only if the ships have advanced wastewater treatment systems, comply with discharge and recordkeeping requirements under the federal Alaska cruise ship law, and get a permit from the state Department of Environmental Protection. Under the law, prior to 2006, graywater dischargers were allowed if the ship operated a treatment system conforming to requirements for continuous discharge systems under the Alaska federal and state laws. In addition, the legislation required the state to apply to EPA for designation of up to


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50 No Discharge Zones, in order that Maine may gain federal authorization to prohibit blackwater discharges into state waters. EPA approved the state’s NDZ request for Casco Bay in June 2006. California enacted three bills in 2004. One bars cruise ships from discharging treated wastewater while in the state’s waters (Calif. A.B. 2672). Another prohibits vessels from releasing graywater (Calif. A.B. 2093), and the third measure prevents cruise ships from operating waste incinerators (Calif. A.B. 471). Additionally, in 2003 California enacted a law that bans passenger ships from discharging sewage sludge and oil bilge water (Calif. A.B. 121), as well as a bill that prohibits vessels from discharging hazardous wastes from photo-processing and dry cleaning operations into state waters (Calif. A.B. 906). Another measure was enacted in 2006: California S.B. 497 requiring the state to adopt ballast water performance standards by January 2008 and setting specific deadlines for the removal of different types of species from ballast water, mandating that ship operators remove invasive species (including bacteria) by the year 2020. Several states, including Florida, Washington, and Hawaii, have entered into memoranda of agreement with the industry (through the International Council of Cruise Lines and related organizations) providing that cruise ships will adhere to certain practices concerning waste minimization, waste reuse and recycling, and waste management. For example, under a 2001 agreement between industry and the state of Florida, cruise lines must eliminate wastewater discharges in state waters within 4 nautical miles off the coast of Florida, report hazardous waste offloaded in the United States by each vessel on an annual basis, and submit to environmental inspections by the U.S. Coast Guard. Similarly, in April 2004 the Washington Department of Ecology, Northwest Cruise Ship Association, and Port of Seattle signed a memorandum of understanding (MOU) that would allow cruise ships to discharge wastewater treated with advanced wastewater treatment systems into state waters and would prohibit the discharge of untreated wastewater and sludge. Environmental advocates are generally critical of such voluntary agreements, because they lack enforcement and penalty provisions. States respond that while the Clean Water Act limits a state’s ability to control cruise ship discharges, federal law does not bar states from entering into voluntary agreements that have more rigorous requirements. [46] In January 2005 the Department of Ecology reported that cruise ships visiting the state during the 2004 sailing season mostly complied with the MOU to stop discharging untreated wastewater, leading to some improvement in management of wastes. Although enforcement of what is essentially a voluntary agreement is difficult, the state argues that having something in place to protect water quality, while not lessening the state’s authority, is beneficial. [47]

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Industry Initiatives Pressure from environmental advocates, coupled with the industry’s strong desire to promote a positive image, have led the cruise ship industry to respond with several initiatives. In 2001, members of the International Council of Cruise Lines (ICCL), which represents 16 of the world’s largest cruise lines, adopted a set of waste management practices and procedures for their worldwide operations building on regulations of the IMO and U.S. EPA. The guidelines generally require graywater and blackwater to be discharged only while a ship is underway and at least 4 miles from shore and require that hazardous wastes be recycled or disposed of in accordance with applicable laws and regulations. Twelve major cruise line companies also have implemented Safety Management System (SMS) plans for developing enhanced wastewater systems and increased auditing oversight. These SMS plans are certified in accordance with the IMO’s International Safety Management Code. The industry also is working with equipment manufacturers and regulators to develop and test technologies in areas such as lower emission turbine engines and ballast water management for elimination of non-native species. Environmental groups commend industry for voluntarily adopting improved management practices but also believe that enforceable standards are preferable to voluntary standards, no matter how well intentioned. [48] The ICCL joined with the environmental group Conservation International (CI) to form the Ocean Conservation and Tourism Alliance to work on a number of issues. In December 2003 they announced conservation efforts in four areas to protect biodiversity in coastal areas: improving technology for wastewater management aboard cruise ships, working with local governments to protect the natural and cultural assets of cruise destinations, raising passenger and crew awareness and support of critical conservation issues, and educating vendors to lessen the environmental impacts of products from cruise ship suppliers. Because two-thirds of the top cruise destinations in the world are located in the Caribbean and Mediterranean, two important biodiversity regions, in March 2006 ICCL and CI announced a joint initiative to develop a map integrating sensitive marine areas into cruise line navigational charts, with the goal of protecting critical marine and coastal ecosystems. In May 2004, Royal Caribbean Cruises Ltd. announced plans to retrofit all vessels in its 29-ship fleet with advanced wastewater treatment technology by 2008, becoming the first cruise line to commit to doing so completely. The company had been the focus of efforts by the environmental group Oceana to pledge to adopt measures that will protect the ocean environment and that could


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serve as a model for others in the cruise ship industry, in part because of the company’s efforts to alter its practices following federal enforcement actions in the 1 990s for environmental violations that resulted in RCCL paying criminal fines that totaled $27 million.

ISSUES FOR CONGRESS Concerns about cruise ship pollution raise issues for Congress in three broad areas: adequacy of laws and regulations, research needs, and oversight and enforcement of existing programs and requirements. Attention to these issues is relatively recent, and more assessment is needed of existing conditions and whether current steps (public and private) are adequate. Bringing the issues to national priority sufficient to obtain resources that will address the problems is a challenge. Laws and Regulations. A key issue is whether the several existing U.S. laws, international protocols and standards, state activities, and industry initiatives described in this report adequately address management of cruise ship pollution, or whether legislative changes are needed to fill in gaps, remedy exclusions, or strengthen current requirements. As EPA noted in its 2000 white paper, certain cruise ship waste streams such as oil and solid waste are regulated under a comprehensive set of laws and regulations, but others, such as graywater, are excluded or treated in ways that appear to leave gaps in coverage. [49] Graywater is one particular area of interest, since investigations, such as sampling by state of Alaska officials, have found substantial contamination of cruise ship graywater from fecal coliform, bacteria, heavy metals, and dissolved plastics. State officials were surprised that graywater from ships’ galley and sink waste streams tested higher for fecal coliform than did the ships’ sewage lines. [50] One view advocating strengthened requirements came from the U.S. Commission on Ocean Policy. In its 2004 final report, the Commission advocated clear, uniform requirements for controlling the discharge of wastewater from large passenger vessels, as well as consistent interpretation and enforcement of those requirements. It recommended that Congress establish a new statutory regime that should include: • •

uniform discharge standards and waste management procedures. thorough recordkeeping requirements to track the waste management process.

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required sampling, testing, and monitoring by vessel operators using uniform protocols flexibility and incentives to encourage industry investment in innovative treatment technologies. [51]

A proposal reflecting some of these concepts, the Clean Cruise Ship Act, was introduced in the 109th Congress as S. 793 (Durbin) and H.R. 1636 (Farr), but Congress did not act on either bill. The bills were free-standing legislation that would not have amended any current law, nor ratified Annex IV of MARPOL. The legislation would have prohibited cruise vessels entering a U.S. port from discharging sewage, graywater, or bilge water into waters of the United States, including the Great Lakes, except in compliance with prescribed effluent limits and management standards. It further would have directed EPA and the Coast Guard to promulgate effluent limits for sewage and graywater discharges from cruise vessels that were no less stringent than the more restrictive standards under the existing federal Alaska cruise ship law described above. It would have required cruise ships to treat wastewater wherever they operate and authorized broadened federal enforcement authority, including inspection, sampling, and testing. Environmental advocates supported this legislation. Industry groups argued that it targeted an industry that represents only a small percentage of the world’s ships and that environmental standards of the industry, including voluntary practices, already meet or exceed current international and U.S. regulations. Similar legislation has been introduced in the 1 10th Congress (S. 2881). As noted above, some states have passed legislation to regulate cruise ship discharges. If this state-level activity increases, Congress could see a need to develop federal legislation that would harmonize differences in the states’ approaches. Another issue for Congress is the status of EPA’s efforts to manage or regulate cruise ship wastes. As discussed previously, in 2000 Congress authorized EPA to issue standards for sewage and graywater discharges from large cruise ships operating in Alaska. The agency has been collecting information and assessing the need for additional standards, beyond those provided in P.L. 106554, but has not yet proposed any rules. In December 2007, EPA released a Draft Cruise Ship Discharge Assessment Report that builds on the 2000 White Paper and partially responds to the 2000 petition by Bluewater Network and other groups that seek to force EPA to address cruise ship pollution (see page 2). The draft report examines five cruise ship waste streams (sewage, graywater, oily bilge water, solid waste, and hazardous waste) and discusses how the waste


