Environmental Compliance in the Cruise Industry
May 31, 2001
ABSTRACT
The deep-sea, overnight cruise industry is the fastest growing segment of the
maritime industry with annual growth rates of eight to ten percent. The
environmentally sound and legally compliant operation of its ships is a priority
of cruise ship operators. The changing legal landscape, increasing public
interest, the activities of a number of interested parties, ship operational
requirements, technical innovations, and evolving environmental sensitivity are
some of the specific aspects of the overall cruise ship environmental issue. A
discussion on these various aspects is presented in order to inform the reader
of some of the specific actions and developments to date and to provide a better
understanding of the overall issues.
INTRODUCTION
Regulatory and public interest in the potential impacts of cruise ship
operations on the environment continues to draw significant attention. As a
result of a recent petition by a group of public environmental advocates, the
U.S. Environmental Protection Agency has undertaken the task of evaluating
cruise ship operations and their potential environmental impacts. This effort is
being undertaken concurrently with similar evaluations by states such as Alaska,
Florida, and California. The cruise industry is working closely with regulatory
agencies and the public to address operational and environmental concerns.
This paper describes the complex legal regime in which the industry currently
must operate and the methods the cruise industry uses to meet these stringent
environmental requirements. Included is a discussion of current engineering and
operational practices applied by the cruise industry to minimize the
environmental impacts of their operations.
The paper concludes with an overview of technical and operational changes
that are anticipated as a result of current and future regulatory efforts and
related developments. A brief industry outlook is also presented.
THE CRUISE INDUSTRY
The U.S.-based, deep-sea, overnight cruise industry served over 6.9 million
passengers in 2000 and operated 123 ships on numerous itineraries through the
Caribbean, Alaska, and other exotic locales. The total economic impact in the
United States alone was calculated to be over $15 billion. To say that the
cruise industry is the fastest growing segment of the overall maritime industry
is an understatement. With a growth rate of between eight and ten percent over
the past several years, as of January 2001, there were fifty-three new cruise
ships on order to be delivered by 2005. At a total investment of over $18.5
billion, these new ships will add over 98,000 berths to the market (Seatrade
Cruise Review 2001). As a specific example of growth, one major cruise
operator will increase its capacity from 18,670 available berths in 1998 to
45,006 berths in 2004 – a whopping 241% expansion (International Cruise and
Ferry Review). This expansion will be even greater if options for additional
ships are exercised. With this explosive growth come great opportunities as well
as great challenges. One such challenge is the environmentally sound and legally
compliant operation of these ships.
THE LEGAL REGIME
Cruise ships operate within a pervasively regulated industry. They are
subject to control and oversight from their flag state (i.e., the nation with
which they are registered), the port states (i.e., the nations at which they
make port calls), and, in the United States, the individual states and
localities that they visit. International standards are developed by the
International Maritime Organization (IMO). Cruise ships are also inspected and
surveyed by classification societies. With respect to environmental issues, the
major international standard applicable to cruise ships is the International
Convention for the Prevention of Pollution from Ships, commonly referred to as
MARPOL. This standard addresses such things as operational discharges of oil,
disposal of garbage and plastics, and air emissions. Most flag states and port
states, including the United States, have adopted MARPOL requirements as their
domestic standard, so that compliance with this convention constitutes
compliance with national law. The International Safety Management (ISM) Code
required by Chapter IX of the International Convention for the Safety of Life at
Sea (SOLAS) is also important to environmental protection. This code requires an
extensive Safety Management System (SMS) that addresses safety and environmental
management practices and procedures.
The United States has also adopted a series of national environmental laws
that are applicable to all cruise ships operating in U.S. waters. The drafters
of some of these statutes, such as the Federal Water Pollution Control Act (FWPCA),
consciously considered maritime issues. Other statutes, though, such as the
Clean Air Act (CAA) and the Resource Conservation and Recovery Act (RCRA), were
implemented with little or no consideration of maritime application, which was
primarily recognized after the fact. The FWPCA prohibits the discharge of oil
and hazardous substances into waters of the United States. It also addresses the
operation of marine sanitation devices (MSDs). The CAA authorizes the U.S.
Environmental Protection Agency (EPA) to establish air emission standards and
impose civil penalties for emissions in excess of those standards. RCRA
authorizes the EPA to establish regulations relating to the handling and
disposal of hazardous waste. Under this statute, the EPA has developed a complex
and paperwork-intensive program that tracks hazardous waste "from cradle to
grave."
