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Enhanced MARPOL IV Sewage and Graywater Pollution Prevention - Holland America Line Westours Case Study

Doug Dixon, P.E., (M) Dixon Marine Surveys, LLC, Seattle Jerome Daly, P.Eng. (V) ZENON Environmental, Inc., Ontario, Canada Hans Dörr, Chief Engineer, (V) Holland America Line Westours, Seattle Randall Peterson, R.S., Chief Environmental Programs, (V) Holland America Line, Seattle

Abstract

Presented in this paper is a synopsis of the status of MARPOL Annex authorizations, current federal and state sewage and graywater regulations, latest EPA/GAO action and the International Council of Cruise Lines mandatory waste management practices. The efforts of Holland America Line Westours to comply with pollution regulations and a review of their upgraded sewage and graywater treatment equipment, procedures and internal reporting in excess of the regulations are examined. Through this examination and understanding of the current regulations and capabilities available for both existing vessels and new designs, it is hoped educated decisions can be made about future regulations.

INTRODUCTION The steady increase in the number of foreign and domestic vessels calling on U.S. ports is generating a closer look by regulators and the public with regard to how they handle their waste and the effect they have on the environment. Central to this expansion are the coastal cruise, foreign cruise and ferry fleets that

accommodate large numbers of passengers with all the attendant wastes generated from their care and feeding, in addition to the normal operation of the ship. As a result, new US sewage and graywater regulations have been enacted, in the form of the 2001 Murkowski Act, to govern operations in sensitive Alaskan waters.

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Industry has reacted with tighter controls with in the trade organizations such as the International Council of Cruise Lines (ICCL). Additional regulations in other sensitive areas could follow. Holland America Line Westours (HALW), operator of ten cruise vessels with an additional four under construction, has enhanced its sewage and graywater pollution prevention machinery, operating procedures, record keeping, training and survey arrangements in order to bring a new level of confidence in its operations in sensitive areas through ultrafiltration processes and increased managerial oversight. Following is a review of the regulations and the enhanced ultrafiltration process. MARPOL CONVENTION International pollution control regulations for ships are set forth by the International Maritime Organization

(IMO) and found in the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978, better known as MARPOL 73/78 for Annex I through V with the Protocol of 1997 covering Annex VI. See table 1. An additional Annex was also under consideration to enact regulations for the phase out of toxic anti-fouling paints. This will be considered instead as a separate Convention at the next IMO meeting in June 1999 with the U.S. taking the lead. Conventions and Annexes come into force 12 months after the date when not less than 15 countries approve and the combined merchant fleets of which constitute not less than 50% of the gross tonnage of the world’s merchant fleet. The United States has yet to approve Annex IV (Sewage) and Annex VI (Air Pollution). Annex VII (Ballast Water) is in the draft proposal stage. See table 2.

Annex I Regulations for the Prevention of Pollution by Oil

Annex II Regulations for the Prevention of Pollution by Noxious Liquid Substances in Bulk

Annex III Regulations for the Prevention of Pollution by Harmful Substances in Package Form

Annex IV Regulations for the Prevention of Pollution by Sewage from Ships

Annex V Regulations for the Prevention of Pollution by Garbage from Ships

Annex VI Regulations for the Prevention of Air Pollution from Ships

Annex VII Regulations for the Prevention of Pollution from Ballast Water (Proposed)

Table 1. IMO MARPOL Convention Annexes

Annexes

Entry into Force No. of Contracting Countries

Percent World Tonnage

Annex I 2-Oct-83 119 95.90 Annex II 2-Oct-83 119 95.90 Annex III 1-Jul-92 100 81.46 Annex IV No 84 46.34 Annex V 31-Dec-88 104 87.86 Annex VI No 4 14.30 Annex VII No 0 0.00

Table 2. Summary of Status of IMO MARPOL Annexes as of 31 December 2001.

MARPOL IV vs. U.S. SEWAGE REGULATIONS MARPOL Annex IV, to which the U.S. is not signatory, allows treated sewage discharge for vessels over 200 GRT or more than 10 persons on board when operating between 4 and 12 nautical miles from land with operational requirements as per IMO Resolution ME.2(VI). See table 3. Alternately, a holding tank to the satisfaction of the Flag Administration may be

installed. Untreated sewage discharge is permitted outside the 12-mile limit. USCG 33 CFR 159.3 for Marine Sanitation Devices (MSD) governs requirements for all vessels for discharge within 3 nautical miles off the coast in the territorial seas with either a Type I or Type II designation dependent upon vessel size. An additional Type III MSD applicable for any vessel allows any device, i.e. a holding tank, that is designed to prevent

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the overboard discharge via containment onboard for the duration of the voyage. These requirements vary

from the international MARPOL regulations as shown in table 3.