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streams are managed and current actions by the federal government to address the waste streams. However, while the draft report summarizes available information, it does not include recommendations or options to address management of cruise ship wastes. A final report, expected at the end of 2008, could include such alternatives. Other related issues of interest could include harmonizing the differences presented in U.S. laws for key jurisdictional terms as they apply to cruise ships and other types of vessels; providing a single definition of “cruise ship,” which is defined variously in federal and state laws and rules, with respect to gross tonnage of ships, number of passengers carried, presence of overnight passenger accommodations, or primary purpose of the vessel; or requiring updating of existing regulations to reflect improved technology (such as the MSD rules that were issued in 1976). Research. Several areas of research might help improve understanding of the quantities of waste generated by cruise ships, impacts of discharges and emissions, and the potential for new control technologies. In the 2007 Draft Cruise Ship Discharge Assessment report, EPA stated that it is evaluating technologies for the treatment of sewage and graywater, including some now used for land-based treatment that could be adapted for shipboard application, and anticipates making these analyses publicly available later in 2008. [52] The U.S. Commission on Ocean Policy noted in its 2004 final report that research can help identify the degree of harm represented by vessel pollution and can assist in prioritizing limited resources to address the most significant threats. The commission identified several directions for research by the Coast Guard, EPA, NOAA, and other appropriate entities on the fates and impacts of vessel pollution: [53] • • • •

•

Processes that govern the transport of pollutants in the marine environment. Small passenger vessel practices, including the impacts of stationary discharges. Disposal options for concentrated sludge resulting from advanced sewage treatment on large passenger vessels. Cumulative impacts of commercial and recreational vessel pollution on particularly sensitive ecosystems, such as coastal areas with low tidal exchange and coral reef systems. Impacts of vessel air emissions, particularly in ports and inland waterways where the surrounding area is already having difficulty meeting air quality standards.

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Oversight and Enforcement. The 2000 GAO report documented — and EPA’s 2000 cruise ship white paper acknowledged — that existing laws and regulations may not be adequately enforced or implemented. GAO said there is need for monitoring of the discharges from cruise ships in order to evaluate the effectiveness of current standards and management. GAO also said that increased federal oversight of cruise ships by the Coast Guard and other agencies is needed concerning maintenance and operation of pollution prevention equipment, falsifying of oil record books (which are required for compliance with MARPOL), and analysis of records to verify proper off-loading of garbage and oily sludge to onshore disposal facilities. [54] The Coast Guard has primary enforcement responsibility for many of the federal programs concerning cruise ship pollution. A key oversight and enforcement issue is the adequacy of the Coast Guard’s resources to support its multiple homeland and non-homeland security missions. The resource question as it relates to vessel inspections was raised even before the September 11 terrorist attacks, in the GAO’s 2000 report. The same question has been raised since then, in light of the Coast Guard’s expanded responsibilities for homeland security and resulting shift in operations, again by the GAO and others. [55] In its 2000 report, GAO also found that the process for referring cruise ship violations to other countries does not appear to be working, either within the Coast Guard or internationally, and GAO recommended that the Coast Guard work with the IMO to encourage member countries to respond when pollution cases are referred to them and that the Coast Guard make greater efforts to periodically follow up on alleged pollution cases occurring outside U.S. jurisdiction.

REFERENCE [1]

[2] [3] [4]

Lloyd’s Maritime Information Services, on the website of the Maritime International Secretaries Services, Shipping and World Trade Facts, at [http://www.marisec.org/ shippingfacts/keyfacts/] International Council of Cruise Lines, “The Cruise Industry, 2005 Economic Summary.” U.S. Environmental Protection Agency, “Cruise Ship White Paper,” August 22, 2000, p. 3. Hereafter, EPA White Paper Bell, Tom, “Experts: Mega-birth Needed for Cruise Ships,” Portland Press Herald, Sept. 28, 2007.

Cruise Ship Pollution [5] [6]

[7]

[8] [9]

[10]

[11] [12] [13]

[14]

[15]

[16] [17] [18]

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Bureau of Transportation Statistics, Department of Transportation, “Summary of Cruise Ship Waste Streams.” U.S. General Accounting Office, Marine Pollution: Progress Made to Reduce Marine Pollution by Cruise Ships, but Important Issues Remain, GAO/RCED-00-48, February 2000. 70 pp. Hereafter, 2000 GAO Report. Bluewater Network, Petition to the Administrator, U.S. Environmental Protection Agency, March 17, 2000. The petition was amended in 2000 to request that EPA also examine air pollution from cruise ships; see discussion below (page 16). EPA White Paper. U.S. Environmental Protection Agency, Office of Water, “Draft Cruise Ship Discharge Assessment Report,” EPA842-R-07-005, December 2007. Hereafter, EPA Draft Discharge Assessment Report. See: U.S. Environmental Protection Agency, “Draft Cruise Ship Discharge Assessment Report, Notice of availability and request for public comments,” Federal Register, vol. 72, no. 244, Dec. 20, 2007, p. 72353. The Ocean Conservancy, “Cruise Control, A Report on How Cruise Ships Affect the Marine Environment,” May 2002, p. 13. Hereafter, “Cruise Control.” EPA Draft Discharge Assessment Report, pp. 3-5 - 3-6. Cruise Control, p. 15. The Center for Environmental Leadership in Business, “A Shifting Tide, Environmental Challenges and Cruise Industry Responses,” p. 14. Hereafter, “Shifting Tide.” Bluewater Network, “Cruising for Trouble: Stemming the Tide of Cruise Ship Pollution,” March 2000, p. 5. Hereafter, “Cruising for Trouble.” A report prepared for an industry group estimated that a 3,000-person cruise ship generates 1.1 million gallons of graywater during a seven-day cruise. Don K. Kim, “Cruise Ship Waste Dispersion Analysis Report on the Analysis of Graywater Discharge,” presented to the International Council of Cruise Lines, September 14, 2000. National Research Council, Committee on Shipboard Wastes, Clean Ships, Clean Ports, Clean Oceans: Controlling Garbage and Plastic Wastes at Sea (National Academy Press, 1995), Table 2-3, pp. 38-39. Ibid., p. 126. “Shifting Tide,” p. 16 Statement of Catherine Hazelwood, The Ocean Conservancy, “Ballast Water Management: New International Standards and NISA Reauthorization,” Hearing, House Transportation and Infrastructure

174

[19]

[20] [21] [22]

[23]

[24] [25] [26]

[27] [28]

[29] [30] [31] [32] [33]