In the federal system of the United States, each state has broad residual
authority or "police power" over most issues, with the exception of
things such as national defense and coinage, and regulation of interstate or
foreign commerce. One area in which the states and local jurisdictions have and
exercise extensive authority is that of environmental protection. Thus,
balancing the states rights against federal interests, each state or community
visited by a cruise ship may adopt standards with respect to defining
permissible discharges, including graywater (from dishwashers, showers, laundry,
bath, galleys, and washbasins), blackwater (sewage and medical and dental sink
drainage), oil, ballast water, and air emissions. Florida, where the majority of
large cruise ships are based, has adopted stringent standards for hazardous
waste management, in accordance with the RCRA. California has initiated programs
affecting cruise ships by addressing such things as ballast water discharges and
air emissions.
PRIOR ENVIRONMENTAL VIOLATIONS
Over the past several years, the cruise industry has experienced several
highly visible environmental violations. They have been cited for discharges of
oily waste, hazardous substances, and plastics, as well as excessive air
emissions. In an effort to improve their stature as good environmental citizens
and reduce the risk of future environmental violations, cruise lines are
adopting compliance programs that establish formal internal regimes for meeting
or exceeding environmental standards, and for training and auditing. They are
also installing new equipment to significantly reduce discharges and emissions.
THE GAO REPORT
The United States General Accounting Office (GAO) published a Report to
Congressional Requesters in February 2000 (GAO 2000). This report, entitled
"Marine Pollution – Progress Made to Reduce Marine Pollution by Cruise
Ships, but Important Issues Remain," was developed in response to a request
by Congressman John D. Dingell (D-MI) and Congressman Henry A. Waxman (D-CA) and
addressed the general issue of cruise ship environmental performance and several
specific related issues, for the period of 1993-1998. The report concluded that
federal agencies and the cruise industry have recently taken positive steps to
improve environmental performance and compliance. While the report indicated
that only four percent of the pollution violations by commercial foreign-flagged
ships were attributable to cruise ships, and that many of these instances were a
result of accidents, such as failed hydraulic lines and spilling of "a few
drops of paint," it also recognized that a number of significant
environmental issues still require attention by all parties. These issues
include technical and scientific aspects of environmental protection, as well as
operational, legal, administrative, and policy matters.
THE BLUEWATER NETWORK PETITION
On March 17, 2000, the environmental advocacy group, Bluewater Network, and
53 other organizations sent a petition to the EPA urging various regulatory
actions to further control cruise ship discharges. The petition, and an
accompanying report entitled, "Cruising for Trouble: Stemming the Tide of
Cruise Ship Pollution," (Schmidt 2000) expressed concern over a number of
issues including, the magnitude of the discharge volumes from an increasing
number of larger cruise ships. The petition and report recognized that cruise
ships generate and discharge several waste streams and requested that the EPA
take the following actions:
- Assess the volumes and characteristics of cruise ship discharges.
- Identify potential water quality, aquatic environment, and human health
impacts.
- Examine existing federal regulations governing cruise ship discharges.
- Recommend means to control and regulate cruise ship discharges.
- Outline monitoring and record-keeping options for pollutants discharged by
cruise ships in U.S. ports.
EPA INITIATIVES
Traditionally, the EPA has paid scant attention to ships. In addition to
exempting discharges from properly operating marine engines from the FWPCA
prohibitions, the agency also exempted discharges of sewage, wastes from
laundries, showers, and galley sinks, and other discharges incidental to the
normal operation of a vessel from requiring permits under the National Pollutant
Discharge Elimination System (NPDES). Sewage treatment and discharge, however,
is addressed in the law and in implementing regulations overseen by the United
States Coast Guard. In response to the Bluewater Network petition and other
concerns expressed, the EPA has undertaken a study of environmental issues
associated with cruise ship operations. The agency has commenced a broad
assessment of cruise ship discharges.
To this end, the EPA launched an interagency work group on March 31, 2000 to
develop and implement a plan for responding to the Bluewater Network petition.
This work group developed a draft six-month action plan outlining proposed
actions in response to the petition. These actions included conducting public
hearings to solicit input from interested parties, gathering cruise ship waste
discharge information, drafting a report on cruise ship discharges, and
reviewing existing regulatory requirements to determine which, if any, should be
updated. Public hearings were announced in the Federal Register on August 11,
2000 and were held in the regional locations of Los Angeles, Juneau, and Miami
in September 2000. On August 22, 2000, the EPA published a Cruise Ship White
Paper (EPA 200) containing preliminary information regarding cruise ships and
waste management practices and some preliminary discussion on how the EPA might
respond to the Bluewater Network petition.