Claudia Copeland Subcommittee on Water Resources and Environment, 108th Cong., 2nd sess., March 25, 2004. David Pimentel, Lori Lach, Rodolfo Zuniga, and Doug Morrison, “Environmental and Economic Costs Associated with Non-indigenous Species in the United States,” presented at AAAS Conference, Anaheim, CA, January 24, 1999. 68 Federal Register 9751, 9753, February 28, 2003. Ibid., pp. 9751, 9756. The majority of cruise ships are foreign-flagged, primarily in Liberia and Panama. Both of these countries have ratified all six of the MARPOL annexes. For information, see [http://www.imo.org/]. For additional information, see CRS Report RL34548, Air Pollution from Ships:MARPOL Annex VI and Other Control Options, by James E. McCarthy. 2000 GAO Report, pp. 19-21. 2000 GAO Report, pp. 34-35, 13. The Homeland Security Act of 2002 (P.L. 107-296) transferred the entirety of the Coast Guard from the Department of Transportation to the Department of Homeland Security. For discussion, see archived CRS Report RS21 125, Homeland Security: Coast Guard Operations — Background and Issues for Congress. EPA Draft Discharge Assessment Report, p. 2-13. The 1988 Shore Protection Act (33 U.S.C. 2601-2603) prohibits vessels from transporting municipal or commercial waste in U.S. coastal waters without a permit issued by the Department of Transportation. It was intended to minimize trash, medical debris, and potentially harmful materials from being deposited in U.S. coastal waters. However, its provisions exclude waste generated by a vessel during normal operations and thus do not apply to cruise ships. EPA Draft Discharge Assessment Report, pp. 6-4, 6-7. EPA White Paper, p. 10. “Cruising for Trouble,” p. 5. 68 Federal Register 53165, September 9, 2003. In 1990, Congress enacted the Non-indigenous Aquatic Nuisance Prevention and Control Act (16 U.S.C. 4701 et seq) to focus federal efforts on non-indigenous, invasive, aquatic nuisance species, specifically when such species occur in ballast water discharges. That law, as amended by the National Invasive Species Act of 1996, delegated authority to the Coast Guard to establish a phased-in regulatory program for ballast water.


175

[34] For information, see CRS Report RL32344, Ballast Water Management to Combat Invasive Species, by Eugene H. Buck. [35] U.S. Environmental Protection Agency, “Draft National Pollutant Discharge Elimination System (NPDES) General Permits for Discharges Incidental to the Normal Operation of Vessels,” 73 Federal Register 117, June 17, 2008, pp. 34296-343049. [36] U.S. Environmental Protection Agency, “Final Rule, Control of Emissions from New Marine Compression-Ignition Engines at or Above 30 Liters Per Cylinder,” 68 Federal Register 9746-9789, February 28, 2003. [37] For information, see [http://www.earthjustice.org/news/display.html? ID=53] and [http://www.earthjustice.org/urgent/display.html?ID=158]. [38] Annex VI, which came into force internationally in May 2005, also regulates ozone- depleting emissions, sulfur oxides, and shipboard incineration, but there are no restrictions on particulate matter, hydrocarbons, or carbon monoxide. [39] Bluewater Network v. EPA, D.C.Cir., No. 03-1120, June 22, 2004. [40] U.S. Environmental Protection Agency, “Control of Emissions from New Marine Compression-Ignition Engines at or Above 30 Liters per Cylinder; Proposed Rule,” Federal Register, vol. 72, no. 235, Dec. 7, 2007, pp. 6952169552. [41] For an explanation of these terms, see [http://encyclopedia.thefree dictionary.com/Statute%20mile]. [42] In 2003, the number of cruise ship passengers in Southeast Alaska was about 800,000, with tens of thousands of crew, in addition. By comparison, the state’s population is approximately 650,000. Roughly 95% of the current cruise ship traffic is concentrated in Southeast Alaska, a region with a population of approximately 73,000 people. Alaska Department of Environmental Conservation, Commercial Passenger Vessel Environmental Compliance Program, “Assessment of Cruise Ship and Ferry Wastewater Impacts in Alaska,” February 9, 2004, p. 8. Hereafter, “Assessment of Impacts in Alaska.” [43] As part of its efforts to develop these vessel discharge standards, in the summer of 2004 EPA sampled wastewater from four large cruise ships operating in Alaska waters in order to evaluate the performance of various treatment systems. Results of this sampling are available at [http://www.epa.gov/owow/oceans/cruise_ships/results.html. [44] 66 Federal Register 38926, July 26, 2001. [45] “Assessment of Impacts in Alaska,” pp. 33-57.

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[46] Washington State Department of Ecology, Water Quality Program, “Focus on: Cruise Ship Discharges. Draft — Memorandum of Understanding (MOU),” April 10, 2004, p. 2. [47] State of Washington. Department of Ecology. “2004 Assessment of Cruise Ship Environmental Effects in Washington.” January 2005. 22 p. [48] “Cruise Control,” p. 25. [49] EPA White Paper, p. 16. [50] “Assessment of Impacts in Alaska,” p. 12. [51] U.S. Commission on Ocean Policy, “An Ocean Blueprint for the 21st Century,” September 2004, p. 243. [52] EPA Draft Cruise Ship Discharge Assessment Report, pp. 2-36 - 2-39. [53] U.S. Commission on Ocean Policy, “An Ocean Blueprint for the 2 1st Century,” September 2004, p. 249. [54] 2000 GAO Report, p. 34. [55] U.S. General Accounting Office, Coast Guard: Relationship between Resources Used and Results Achieved Needs to be Clearer, GAO-04-432, March 2004. Also see CRS Report RS21 125, Homeland Security: Coast Guard Operations — Background and Issues for Congress, by Ronald O’Rourke.

INDEX A AAAS, 174 accidental, 105, 106, 146, 147 accuracy, 9, 65 achievement, 161 acid, 57, 58, 130, 150 Act to Prevent Pollution from Ships, vii, 102, 103, 116, 117, 144, 152, 157, 159, 163 activated carbon, 138 acute, 110, 133, 134 administration, 126 administrative, 2, 159, 165 advocacy, 1, 146 aerobic, 16, 21, 22, 56 aesthetics, 43, 89 age, 101, 162 agents, 101 agriculture, 149 air, vii, viii, 1, 2, 22, 31, 65, 109, 132, 143, 147, 150, 152, 161, 162, 171, 173 air emissions, 162, 171 air pollutant, 147 air pollutants, 147 air quality, 150, 161, 171 Alaska, vii, 2, 3, 4, 5, 7, 8, 11, 13, 14, 16, 17, 21, 22, 23, 24, 38, 39, 40, 45, 46, 51, 54, 55, 59, 60, 61, 63, 65, 68, 69, 84, 95, 96, 97, 98, 99, 102, 112, 127, 142, 144, 147, 148, 156, 163, 164, 165, 166, 169, 170, 175, 176

Alaska Natives, 163 algae, 34, 46, 49, 91, 93 alkaline, 130 alkalinity, 56 alternative, 137, 139, 155 alternatives, 146, 171 aluminum, 6, 58, 122, 114, 123, 124, 148 ambient air, 161 amendments, 12 ammonia, 17, 20, 33, 50, 51, 52, 54, 56, 57, 62, 69, 83, 94, 95, 96, 99 amplitude, 42, 88 Animal and Plant Health Inspection Service, 153 animals, 12, 110, 125, 149 Annex IV, 11, 12, 64, 151, 155, 170 anode, 130 anomalous, 33 Antarctic, 116, 119 APHIS, 153 application, 55, 141, 171 argument, 160 Army, 157 Army Corps of Engineers, 157 arsenic, 92 ash, 6, 101, 113, 114, 121, 123, 129, 138, 139, 148, 150 Asian, 149 assessment, 2, 55, 57, 58, 59, 96, 146, 169 assets, 168 assignment, 4, 140 Atlantic, 110, 125

178

Index

attacks, 155, 172 auditing, 6, 7, 168 authority, 6, 10, 14, 106, 131, 167, 170, 174 autotrophic, 56 availability, 13, 156, 173 aviation, 163 avoidance, 45, 91 avoidance behavior, 45, 91 awareness, 168

B bacteria, 21, 22, 34, 41, 42, 56, 65, 70, 86, 87, 109, 147, 149, 154, 167, 169 bacterial, 41, 87, 147, 154, 156 ballast, vii, 2, 15, 105, 110, 143, 147, 149, 152, 159, 160, 167, 168, 174 Barbados, 127 barges, 144 baths, 15, 63, 64 batteries, 6, 128, 130, 135, 138, 148 battery, 138 beaches, 124 behavior, 45, 91 benefits, vii, viii, 5, 143, 145 benzene, 59 bilge, vii, viii, 2, 6, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 141, 143, 144, 145, 146, 147, 149, 159, 160, 164, 167, 170 binding, 141, 151 bioassay, 130 bioavailability, 46, 91 biodegradable, 114, 124 biodegradation, 44, 89 biodiversity, 168 bioreactor, 21, 22, 24, 33 bioreactors, 21, 22, 23, 24, 25, 34, 37, 58 biota, 42, 88 birds, 110, 125, 148 birth, 172 Black Sea, 116 boats, 121 Boston, 44, 90 breakdown, 149

breathing, 50, 94 British Columbia, 61 bulbs, 128, 129, 138, 148 burn, 150 burning, 122 bypass, 111

C cadmium, 130 calibration, 111 Canada, 103, 110, 113 capacity, 5, 9, 12, 67, 101, 109, 120, 126 carbon, 19, 24, 27, 48, 49, 56, 75, 125, 138, 150, 175 carbon dioxide, 150 carbon monoxide, 150, 175 carcinogen, 150 cardboard, 6, 114, 122, 123, 138, 148 cardiac output, 50, 94 cargo, 64, 103, 104, 115, 144, 146, 149 Caribbean, 61, 112, 115, 116, 119, 122, 123, 127, 163, 164, 168 Caribbean Sea, 119 categorization, 158 cathode, 130 CCC, 46, 47, 51, 91, 93 cell, 138 CERCLA, 135, 158, 162 certificate, 11, 12 certification, 10, 11, 12 chemicals, 4, 6, 58, 59, 130, 132, 137, 146, 148, 149, 154, 157, 164 Chloride, 20, 26, 58, 73, 80 chlorinated hydrocarbons, 128, 129, 148 chlorination, 12, 15, 16, 19, 45, 46, 91, 155 chlorine, 13, 16, 17, 18, 19, 24, 38, 39, 40, 43, 45, 46, 49, 54, 62, 69, 76, 83, 85, 88, 90, 91, 99, 160, 164, 166 chloroform, 83 chlorophyll, 52 Chromium, 19, 28, 35, 76 citizens, 3 classification, 6, 134 clay, 46, 91

Index Clean Air Act, 2, 161 Clean Water Act, vii, 2, 10, 15, 64, 67, 68, 97, 106, 111, 119, 131, 144, 152, 153, 155, 156, 158, 159, 162, 163, 167 cleaning, 4, 6, 49, 59, 65, 92, 100, 105, 110, 128, 129, 132, 136, 137, 139, 147, 148, 164, 167 cleanup, 125, 133 CMC, 46, 47, 51, 91, 93 CO2, 139 Coast Guard, 3, 6, 10, 11, 12, 14, 17, 22, 23, 24, 25, 27, 29, 31, 32, 33, 39, 43, 46, 47, 49, 50, 60, 64, 67, 97, 103, 104, 105, 106, 108, 111, 117, 126, 152, 153, 154, 157, 158, 159, 160, 164, 165, 167, 170, 171, 172, 174, 176 coastal areas, 147, 150, 168, 171 coastal communities, 124, 125, 148 coliforms, 13, 164 coma, 50, 94 combustion, 102 commerce, 10, 117, 144, 161 communities, 42, 44, 45, 88, 89, 91, 113, 124, 125, 145, 148, 166 community, 42, 88 compensation, 42, 88 competitiveness, 166 compliance, 4, 6, 11, 12, 14, 22, 23, 24, 40, 69, 104, 108, 113, 120, 122, 126, 131, 145, 152, 154, 158, 165, 170, 172 components, 47, 92, 101, 110, 135, 137, 138 composition, 45, 62, 91, 99, 101, 125 compounds, 33, 48, 59, 83, 92, 101, 129 Comprehensive Environmental Response, Compensation, and Liability Act, 135, 158 concentration, 17, 20, 21, 27, 29, 32, 33, 34, 40, 41, 45, 47, 48, 49, 50, 54, 56, 57, 70, 83, 86, 87, 91, 93, 94, 95, 107, 114 confidence, 41, 87 Congress, vii, 4, 13, 68, 125, 126, 144, 147, 152, 159, 160, 162, 165, 169, 170, 174, 176 conservation, 14, 68, 120, 159, 168 Consolidated Appropriations Act, 164 constraints, 23, 56, 112 construction, 6

179

consumers, 41, 86 consumption, 40, 43, 47, 50, 85, 88, 92, 94, 115, 166 contaminant, 156 contaminants, 101, 102, 146, 154 contamination, 29, 41, 78, 86, 102, 147, 169 contingency, 106 control, 2, 34, 56, 106, 111, 147, 151, 159, 160, 161, 162, 167, 171 conversion, 56 cooling, 101 copper, 47, 58, 59, 83, 92, 166 coral, 14, 15, 68, 110, 156, 171 coral reefs, 14, 110, 156 corrosion, 8 corrosive, 130, 157 corrosivity, 128, 133 costs, 5, 56, 57, 58, 59, 125 Court of Appeals, 67, 120 coverage, 150, 169 covering, 11, 158 credit, 137 CRS, 110, 112, 113, 121, 127, 134, 139, 142, 143, 174, 175, 176 crude oil, 103 crustaceans, 46, 91 cycles, 42, 56, 88

D danger, 158 data collection, 146, 164 death, 45, 50, 91, 94 defense, 155 definition, 67, 117, 135, 153, 156, 157, 171 degradation, 14, 110, 124 dehydration, 122 delivery, 10 demographics, 129 denial, 120, 159 density, 52 Department of Commerce, 153 Department of Homeland Security, 153, 174 Department of Justice (DOJ), 111, 153 Department of State, 153

180

Index

Department of Transportation, 173, 174 deposition, 150 destruction, 22, 147 detection, 17, 18, 19, 20, 23, 24, 25, 27, 29, 31, 32, 33, 36, 39, 40, 42, 45, 46, 47, 48, 49, 50, 54, 72, 75, 78, 81, 82, 83, 85, 87, 91, 93, 94 detergents, 101, 147 deviation, 41, 87 diesel, 2, 110, 150, 161 diesel engines, 2, 150, 161 diesel fuel, 110 digestive process, 47, 92 dioxins, 69 disabled, 111 discharges, vii, 2, 3, 4, 6, 7, 11, 12, 13, 14, 16, 23, 38, 40, 46, 53, 55, 60, 64, 67, 68, 69, 84, 86, 95, 96, 97, 100, 103, 104, 106, 107, 110, 111, 113, 117, 120, 122, 126, 131, 140, 144, 146, 147, 149, 151, 153, 154, 155, 156, 158, 159, 160, 163, 164, 165, 166, 167, 170, 171, 172, 174 disinfection, 7, 10, 16, 20, 21, 22, 24, 38, 40, 57, 58, 155 dispersion, 55, 96 dissolved oxygen, 44, 89 distribution, 137 domestic laws, vii, viii, 144, 146, 150, 152 dosage, 58 doughnut hole, 13 draft, 55, 141, 146, 160, 170 drainage, 12, 64 drinking, 11, 49, 91, 156 drinking water, 11, 49, 91, 156 drowning, 43, 88 dumping, 121, 153, 156, 163 duration, 40, 86

E E. coli, 24, 25, 70 ecological, 14, 68, 120, 125, 149 ecological damage, 125 ecosystem, 50, 93 ecosystems, viii, 1, 50, 93, 125, 149, 168, 171