FEDERAL LEGISLATION
Congress recently enacted, as part of a consolidated appropriations act, a
bill introduced by Senator Frank Murkowski (R-AK) addressing certain cruise ship
operations in Alaska waters. This stand-alone legislation codifies many of the
operational practices previously agreed upon by all participants in the Alaska
Cruise Ship Initiative, including cruise ship operators. It reinforces and
enhances prior federal measures regarding ship discharges, but limits its
application to large cruise ships in Alaska. It prohibits discharge of untreated
sewage into navigable waters of the United States within Alaska and certain
other U.S. waters in the vicinity of Alaska. It specifies that the discharge of
treated sewage and graywater is permitted only when a cruise ship is proceeding
at not less than six knots, is more than one mile from land, is in compliance
with all applicable discharge standards, and when the discharge is not otherwise
prohibited. The legislation establishes requirements with respect to effluent
quality for sewage and graywater, which the EPA is authorized to change by
regulation. The U.S. Coast Guard is directed to establish a cruise ship
inspection and wastewater sampling regime, examine environmental compliance
records and procedures, and inspect the functionality and proper operation of
equipment installed for abatement and control of discharges. Owners, operators,
and masters of cruise ships are required to immediately report any discharge in
violation of the legislation. Violations may result in the assessment of civil
penalties. Negligent violations may result in misdemeanor prosecutions. Persons
who knowingly violate the restrictions may face felony prosecutions, as may
anyone who knowingly makes a false statement or tampers with any testing or
monitoring device or method required by the legislation. To date, no
implementing regulations have been promulgated, although the cruise industry is
working closely with the Coast Guard and other regulatory agencies to ultimately
comply with the requirements.
U.S. COAST GUARD ACTIONS
As part of their role in participating in interagency work groups and in
fulfilling their mission, the U.S. Coast Guard conducted Operation Cruise Watch
2000 from June to September 2000 to place increased emphasis and focus on cruise
ships for compliance with applicable environmental laws. The Coast Guard
increased the scope of its environmental inspections and oversaw the sampling of
cruise ship discharges for every major cruise ship operating in Alaskan waters.
The cruise industry voluntarily agreed to cooperate in this program and funded
the sample analysis efforts. Coast Guard inspectors dedicated more time during
their periodic inspections reviewing environmental compliance and examining
oil-water separators (OWS) and marine sanitation devices. These increased
efforts in inspection and oversight of pollution prevention equipment and
environmental management practices are continuing.
STATE INITIATIVES AND RELATED ACTIONS
Alaska
In December 1999, the Alaska Department of Environmental Conservation (ADEC)
invited the EPA, the Southeast Alaska Conference (representing Southeast Alaska
communities), and the Coast Guard to join with cruise ship industry officials in
discussions to improve cruise ship discharge and pollution prevention practices.
The meeting objectives included the identification of discharges and spill
risks, development of pollution prevention and waste management techniques to
eliminate or reduce pollution impacts, evaluation of the compliance process, and
ways to educate the public on these issues. After this initial meeting, ADEC
established the Alaska Cruise Ship Initiative and formed several work groups to
assess cruise ship discharges, focusing on air quality, oil pollution response,
wastewater and solid waste management, and environmental leadership. After
receiving questions and complaints from environmental groups and Alaskans, the
Coast Guard, as part of the Initiative, examined the need to change the
standards for wastewater discharge. One major impact on this decision stemmed
from the controversy involving cruise ships transiting through "doughnut
holes," which are small, localized areas within the Inside Passage of
Alaska that are more than three miles from any land and technically considered
to be international waters where certain wastes can be legally discharged. These
discharges into the "doughnut holes" would not be permitted if these
waters were classified as territorial waters of the United States. In an effort
to allay this controversy, the non-U.S. flagged cruise ships on Alaskan
itineraries pledged in 1999 to consider all the waters of the Alexander
Archipelago as internal to the U.S., and therefore, off limits to discharges by
cruise ships.
In July 2000, the Alaska Cruise Ship Initiative developed a sampling plan and
laboratory analysis procedures for both graywater and blackwater to determine
the type, quantity, and constituent makeup of cruise ship discharges. The
regulatory agencies, cruise ship industry, environmental groups, and interested
citizens worked cooperatively to develop the sampling plan which required each
cruise ship to have its wastewater discharges sampled twice during the summer.
Since the cruise industry had already committed to discharging only when at
least ten miles from port, the sampling occurred while underway.
Following the release of preliminary results from Alaska's cruise ship
sampling efforts in September 2000, Alaska's Governor Tony Knowles called on
state and federal governments to toughen cruise ship environmental regulations.
Final results from the sampling effort indicate that a majority of the samples
analyzed failed to fully comply with established standards. Many graywater
samples exhibited fecal coliform counts in excess of 1000 per 100 milliliters
(ml) and as many as nine samples of treated blackwater exhibited counts in
excess of 10 million per 100 ml. A complete summary of findings is available in
the Initiative’s November 2000 Wastewater Monitoring Fact Sheet (ADEC 2000).