Education, 4, 13, 68 educational programs, 125 effluent, 3, 10, 11, 17, 18, 19, 20, 22, 23, 24, 27, 29, 31, 32, 33, 34, 37, 38, 40, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 54, 55, 56, 57, 58, 59, 69, 84, 90, 95, 96, 104, 107, 108, 109, 111, 120, 136, 154, 156, 157, 164, 165, 166, 170 election, 56 electricity, 59 electrolyte, 130 emission, 161, 168 energy, 58, 120 engagement, 126 engines, 2, 100, 101, 102, 120, 150, 161, 162, 168 England, 127 entanglement, 148 entanglements, 125 enterococci, 24, 41, 70, 86, 87, 96 environment, vii, 2, 6, 14, 41, 43, 45, 46, 50, 53, 68, 86, 89, 91, 94, 107, 114, 120, 121, 122, 125, 128, 132, 136, 137, 138, 139, 140, 144, 145, 147, 151, 158, 165, 168, 171 environmental effects, 13, 148 environmental impact, vii, viii, 2, 3, 8, 15, 38, 43, 53, 64, 84, 88, 95, 100, 113, 128, 141, 143, 145, 168 environmental protection, 12, 155, 156 Environmental Protection Agency, 1, 62, 63, 99, 100, 112, 113, 127, 141, 142, 146, 172, 173, 175 environmental regulations, 166 environmental standards, 5, 170 EPA, 1, 2, 3, 4, 5, 9, 10, 11, 13, 14, 21, 22, 23, 24, 25, 27, 29, 31, 32, 33, 34, 36, 37, 38, 39, 40, 43, 45, 46, 47, 49, 50, 52, 55, 57, 59, 62, 63, 65, 67, 69, 70, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 89, 90, 92, 93, 94, 96, 97, 99, 101, 107, 110, 113, 120, 125, 129, 131, 132, 133, 134, 138, 140, 141, 146, 148, 150, 152, 153, 154, 155, 156, 157, 158, 159, 160, 161, 162, 164, 165, 166, 168, 169, 170, 171, 172, 173, 174, 175, 176

Index EPC, 12 equilibrium, 50, 94 estuaries, 52, 153 estuarine, 52 eutrophication, 50, 93, 150 examinations, 154 exclusion, 67, 120, 159 Executive Order, 131 expert, 52 Expert System, 54, 95 explosives, 130 exports, 135 exposure, 45, 46, 47, 62, 90, 91, 92, 99, 110

F failure, 106, 150 family, 116 fax, 141, 142 February, 125, 161, 165, 173, 174, 175 federal government, 2, 106, 111, 141, 146, 171 federal law, 13, 23, 103, 121, 128, 132, 153, 156, 157, 161, 164, 165, 167 Federal Register, 162, 173, 174, 175 Federal Water Pollution Control Act, 153 feet, 1, 10, 15, 116, 118, 145, 154, 160, 163 fiber, 22 fibers, 21 film, 107, 129 filters, 22, 67, 138 filtration, 16, 21, 34, 108 fines, 112, 146, 166, 169 fire, 101 fire hazard, 101 fish, 42, 43, 45, 46, 50, 88, 89, 90, 91, 94, 110, 116, 125, 147, 148, 149 fisheries, 147, 149, 155, 163 fishing, 114, 118, 119, 121, 125, 159 flexibility, 170 float, 114, 118, 119 floating, vii, 10, 22, 42, 43, 88, 89, 105, 117, 120, 131, 143, 145, 154 flotation, 21, 22, 31

181

flow, 10, 15, 42, 55, 59, 70, 72, 75, 78, 81, 82, 88, 96 flow rate, 70, 72, 75, 78, 81, 82 fluid, 6, 109, 129, 136 fluorescent light, 148 flushing, 8, 111, 160 focusing, 60, 97 food, 22, 56, 65, 69, 70, 113, 114, 122, 123, 138, 147, 153 France, 112 fresh water, 8, 53 freshwater, 41, 42, 86, 88, 111 fruits, 114 fuel, 102, 103, 105, 107, 110, 149, 150, 162 furniture, 49, 92

G garbage, vii, 6, 65, 113, 115, 116, 117, 118, 119, 120, 126, 144, 146, 148, 150, 151, 153, 156, 157, 163, 172 gas, 125, 128 gas exchange, 125 gases, 114 gasoline, 149 gastrointestinal, 24 General Accounting Office, 145, 173, 176 generation, 2, 4, 9, 37, 65, 67, 132, 133, 138, 139, 157 generators, 4, 130, 132, 133, 135, 157 Geneva, 63, 100 glass, 6, 101, 114, 115, 118, 119, 125, 138, 148 glasses, 114 goals, 121, 132 government, 2, 3, 106, 116, 135, 141, 146, 153, 160, 168, 171 grasses, 34 gravity, 8, 108, 109 Graywater, 4, 5, 14, 63, 64, 66, 67, 68, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 84, 85, 87, 91, 93, 94, 96, 99, 147, 156, 169, 173 Great Lakes, vii, 67, 97, 103, 144, 156, 159, 170

182

Index

groups, 3, 126, 146, 147, 159, 160, 161, 162, 163, 168, 170 growth, 22, 49, 93, 145, 147 growth rate, 145 guidance, 41, 52, 62, 87, 126 guidelines, viii, 144, 152, 168 Gulf of Mexico, 119

H habitat, 15, 68, 110 handling, 118, 122, 133, 135, 136 harm, 43, 89, 140, 144, 149, 166, 171 harvesting, 41, 42, 86 Hawaii, 52, 53, 167 hazardous materials, 138 hazardous substance, 107, 114, 122, 131, 135, 140, 158, 163, 164 hazardous substances, 107, 114, 122, 131, 135, 140, 158, 163, 164 hazardous wastes, vii, 2, 4, 122, 128, 129, 130, 131, 133, 135, 136, 137, 139, 143, 145, 147, 148, 157, 167, 168 hazards, 121, 125, 132 haze, 150 HDPE, 114 health, vii, 2, 40, 41, 43, 47, 50, 62, 85, 86, 88, 92, 94, 99, 107, 114, 121, 125, 128, 132, 144, 145, 147, 149, 150, 158, 161, 165, 166 Health and Human Services, 4, 13, 68 health effects, 62, 99, 150 heat, 59 heat removal, 59 heavy metal, 128, 129, 140, 148, 154, 169 heavy metals, 128, 129, 140, 148, 154, 169 hepatitis, 41, 86 high pressure, 135 hip, 115 hips, 121, 150 Holland, 21, 63, 99, 100, 110, 112, 115, 130, 131 homeland security, 153, 155, 172, 174, 176 Homeland Security Act, 174 horizon, 116

hospitals, 64 host, 41 hot water, 64, 65 hotels, viii, 1 House, 152, 160, 165, 173 household, 49 human, 2, 7, 8, 10, 40, 41, 43, 47, 50, 84, 85, 86, 88, 92, 94, 110, 114, 121, 125, 128, 132, 144, 145, 147, 149, 150, 166 human exposure, 47, 92 humans, 124, 148 hydro, 3, 17, 69, 109, 110, 128, 129, 140, 147, 148, 150, 175 hydrocarbon, 137 hydrocarbons, 3, 17, 69, 109, 110, 128, 129, 140, 147, 148, 150, 175 hydroxide, 130 hydroxyl, 61

I id, 7, 43, 45, 62, 89, 90, 98, 99, 127, 129, 165 identification, 122, 132, 134, 140 ignitability, 128, 133 immigration, 162 implementation, 103, 126, 151, 165 impurities, 102 incentives, 170 incineration, 114, 117, 118, 122, 137, 139, 175 income, 166 income tax, 166 indicators, 23, 24, 41, 69, 70, 86 indigenous, 42, 88, 174 industrial, 49, 113, 131, 136, 157 industry, vii, viii, 1, 3, 5, 6, 7, 15, 23, 61, 98, 106, 112, 122, 127, 132, 136, 139, 142, 143, 144, 145, 147, 149, 150, 157, 160, 166, 167, 168, 169, 170, 173 infectious, 114 Information System, 126 ingestion, 110, 125 inhibitors, 111 injuries, 124 inorganic, 101

Index inorganic salts, 101 inspection, 6, 12, 14, 60, 97, 105, 126, 153, 157, 170 inspections, 6, 14, 111, 126, 154, 167, 172 inspectors, 60, 97, 126, 154 instruction, 136 interface, 51 interference, 124, 125 international standards, 146, 152, 161 interpretation, 159, 169 interstate, 10 interstate commerce, 10 invasive, 149, 159, 167, 174 invasive species, 149, 159, 167 invertebrates, 110 investment, 170 ions, 57, 58 iron, 58

J jobs, vii, viii, 143, 145 jurisdiction, 69, 103, 117, 144, 150, 152, 153, 155, 157, 159, 163, 172

183

law, vii, 4, 13, 14, 23, 68, 69, 103, 107, 121, 128, 132, 139, 144, 146, 150, 153, 154, 156, 157, 158, 161, 163, 164, 165, 166, 167, 170, 174 laws, vii, viii, 2, 6, 7, 10, 64, 100, 113, 128, 136, 138, 141, 144, 145, 146, 150, 152, 153, 156, 162, 163, 166, 168, 169, 171, 172 leachate, 2 leaks, 101, 149 legislation, vii, 2, 14, 38, 144, 147, 152, 160, 162, 164, 165, 166, 170 Liberia, 145, 174 life-threatening, 124 limitations, 52 liquids, 114, 122 Lithium, 130 litigation, 161 local government, 168 location, 121, 156 logging, 106 London, 127 long-term impact, 110 Los Angeles, 3, 44, 51, 90 lubricants, 100 lubricating oil, 107 lying, 163

K killing, 46 knots, 13, 37, 55, 68, 96, 164

L labeling, 135, 151 labor, 57, 58, 59 lakes, 52, 153 land, 8, 16, 38, 44, 53, 55, 56, 84, 89, 103, 104, 108, 116, 118, 119, 136, 145, 151, 154, 155, 159, 162, 171 land disposal, 136 larva, 43, 89 larvae, 110 laser, 137 laundry, 15, 21, 22, 63, 64, 65, 67, 69, 70, 83, 120, 147

M machinery, 101, 103, 105, 106, 107, 108, 110, 113, 149, 159 Maine, vii, 144, 166 maintenance, 4, 16, 56, 57, 58, 59, 101, 106, 111, 114, 129, 132, 149, 157, 172 mammals, 148 management, viii, 3, 4, 6, 14, 37, 57, 58, 59, 68, 102, 108, 109, 111, 117, 118, 120, 121, 122, 123, 124, 126, 128, 131, 132, 133, 136, 138, 139, 140, 141, 144, 146, 149, 152, 157, 159, 160, 167, 168, 169, 170, 171, 172 management practices, 3, 102, 121, 122, 132, 160, 168 manifolds, 102 manufacturer, 137

184

Index

marine environment, 2, 14, 68, 120, 122, 136, 137, 138, 147, 151, 155, 171 maritime, 6, 145, 150, 151, 152 market, 123, 145 MARPOL, vii, 6, 11, 12, 64, 102, 103, 104, 106, 107, 108, 109, 111, 116, 117, 122, 124, 125, 126, 139, 143, 151, 152, 155, 157, 159, 161, 162, 170, 172, 174 matrix, 50, 51, 95 measurement, 52 measures, 2, 6, 57, 116, 151, 163, 168 media, 129 median, 41, 52, 87 Mediterranean, 116, 119, 168 membership, 5 membranes, 21, 22 memorandum of understanding (MOU), 167 mercury, 6, 29, 58, 59, 78, 128, 129, 135, 138, 140, 148 Mercury, 19, 28, 77, 129, 138 metabolism, 44, 89 metal ions, 58 metallurgy, 56 metals, 17, 23, 31, 37, 46, 47, 54, 55, 58, 59, 69, 83, 91, 92, 96, 101, 122, 128, 129, 140, 147, 148, 154, 155, 169 metric, 43, 88, 149 Mexico, 119 Miami, 3, 44, 55, 90, 96 micrograms, 13 microorganisms, 23, 33, 34, 56 migrant, 155 migration, 43, 89 military, 121 milligrams, 11, 13, 154 minerals, 46, 91 mining, 120 Minnesota, 156 missions, 126, 150, 172 mixing, 16, 48, 49, 53, 54, 55, 92, 95, 96 modeling, 52, 54, 95 mollusks, 149 money, 125 morphological, 46, 91 mortality, 45, 90, 110, 113, 114

mortality rate, 45, 90 MOU, 167, 176 movement, 55, 96

N narcotic, 137 nation, 152 National Oceanic and Atmospheric Administration (NOAA), 68, 120, 153 National Research Council, 41, 43, 50, 61, 62, 86, 88, 93, 98, 115, 124, 125, 173 native species, 150, 168 natural, 43, 49, 52, 53, 89, 107, 124, 131, 158, 168 natural resources, 107, 131, 158 needles, 125 negotiating, 152 New Jersey, 125 New Orleans, 150 New York, 51, 61, 98, 147, 156, 164 New York Times, 61 newspapers, 113 nickel, 47, 58, 59, 83, 92 nitrate, 33, 52, 56, 57, 64, 83 nitrification, 33, 56, 57 nitrifying bacteria, 56 Nitrite, 33, 36, 53, 82 nitrogen, 33, 49, 52, 56, 57, 63, 83, 93, 100, 147, 150, 151, 155, 161 nitrogen compounds, 33 nitrogen oxides, 161 nitrous oxide, 2 NOAA, 14, 60, 68, 97, 121, 125, 153, 171 non-hazardous, 113, 116, 124, 137, 139, 148 nonionic, 57 non-native, 149, 168 non-native species, 150, 168 nontoxic, 57 normal, 2, 3, 67, 97, 110, 115, 116, 120, 153, 156, 159, 160, 174 North America, 5, 103, 148 NRC, 61, 62, 98 NTU, 27, 53, 75 nutrient, 23, 33, 50, 52, 62, 83, 94, 160

Index nutrients, 16, 23, 33, 49, 52, 55, 69, 83, 93, 95, 96, 147, 155

O obligations, 141 Ocean Dumping Act, 121 oceans, 3, 4, 5, 62, 63, 99, 100, 108, 112, 127, 144, 175 OECD, 112 offshore, 3, 11, 107, 117, 132, 135, 157, 158 oil, 23, 43, 60, 64, 65, 69, 88, 89, 97, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, 111, 112, 113, 120, 131, 146, 147, 149, 151, 154, 155, 158, 159, 163, 164, 167, 169, 172 Oil Pollution Act of 1990, 106, 158 oil spill, 106, 111 oils, 42, 43, 88, 89, 102, 107, 110, 129 omnibus, 13, 68 operator, 129, 132, 157 Oregon, 61 organic, 19, 21, 32, 34, 44, 46, 48, 49, 56, 57, 59, 65, 83, 89, 91, 92, 101 organic compounds, 48, 59, 92, 101 organic matter, 21, 46, 49, 65, 91 organization, 5 organizations, 1, 106, 125, 159, 167 osmosis, 16, 17, 18, 19, 20, 21, 39, 46, 48, 50, 58, 59 oversight, viii, 6, 60, 97, 144, 164, 168, 169, 172 oxidation, 21, 22, 56 oxide, 150, 151 oxides, 2, 161, 175 oxygen, 13, 16, 17, 18, 23, 24, 26, 35, 39, 43, 44, 50, 56, 64, 65, 69, 70, 73, 85, 89, 93, 94, 101, 125, 147, 148, 149, 155 ozone, 150, 151, 175