Florida
The Florida Department of Environmental Protection (FDEP) signed a memorandum
of understanding (MOU) on March 14, 2000 with the fifteen cruise-line members of
the Florida-Caribbean Cruise Ship Association (FCCA). The MOU effectively
documented the FDEP's acceptance of a set of waste management practices and
procedures and formalized an agreement between the FDEP, the FCCA and its
members, and the Coast Guard to work together on discharge management proposals,
meeting on an annual basis. The cruise industry waste management practices and
procedures, as appended to the MOU, outlines environmentally responsible and
legally compliant practices and procedures for the minimization, reuse, and
recycling of wastes and specific procedures for improved management and disposal
of solid wastes, hazardous wastes, and wastewaters, including graywater,
blackwater, and bilgewater. Additional principles under the agreement included
compliance with applicable environmental laws and regulations, development of
educational training for discharge management, and environmentally-friendly
cruise ship designs. The U.S. Coast Guard is also recognized as the onboard
inspection agency and a comprehensive inspection checklist for onboard
environmental compliance oversight has been developed jointly by the cruise
industry, the Coast Guard, and FDEP personnel. This group is working on a number
of tasks, including, for example, a resolution to the issue of numerous waste
tracking numbers being used to follow hazardous wastes transferred ashore in
different ports around the United States. Ultimately, the use of a single waste
tracking account number for all waste generated by a given ship will provide
more efficient management, tracking, and accountability.
California
In September 2000, the California Legislature passed, and Governor Gray Davis
signed, Assembly Bill AB 2746 (AB 2746). The objective of AB 2746 is to evaluate
the environmental practices and waste streams of large passenger vessels and
regulations pertaining thereto. AB 2746 called for the creation of the
California Environmental Protection Agency Cruise Ship Environmental Task Force,
composed of representatives from the State Water Resources Control Board,
Department of Fish and Game, Department of Toxic Substances Control, Integrated
Waste Management Board, State Lands Commission, and Air Resources Board. The
U.S. Coast Guard will also participate in the Task Force. The purpose of the
Task Force is to gather information necessary for the preparation of a report to
the Legislature due June 1, 2003. As stated in the bill, and as requested by the
task force, cruise vessel operators will provide records or information relating
to waste released or offloaded after January 1, 2001, from vessels in
California. Such information may be in the form of copied excerpts of records
and manifests, including oil record books, garbage record books and other ships
logs. The report of the Task Force is expected to: identify areas that may not
be adequately addressed by existing reporting requirements; identify
opportunities to improve coordination of regulatory efforts; and make
recommendations to the U.S. Coast Guard and State agencies to address any areas
where additional regulations or reporting may be appropriate.
CRUISE INDUSTRY INITIATIVES AND RELATED ACTIONS
The International Council of Cruise Lines (ICCL) is an industry trade
association representing sixteen major cruise operators. In August 2000, ICCL
and the U.S. Coast Guard jointly conducted an environmental management forum
during which the Coast Guard, the EPA, the National Oceanic and Atmospheric
Administration (NOAA), the U.S. Department of Justice (DOJ), various state
agencies, and public environmental advocacy groups were invited to discuss
industry waste management practices, environmental concerns, and existing
oversight mechanisms. This forum led to an industry initiative to develop a
guideline intended to propose more uniform environmental management practices.
This guideline, developed with the input of the EPA, the Coast Guard, and other
interested parties, is expected to provide guidance to all cruise ship operators
to ensure that management systems are uniform in the scope of the elements
addressed and to assure oversight agencies and the public that shipboard waste
management practices and procedures are being properly conducted.
Additionally, in an effort to better understand some of the technical issues
behind cruise ship discharges, the ICCL commissioned a dispersion analysis and
report. This study estimated the expected concentrations of wastewater
constituents following release from a "typical" cruise ship underway
at various speeds. The results of this analysis indicated that wastewater
constituents would disperse into the receiving waters with a dilution factor as
large as 111,000 (Kim 2000). The Northwest Cruise Ship Association (NWCA),
another industry trade association, conducted rudimentary water sampling studies
in the waters off Ketchikan Alaska, which indicated that constituent
concentrations likely drop off so quickly in the receiving waters that they
become essentially undetectable. Currently, the industry and the EPA plan to
cooperatively conduct a wastewater dispersion analysis in the spring of 2001
utilizing the R/V Anderson, a scientific research vessel. It is
envisioned that the R/V Anderson could trail behind a transiting cruise
ship taking concentration measurements. While there has been much preliminary
discussion, the detailed water sampling plan and testing protocols for
determining constituent or indicator dye concentrations in the actual receiving
waters are still under development.