P Pacific, 160 packaging, 113, 114, 115

185

paints, 131, 148 Panama, 145, 174 paper, 3, 21, 37, 114, 118, 119, 122, 123, 148, 169, 170, 172, 173, 174, 176 parasites, 147 Paris, 112 particles, 41, 46, 65, 86, 91, 123, 125 particulate matter, 3, 21, 47, 91, 150, 175 passenger, 4, 65, 114, 115, 116, 122, 129, 132, 139, 144, 145, 148, 152, 157, 166, 167, 168, 169, 171 pathogens, 16, 21, 23, 34, 41, 46, 86, 147, 155 penalties, 10, 15, 68, 106, 163, 165 penalty, 167 Pennsylvania, 141 per capita, 9, 65 performance, 5, 10, 11, 13, 14, 22, 56, 59, 67, 69, 96, 111, 126, 154, 155, 165, 167, 175 periodic, 138 permit, 67, 97, 110, 120, 121, 131, 153, 154, 156, 158, 159, 160, 166, 174 personal, 59, 130 pesticide, 34 pesticides, 34, 69, 135, 154 petroleum, 42, 43, 88, 103, 107, 108, 110, 147, 149 petroleum products, 103, 107, 108, 149 pH, 13, 17, 18, 26, 39, 47, 50, 51, 54, 56, 57, 58, 64, 65, 69, 74, 85, 91, 94, 95 pharmaceuticals, 6, 59, 128, 129, 137, 148 phenol, 59, 83 phosphate, 58, 64 phosphorous, 147, 155 phosphorus, 33, 49, 52, 57, 83, 93 photosynthetic, 42, 88 physiological, 46, 91 phytoplankton, 45, 62, 91, 99 planning, 107 plants, 38, 44, 50, 56, 57, 84, 89, 93, 149 plastic, 22, 114, 116, 117, 118, 119, 125, 146, 157 plastics, vii, 49, 92, 114, 116, 117, 118, 123, 125, 138, 144, 148, 150, 151, 163, 169 platforms, 117 plea agreement, 140, 163

186

Index

poison, 50, 93 political subdivision, 10 pollutant, 18, 29, 31, 32, 83, 97, 110, 119, 131, 147, 153, 156, 159 pollutants, 5, 8, 15, 17, 23, 24, 32, 40, 43, 47, 54, 64, 69, 70, 83, 86, 88, 92, 120, 140, 144, 147, 148, 149, 154, 166, 171 pollution, vii, viii, 2, 102, 103, 107, 111, 112, 126, 143, 144, 146, 150, 151, 152, 159, 161, 162, 163, 169, 170, 171, 172, 173 pools, viii, 1, 34 poor, 17, 111, 153, 154 population, 175 ports, 12, 17, 50, 54, 55, 67, 69, 95, 96, 102, 106, 111, 112, 116, 126, 145, 147, 148, 150, 155, 161, 162, 171 positive relation, 24 positive relationship, 24 potassium, 130 power, 3, 149 PPS, 103, 117, 152, 157, 159, 163 precipitation, 57 predators, 112 preparedness, 106 President Clinton, 162 pressure, 58, 126, 135 prevention, viii, 103, 106, 107, 111, 126, 144, 151, 152, 172 printing, 137, 139 pristine, viii, 1 private, 14, 169 probation, 112, 140 production, 101, 102, 131, 138 program, 14, 23, 32, 97, 110, 120, 126, 129, 132, 138, 153, 154, 157, 159, 160, 164, 174 promote, vii, viii, 5, 129, 135, 143, 145, 147, 168 propulsion, 3, 38, 69, 100, 101, 157 protection, 6, 11, 12, 14, 42, 47, 88, 92, 155, 156 proteins, 61, 98 protocol, 161 protocols, vii, 123, 138, 143, 144, 150, 169, 170 prototype, 16, 17, 18, 19, 20, 39, 46, 48, 50

public, vii, viii, 3, 14, 60, 98, 107, 126, 141, 143, 144, 145, 146, 147, 149, 158, 162, 165, 166, 169, 173 public health, vii, 107, 144, 147, 149, 158, 165 public service, 166 pumps, 67, 102 purification, 102, 107

Q quarantine, 153 questionnaire, 5, 60, 97

R rail, 132 range, 6, 17, 26, 51, 54, 95, 128, 146, 148, 155, 157 rash, 123, 138 RCRA, 4, 57, 58, 59, 113, 121, 122, 124, 128, 129, 131, 132, 133, 134, 135, 136, 137, 139, 140, 141, 157, 158 reactivity, 128, 130, 133 reception, 12, 100, 104, 106, 107, 108, 109, 116, 118, 126, 148 recognition, 137 recovery, 112, 121, 129, 132 recreation, 144 recreational, 14, 62, 68, 99, 120, 121, 149, 154, 160, 171 recycling, 6, 113, 121, 122, 123, 128, 129, 132, 133, 135, 136, 137, 138, 148, 157, 167 reduction, 6, 16, 109, 113, 121, 122, 123, 126, 132, 148 reef, 171 reefs, 14, 110, 156 regeneration, 57, 58 regional, 3, 140, 150, 164 regulation, 2, 10, 64, 97, 111, 120, 132, 133, 141, 146, 150, 153, 156, 159, 161 regulations, vii, viii, 2, 3, 6, 37, 57, 58, 59, 60, 67, 69, 97, 103, 104, 105, 107, 108, 109, 110, 117, 120, 121, 122, 126, 128, 129,

Index 130, 132, 133, 135, 136, 137, 138, 141, 144, 150, 151, 152, 153, 154, 155, 157, 158, 159, 160, 161, 162, 164, 165, 166, 168, 169, 170, 171, 172 regulators, 168 regulatory requirements, 133 relationship, 9, 24, 65 reliability, 56 rent, 57, 58 reparation, 65 reproduction, 110 resale, 10 research, viii, 125, 144, 169, 171 reservation, 76 reservoirs, 52 residues, 6, 104, 108, 109, 110, 159 resin, 56, 57, 58 Resource Conservation and Recovery Act, 4, 113, 121, 131, 132, 140, 157 resources, 14, 107, 113, 121, 131, 132, 144, 155, 158, 163, 169, 171, 172 respiration, 43, 88 respiratory, 45, 91 respiratory problems, 45, 91 responsibilities, 12, 153, 155, 172 restaurants, viii, 1, 65 retention, 56 risk, 41, 86, 139, 166 risks, 41, 86, 128, 145, 147, 149 rivers, 52 runoff, 2

S safety, 6, 12, 151, 152, 154 salinity, 47, 50, 51, 52, 54, 55, 64, 65, 91, 94, 95, 96 Salmonella, 41, 86 salt, 57 salts, 101 saltwater, 40, 43, 50, 51, 62, 85, 88, 94, 99 sample, 17, 23, 24, 34, 35, 41, 53, 69, 72, 76, 81, 87, 154, 166 sampling, 5, 9, 14, 16, 17, 23, 24, 29, 31, 32, 33, 34, 60, 65, 69, 70, 78, 83, 84, 85, 87,

187

91, 93, 94, 97, 111, 139, 154, 164, 165, 169, 170, 175 sanctuaries, 14, 68, 120 sanitation, 7, 10, 13, 15, 37, 67, 154 seabirds, 110, 113 seafood, 120 seals, 101 search, 51, 155 Seattle, 44, 90, 147, 167 seawater, 8 seaweed, 110 security, 155, 172 sediment, 42, 88, 110 segregation, 113, 122, 123, 138 self, 61 self-monitoring, 23 Senate, 151, 152, 160, 165 separation, 21, 22, 24, 31, 34, 37, 59, 101, 107, 109 September 11, 155, 172 services, 4, 132, 157, 166 severity, 45, 91 sewage, vii, viii, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 19, 21, 22, 24, 34, 37, 38, 43, 44, 55, 56, 57, 59, 60, 63, 65, 67, 68, 69, 84, 89, 96, 97, 101, 120, 139, 141, 143, 144, 145, 147, 151, 153, 154, 155, 156, 159, 160, 163, 164, 165, 167, 169, 170, 171 Shell, 59 shellfish, 41, 42, 86, 87, 110, 147, 156 shigella, 41, 86 shipping, vii, viii, 12, 143, 145, 147, 150, 152 silver, 129, 136, 140 sites, 52 sludge, 9, 21, 33, 34, 37, 56, 58, 67, 102, 107, 109, 113, 136, 155, 167, 171, 172 SMS, 6, 168 sodium, 16, 64, 135 soil, 133 solid waste, vii, 2, 6, 101, 113, 114, 115, 116, 117, 121, 122, 126, 128, 131, 132, 133, 138, 141, 143, 145, 146, 147, 148, 149, 156, 157, 169, 170 solvent, 49, 129