Individual cruise lines operating in Alaska, the Caribbean, and elsewhere
have undertaken numerous initiatives to mitigate environmental effects, to
ensure legal compliance, and to exhibit their willingness and desire to be good
neighbors. Some of these initiatives include developmental efforts with
equipment vendors in wastewater treatment systems, partnerships with NOAA and
other research institutes, installation of onboard oceanic science labs, and the
purchase and installation of state-of-the-art shipboard machinery with improved
environmental performance. An indisputable sign of commitment to environmental
protection and good stewardship is the standby deployment of oil recovery barges
and equipment throughout the waters of Alaska.
CRUISE SHIP DISCHARGES
Graywater
Graywater is defined in 33 CFR 151.05 as drainage from dishwashers, showers,
laundry, bath, galleys, and washbasin drains and does not include drainage from
toilets, urinals, hospitals, and cargo spaces. It traditionally contains
suspended solids, classical pollutants, nutrients, and fecal coliform bacteria.
It might also contain organic compounds, petroleum hydrocarbons, oils and
greases, and metals. This constituent makeup presents some biological and
chemical oxygen demand on receiving waters. Cruise ship generation rates for
graywater have been estimated at about fifty gallons per person per day (Alaska
Cruise Ship Initiative 2000). For the typical ship undertaking a seven-day
voyage with a combined passenger and crew count of 3000 persons, this equates to
a total graywater generation volume of approximately 1.1 million gallons. Given
the physical and logistical impossibility of holding such total volumes for any
length of time, graywater is discharged in a controlled manner during the course
of the voyage. One possible discharge scenario can include collection of as much
as 300,000 gallons of graywater, then discharging it at pump rates as high as
several hundred gallons per minute. Discharging of collected graywater can occur
over several hours and as often as operationally necessary during the ship’s
voyage. Samples of graywater collected from Alaskan cruise operations have shown
relatively high levels of fecal coliform. The possible causes of such
higher-than-expected constituent concentrations and the potential impacts of
graywater constituents on the environment continue to be investigated.
GRAYWATER CONTROL
Graywater generated by cruise ships can be handled in several different ways
to ensure environmental protection. Generally, as technology is developed and
proven, graywater will be treated for reuse, treated for release to the
receiving waters, or converted to solid or gaseous form for ultimate destruction
or removal. Currently, graywater is collected and held for controlled discharge
in accordance with current requirements and industry practices.
One of the most promising treatment technologies involves the filtering of
contaminants from graywater, thereby reducing or eliminating the adverse
environmental impact potential of the discharge. Filtration equipment can be
configured into various shipboard systems from a number of commercial vendors,
both foreign and domestic. Each embodiment of the filtration technology employs
different filter media, preconditioning schemes, filter maintenance techniques,
and equipment packaging concepts. The levels to which contaminants are removed
can also vary. This variability is largely dependent on the particular filter
element design and rating, the nature of the influent graywater, and on the
effluent purity needs at the treated end. Water suitable for reuse in ship’s
laundries, machinery plants, for deck washing, and for other technical uses can
be produced with proper filtration from graywater. The theory of filtration
treatment allows for treatment to water quality suitable for human use,
including contact recreational use, bathing, and ingestion as drinking water.
Filtration systems are augmented with chemical, thermal, or radiant disinfection
processes to achieve discharge quality suitable for drinking.
Given the range of treated effluent quality available through filtration
treatment, effluent quality suitable for discharge to various receiving waters
can be achieved. Successful application of a commercially available and viable
filtration system can lead to environmentally protective, legally compliant, and
socially acceptable disposal of graywater from cruise ships.
To date, the industry’s experience with filtration systems, while limited,
has been basically successful in initial shipboard field tests. Some of the
technical difficulties anticipated from the deployment of filtration systems
have included installation delays, system throughput limits, and filter element
maintenance and ultimate life. Related to these issues are feasibility concerns
including space allocation, impacts to ship operations, reliability and
availability estimates, and cost. Some of the first treatment systems that have
been installed are continuing to undergo evaluation and data collection while
analyses of problems and issues continue in order to optimize system
installation and operation.
Beyond the various embodiments of filtration technologies, other graywater
treatment techniques include an activated oxidation process in which water
soluble organics in the graywater are destroyed by exposure to hydrogen peroxide
and ozone, as well as an electro-chemical flocculation process. Shipboard
treatment systems based on these techniques are also under evaluation for
throughput, effluent quality, reliability, maintenance requirements, and other
feasibility issues.