188

Index

solvents, 59, 128, 129, 137, 139, 148 soy, 137 species, 42, 45, 46, 62, 88, 90, 91, 99, 149, 159, 160, 167, 168, 174 specific gravity, 109 speed, 37, 55, 68, 109 spills, 101, 106, 110, 111 stability, 101, 107, 149 stabilize, 149 standard deviation, 41, 87 standardization, 126 standards, vii, 2, 4, 5, 6, 10, 11, 12, 13, 14, 17, 24, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 48, 49, 50, 51, 52, 54, 55, 60, 67, 68, 84, 85, 86, 87, 89, 90, 91, 92, 95, 96, 97, 104, 107, 108, 109, 111, 116, 122, 136, 144, 147, 150, 151, 152, 154, 155, 156, 157, 161, 162, 163, 164, 165, 166, 167, 168, 169, 170, 171, 172, 173, 175 starvation, 110 state control, 111 State Department, 153, 176 state laws, 166, 171 statutory, 10, 13, 65, 68, 153, 162, 169 steel, 6, 114, 148 storage, 65, 67, 70, 114, 120, 136, 157 strain, 148 strategies, 6, 123, 138 streams, vii, viii, 2, 6, 12, 38, 52, 65, 84, 101, 102, 113, 117, 123, 136, 139, 143, 144, 146, 147, 150, 153, 157, 160, 164, 169, 170 strength, 18, 24, 70 stress, 44, 89 substances, 23, 101, 116, 119, 128, 131, 135, 147, 148, 151, 155, 157, 158, 163 sulfate, 58 sulfur, 150, 151, 162, 175 sulfur dioxide, 150 sulfur oxides, 175 sulfuric acid, 130 summer, 5, 14, 42, 45, 88, 175 Superfund, 158 suppliers, 168 surface water, 124 surprise, 155

survival, 110 susceptibility, 42, 88 Switzerland, 63, 100 systems, 3, 5, 7, 8, 9, 14, 15, 16, 17, 18, 19, 20, 21, 24, 31, 34, 37, 38, 39, 42, 44, 46, 48, 50, 52, 59, 63, 65, 69, 84, 96, 101, 108, 111, 112, 140, 154, 155, 164, 165, 166, 167, 168, 171, 175

T tankers, 3, 103, 144, 146, 149, 161 tanks, 11, 15, 37, 58, 67, 70, 105, 110, 122, 159 taxes, 166 technology, 37, 57, 58, 59, 136, 139, 161, 165, 168, 171 telephone, 141 temperature, 24, 42, 43, 44, 45, 50, 51, 54, 55, 56, 59, 88, 89, 90, 94, 95, 96 terminals, 116 territorial, 10, 37, 68, 118, 119, 121, 131, 156, 162, 163 territory, 121 terrorist, 155, 172 terrorist attack, 155, 172 test procedure, 124, 139 tetrachloroethylene, 49, 54, 92, 129 thallium, 92 The Homeland Security Act, 174 thinking, 141 third party, 6 threat, 124, 148 threats, 149, 171 threshold, 109, 133, 135 threshold level, 109 time, 16, 34, 37, 52, 53, 56, 97, 106, 111, 112, 125, 126, 133, 135, 146, 154, 161, 164 tin, 114 total organic carbon (TOC), 24, 125 tourism, 1, 149, 163, 166 tourist, 145 toxic, 34, 45, 46, 50, 57, 90, 91, 94, 110, 138, 139, 147, 150, 157, 166 toxic substances, 147, 157

Index toxicity, 46, 50, 91, 94, 110, 128, 133, 139, 148 tracking, 4, 135 trade, 165 tradition, 16 traffic, 175 training, 56, 111, 122, 135, 136, 137, 139, 142 transcripts, 3 transfer, 7, 106 transport, 144, 149, 156, 163, 171 transportation, 114, 120, 121, 132, 135 traps, 67 travel, 1, 7, 61, 112, 127, 144, 155 tribes, 159 tubular, 21 turtles, 125, 148

U U.S. economy, vii, viii, 143, 145 ubiquitous, 161 ultraviolet, 21, 22, 38 ultraviolet light, 21, 38 uniform, 160, 169, 170 United Nations, 151 United States, 4, 10, 11, 12, 13, 44, 45, 50, 51, 55, 67, 68, 90, 95, 96, 102, 103, 106, 107, 111, 116, 117, 118, 119, 120, 121, 126, 131, 134, 140, 145, 150, 151, 152, 153, 155, 156, 158, 159, 161, 162, 163, 164, 167, 170, 174 universe, 128, 135 updating, 171 upholstery, 49, 92 UV, 21, 22, 24, 25, 38, 57, 58

V vacuum, 8, 22 values, 40, 44, 51, 52, 53, 54, 89, 95 vapor, 6, 128, 138, 148 variability, 53 variable, 70, 148 variation, 52

189

vegetables, 34, 114 vehicles, 161 velocity, 109 venue, 141 vessels, 3, 6, 7, 8, 10, 11, 12, 13, 14, 16, 17, 18, 19, 20, 21, 23, 33, 34, 37, 38, 39, 46, 48, 55, 60, 64, 67, 68, 84, 96, 97, 100, 102, 103, 105, 108, 110, 111, 112, 113, 115, 117, 118, 120, 121, 125, 126, 128, 129, 130, 136, 144, 145, 146, 147, 148, 150, 151, 152, 153, 154, 155, 156, 157, 159, 160, 161, 162, 163, 164, 165, 166, 167, 168, 169, 170, 171, 174 Victoria, 61 viruses, 22, 34, 41, 86, 147, 149 visible, vii, viii, 10, 108, 143, 145, 147, 154, 158 voters, 166

W waste disposal, 121, 122, 132, 139 waste incinerator, 167 waste management, viii, 3, 57, 58, 121, 122, 123, 124, 126, 132, 136, 138, 139, 140, 144, 146, 157, 167, 168, 169 waste products, 6, 11, 124, 137, 139 waste treatment, 136, 164 waste water, 12, 64, 101 wastes, vii, viii, 1, 4, 7, 8, 10, 57, 58, 100, 116, 118, 122, 123, 126, 128, 129, 130, 131, 133, 134, 135, 136, 137, 139, 143, 145, 146, 147, 148, 149, 154, 157, 158, 164, 165, 167, 168 wastewater, vii, 3, 4, 8, 9, 13, 14, 15, 16, 17, 18, 20, 21, 22, 24, 38, 40, 46, 49, 55, 57, 63, 64, 65, 67, 69, 70, 83, 84, 86, 93, 109, 143, 145, 146, 147, 149, 165, 166, 167, 168, 169, 170, 175 wastewater treatment, 9, 13, 16, 46, 55, 67, 165, 166, 167, 168 water, vii, viii, 1, 2, 3, 6, 7, 8, 10, 11, 13, 16, 20, 37, 38, 40, 41, 42, 43, 44, 45, 46, 48, 49, 50, 51, 52, 53, 54, 55, 58, 59, 60, 61, 62, 64, 86, 89, 90, 91, 92, 95, 97, 98, 99,

190

Index

100, 101, 102, 104, 105, 106, 107, 108, 109, 110, 111, 112, 116, 118, 119, 123, 127, 132, 139, 141, 142, 143, 144, 145, 146, 147, 149, 150, 152, 156, 158, 159, 160, 164, 166, 167, 168, 170, 174 water quality, 1, 2, 13, 40, 42, 43, 44, 45, 48, 49, 50, 51, 52, 53, 54, 55, 62, 86, 87, 89, 90, 91, 92, 95, 99, 107, 111, 166, 167 water quality standards, 13, 40, 42, 43, 44, 45, 48, 49, 52, 53, 54, 55, 86, 87, 89, 90, 91, 92, 95, 107, 166 waterfowl, 43, 88 waterways, 155, 171 welfare, 107, 145, 158 wetlands, 52 WHO, 50, 94

wildlife, 50, 93, 149 winter, 45 wood, 114, 122, 123, 124, 138 World Health Organization (WHO), 63, 100

X Xenobiotic, 63, 100

Z Zinc, 18, 19, 29, 35, 47, 58, 59, 77, 78, 83, 92, 93, 166

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