Collection and holding of graywater and treated blackwater until the
requisite discharge conditions are met, as provided for in the recent
Congressional enactment of the "Murkowski Bill," is a significant step
toward further precluding the possibility of adverse effects on receiving
waters. Such efforts at managing the handling of wastes is an effective, albeit
not technical, method of mitigating environmental risks.
Blackwater
Blackwater is defined as waste from toilets and urinals. Blackwater also
includes sink drainage from medical and dental facilities. The key measurable
characteristics of blackwater include fecal coliform count, suspended solids
concentration, nitrogen concentration, pH, and resultant biological and chemical
oxygen demand. Cruise ship generation rates for blackwater have been estimated
at about five gallons per person per day (Alaska Cruise Ship Initiative). For
the typical ship undertaking a seven-day voyage with a combined passenger and
crew count of 3000 persons, this equates to a total blackwater generation volume
of approximately 105,000 gallons, prior to any form of treatment. Blackwater can
be buffered in holding tanks, biologically or chemically treated by MSDs, and
discharged where allowed. Typically, some combination of these practices is
employed. Examination of installed MSDs aboard ships operating in and around
Alaska waters have shown some instances of improperly functioning MSDs whose
effluents did not meet design specifications for a properly installed and
functioning MSD. Specifically, fecal coliform counts were in excess of 200 per
100 ml. Studies and investigations have been launched to ascertain the cause of
improperly functioning MSDs. While complete and conclusive findings are pending,
one possible explanation could lie in the sampling methodology. It has been
suggested that treated blackwater samples taken from holding tanks downstream of
the treatment device might have much higher fecal coliform concentrations due to
an incubation phenomenon within the holding tank itself. Treated blackwater
effluent, if taken directly from an MSD, might exhibit markedly lower
contaminant counts. Again, the investigations are continuing.
BLACKWATER CONTROL
The treatment of blackwater aboard cruise ships is relegated to Type II MSDs
approved in accordance with IMO requirements or certified by the U.S. Coast
Guard. The certification testing protocol requires that treated effluent from
these MSDs contain not more than 150 milligrams per liter (mg/L) of total
suspended solids (TSS) and not more than 200 fecal coliform per 100 ml,
according to 33 CFR 159.126. Many of the treatment systems being examined for
graywater treatment are also capable of further processing the treated
blackwater effluent from Type II MSDs to achieve improved constituent
characteristics. Treatment of commingled graywater and treated blackwater, along
with related collection, storage, and handling issues, are being studied as part
of the overall cruise ship wastewater treatment effort.
Hazardous Wastes and Substances
Examples of waste materials onboard cruise ships that are considered
hazardous and that must be handled in accordance with the requirements of RCRA
include photo and x-ray processing chemicals, chlorinated dry cleaning solvents,
spent fluorescent and mercury vapor lamps and some batteries, some
pharmaceuticals, and some miscellaneous shop process byproducts such as from
print, paint, and repair shops. Contained within these liquid and solid wastes
are heavy metals, volatile organic compounds, and other compounds that, if not
properly handled, can pose a danger to the environment and directly to humans
through both short and long-term exposure. Within the legal regime that cruise
ships operate under, the handling and ultimate disposal of such hazardous
materials are strictly prescribed. The industry has established practices for
the safe, environmentally sound, and legally compliant handling of these wastes.
These practices include a combined regimen of sorting and segregation,
containerization, safe storage, and transfer to approved shore disposal
facilities. In many cases, recycling programs and pollution prevention efforts,
by which the type and amount of potentially polluting substances and materials
are reduced, are relied upon as an integral part of the overall environmental
protection and compliance effort.
Oily Wastes
Oily waste discharges from cruise ships are primarily a product of the
propulsion plant and auxiliary machinery. Hundreds of thousands of gallons of
fuel oil and lube oil are carried by a cruise ship at the onset of a typical
voyage. A mechanical mishap or structural damage could lead to the unintended
release of some of this oil. However, such events are rare and only occur as a
result of other events, such as a collision or grounding. Oily waste discharges
most commonly take the form of bilge accumulations or equipment drainage that is
collected for proper treatment and disposal. Oily wastes are collected in large
buffer tanks then processed through oil-water separators. These devices
typically employ gravity separation or centrifugal force processes, aided by the
natural tendency of oil to separate from water. Other means of treating oily
wastes include electro-chemical flocculation, biological digestion, membrane
polishing, oil absorption, and incineration. Investigations into the feasibility
and effectiveness of these and other techniques and actual shipboard evaluations
are currently ongoing. It is worth noting that, together with these technical
developments, the IMO is in the process of reevaluating certain key aspects of
MARPOL related to oil pollution. As a result, changes intended to provide added
environmental protection are expected.
Solid Wastes
Solid wastes generated aboard cruise ships during the course of a typical
voyage include paper, plastic, glass, metal, and other trash produced by
passengers and crew. It does not include materials otherwise designated as
hazardous. It also does not include food wastes from galleys and passenger meal
consumption. Not unlike the techniques for handling hazardous materials and
substances, solid waste is sorted and segregated. The waste is then stored for
proper disposal ashore, recycled, or incinerated aboard ship. All of these
practices ensure minimal adverse impacts to the environment.
Air Emissions
Cruise ship operations, like other segments of the marine industry, generate
air emissions from operating propulsion engines, auxiliary engines, and
incinerators. The stack emissions contain the byproducts of combustion including
oxides of nitrogen, sulfur, and carbon, unburned hydrocarbons, and particulate
matter. The opacity of stack emissions from cruise ships has drawn recent
attention in Alaska and California, for example, and has resulted in notable
actions by ship owners and operators, including changes in operational
procedures, controlling fuel selection, equipment changes, and system
modifications. The design and selection of the engines, the manner in which they
are used when approaching, maneuvering in, and departing ports, and the
condition in which they are maintained all impact stack emissions. In an
unprecedented effort to help improve the air quality in Alaska, Princess
Cruises, a major operator, is planning to secure its shipboard service
generators in favor of taking shore power from the pier when in the Alaskan port
of Juneau. Of course, advances in engine design and shipbuilding will also have
beneficial trickle down effects. The installation of gas turbine power or newer
"greener" diesel engines on some new construction ships are examples.
All these efforts are indicative of the industry’s awareness and sensitivity
and their good-faith efforts to minimize air emissions.
THE INDUSTRY’S OUTLOOK
There is no doubt that the cruise industry, the vast majority of whose ships
are non-U.S. flagged, will continue to be heavily scrutinized. Cruise ships
engaged in international trade must comply with a regulatory scheme that
includes international, federal, and state requirements. However, all of these
ships call at numerous ports around the world. In fact, cruise ships call at
over 300 ports in over 100 different countries. This being the case, the cruise
industry will continue to call for standardized regulations so that equipment
designed to comply with the laws in Alaska, for example, will be suitable for
compliance with the laws in California, Florida, Melbourne Australia, Istanbul
Turkey, or Southampton England. As an international trade, the cruise industry
seeks international solutions. Many of the solutions to environmental concerns,
which will be implemented by the industry in locations around the world, are
being developed as a result of the many legal requirements the industry is
facing in the United States.
In a proactive effort to address concerns expressed mainly in the United
States but certainly applicable in any operating location, the cruise industry
has taken to voluntarily adopting mandatory industry standards for environmental
protection issues, as well as for safety, security, and health. As the industry
develops and implements this self-regulating posture, especially for issues
where there currently are no regulations and in which the regulatory process may
take years, these industry standards will set the bar higher for all cruise
ships and these standards may become applicable to other segments of the
maritime industry as a whole. Solutions to environmental problems, or what may
be perceived as environmental problems, may also impact shipboard operations and
not just their design and equipment. The agreement to preclude discharge of
graywater or treated blackwater while a ship is in port is one example. This
practice was formally codified in the enactment of the "Murkowski
Bill" for the waters of Alaska, although cruise ship operators apply such
industry policy globally to the extent possible. As environmental protection
issues continue to unfold, there may indeed be additional operational impacts
that could go so far as to affect the selection of ship itineraries and ports of
call.
Undoubtedly, self-policing will be important for an industry that has been
publicly embarrassed by several environmental violations over the past decade.
In this era of instantaneous communications, it will continue to be imperative
that the cruise lines be proactive in assuring that facts are forthcoming
regarding their self-imposed standards as well as continuing to inform the
regulators and the public of their current onboard waste management practices
and procedures. The cruise industry must be diligent in ensuring the accuracy of
the facts it reports, and also stay vigilant to ensure the same of others.
Certainly, as new technologies are refined and applied onboard ships and even as
old technologies are adapted for use onboard cruise ships, the cruise industry
will want to make these developments known. Use of environmental technologies
such as gas turbine/diesel combinations (CODAG) and water injection techniques
to reduce air emissions, improved graywater treatment and blackwater treatment
systems, dry cleaning and photography systems that do not result in hazardous
wastes, and "clean" ballast water systems will be important steps
forward that the cruise industry will want to publicize to the regulators and to
the public.
CONCLUSION
The cruise industry operating U.S. itineraries is continually under
increasing scrutiny and pressure to adhere to environmental regulations and to
actively participate in the development of related technical, operational,
policy, and legal initiatives. As good corporate citizens who care about the
environment and as responsible businessmen, the leaders in the industry have
made marked strides in recent years toward developing an integrated solution to
the environmental protection issue. Engaging all interested and responsible
parties in open communications, better defining issues and points of concern,
initiating technical studies and data collection efforts, testing technological
innovations in a shipboard setting, and evaluating any necessary regulatory
reform are all examples of progress made. As the issues continue to develop and
evolve, the industry will meet many challenges and continue to face new ones.
Following the significant accomplishments of 2000, the Alaska Cruise Ship
Initiative, and its many component organizations, plan to continue its record of
unprecedented actions and achievements in 2001. The results of planned sampling
events, findings from Coast Guard inspections, and feedback from the industry on
its own environmental management guidelines will further define the status of
environmental compliance in the cruise industry. Technical research,
development, testing, and evaluation will undoubtedly continue as one of the
many key aspects of the total solution. A periodic reexamination of these
issues, related developments, and ultimate impacts are all important aspects of
a comprehensive approach to sound environmental practices.
REFERENCES
Alaska Cruise Ship Initiative, "Part I Final Report - Activities and
Work Products up to June 1, 2000."
Alaska Department of Environmental Conservation. Alaska Cruise Ship
Initiative, Wastewater Monitoring Fact Sheet, November 2000. www.state.ak.us/dec/press/cruise/cruise.htm
International Cruise and Ferry Review, a CCL Magazine, a subsidiary of
Euromoney Publications PLC, London. "Capitalizing on the Spoils of a
Bull Run," Simon Jones interview with Tim Harris, Chairman, P&O
Cruises. Page 14.
Kim, Don K., P.E., "Cruise Ship Wastewater Dispersion Analysis –
Report on the Analysis of Graywater Discharge," prepared for the
International Council of Cruise Lines, September 14, 2000.
Schmidt, Kira, "Cruising for Trouble: Stemming the Tide of Cruise Ship
Pollution," Report prepared by the Director of Bluewater Network’s Cruise
Ship Campaign, March 2000.
Seatrade Cruise Review Published by The Seatrade Organisation, Ltd. March
2001, Vol. 5 No. 1. Page 41. "’Market News’ Cruiseship Orderbook at End
January 2001."
United States Environmental Protection Agency, "Cruise Ship White
Paper," August 22, 2000.
United States General Accounting Office, Report to Congressional Requesters,
"Marine Pollution – Progress Made to Reduce Marine Pollution by Cruise
Ships, but Important Issues Remain," GAO/RCED-00-48, February 2000.
_________________________________
Don K. Kim, P.E., is an Environmental Program
Manager in the M. Rosenblatt & Son Group of AMSEC, LLC in Arlington,
Virginia. Mr. Kim earned his Bachelor of Science and Master of Engineering
degrees in Mechanical Engineering from the University of Virginia. He is a
registered Professional Engineer in the Commonwealth of Virginia. He is a member
of the American Society of Naval Engineers and the American Society of
Mechanical Engineers.
Dennis L. Bryant, Esq., is Senior Counsel in the Washington Office of
Haight Gardner Holland & Knight, a law office of Holland & Knight LLP. He
specializes in the government regulation of ships and shipping. He served
twenty-seven years of active duty in the U.S. Coast Guard, retiring as a
Captain, after supervising the agency's implementation of the Oil Pollution Act
of 1990. He is a graduate of the U.S. Coast Guard Academy and Vanderbilt Law
School. He serves as chair of the Committee on Navigation, Coast Guard, and
Government Regulation of the Maritime Law Association of the United States.
Jennifer M. Salerno is a Senior Environmental Consultant with Booz
Allen & Hamilton in Arlington, Virginia. Ms. Salerno earned her Bachelor of
Science degree in Marine Biology from the University of Maryland at College Park
and her Master of Science degree in Environmental Studies from American
University in Washington, D.C. Her work focuses toward coastal zone management
concepts, endangered species consultations, and development of water
regulations.
Thomas E. "Ted" Thompson is Executive Vice President of the
International Council of Cruise Lines. He retired in 1995 from the U.S. Coast
Guard as a Captain after twenty-seven years of service, twenty-three of which
were in the field of marine safety and environmental protection. Mr. Thompson
graduated from the United States Coast Guard Academy in 1968 and received his
Master of Engineering degrees in Naval Architecture and Marine Engineering and
in Nuclear Engineering from the University of Michigan in 1975. He has been a
member of the Society of Naval Architects and Marine Engineers since 1990.
DISCLAIMER: This paper expresses solely the findings and opinions of the
individual authors and does not necessarily reflect the positions of any
company, organization, or industry.
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