Regulated Item USCG

Type I MSD (Vessels 65 ft. or less)

USCG Type II MSD (Any Vessel)

MARPOL IV

Suspended Solids No visible floating solids Less than 150 mg/l Less than 50 mg/l Fecal Coliform Bacteria Less than 1000/100ml Less than 200/100ml Less than 250 /100ml Biochemical Oxygen Demand BOD5

No requirement

No requirement

Less than 50 mg/l

Residual Chlorine No requirement No requirement As low as practicable

Table 3. United States vs. MARPOL MSD Operational Requirements

MARPOL Annex IV Regulation 1 (3) defines sewage not only as drainage and wastes from toilets and urinals but also “WC scuppers” and all sick bay wash basins and drains which may be interpreted to mean the floor drains in all the toilet areas that are normally handled as graywater. This is not a problem for a vessel that has a combined graywater and sewage system, but could pose complications for those who don’t, if Annex IV of the MARPOL Convention ever comes into force. U.S. regulations do not specifically list WC scuppers, but rather define sewage as wastes from toilets and other receptacles intended to receive or retain body waste.

Two types of Type II MSDs have generally been approved in the past, biological where microorganisms reduce the sewage to acceptable levels and physical/chemical where sewage is mechanically macerated and strained to low levels. Both usually depend upon chlorine to bring the final fecal coliform bacteria count to USCG/IMO levels. This may be a point of contention as chlorine itself is coming under scrutiny as a pollutant. Manufacturers have had difficulty in receiving approval of their equipment in Canada for this type of treatment, but no action has been taken against foreign vessels that have MARPOL compliant MSDs. A third Type II has recently been approved using physical and biological processes combined with ultrafiltration and ultraviolet light to produce near drinking quality water. The United States passed the Federal Water Pollution Control Act (FWPCA) in 1972 with reauthorization in 1985 as the Clean Water Act. Section 312 of the Act is codified as 33 USC 1322 to eliminate the discharge of untreated sewage into the waters of the United States. Various states have petitioned and been approved under 40 CFR 140.3/4 for limited no discharge areas for both treated and untreated sewage (ref. 20). Zones with no sewage discharge permitted, treated or non-treated, for

areas where “greater environmental protection” is required are granted under Section 312 (F)(3) when adequate pump -out facilities are provided or in the event a drinking water intake zone is established under Section (F)(4)(B). These areas include fresh water lakes including the majority of the Great Lakes, sensitive seawater bays and sounds. See table 4 for a full listing. PROPOSED MARPOL IV AMMENDMENTS A draft text of the revised Annex IV of MARPOL 73/78 was set out in annex by the Marine Environment Protection Committee (MEPC) at the 44th session Agenda item 12 on 20 October1999 (MEPC 44/12). The draft text was prepared based on the modified version of Annex IV contained in annex to MEPC 37/12/10 and MEPC 38/8/6. These amendments were developed by the previous Correspondence Group led by Germany, and the proposed amendments to regulations 9, 11 and 12 of the modified version of Annex IV contained in MEPC 43/11/2, which was developed by the Correspondence Group led by Singapore. (ref. 4) The US maintains its position that it cannot support the ratification of Annex IV in its current form. The US supports the continued review and discussion of the proposed amendments to Annex IV, however, the problem remains that the amendments have not yet addressed most of the concerns that the US has with the requirements of Annex IV. The main reasons for the US not accepting Annex IV are because of difficulties related to the definition of sewage, applicability, on-board treatment, nutrient sensitive resources, effluent standards and reception facilities. In summary, the US feels that fundamental amendments to Annex IV are needed. The US states the proposed amendments have not addressed these basic problems. (ref. 3)

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Table 4. FEDERAL CLEAN WATER ACT NO DISCHARGE ZONES

Type 312(f)(3) which protects aquatic habitats where pump out facilities are available Type 312(f)(4)(A) which protects special aquatic habitats or species Type 312(f)(4)(B) designed to safeguard human health by protecting drinking water intake zones

State Water body CWA Type Section 312

Federal Register Notice

Date

California Mission Bay (f)(3) 41 FR 34353 8/13/76 California Oceanside Harbor (f)(3) 41 FR 34353 8/13/76 California Dana Point Harbor (f)(3) 41 FR 34353 8/13/76 California Channel Islands Harbor (f)(3) 44 FR 26963 5/8/79 California Oxnard (f)(3) 44 FR 26963 5/8/79 California Avalon Bay Harbor (f)(3) 44 FR 26963 5/8/79 California Santa Catalina Island (f)(3) 44 FR 26963 5/8/79 California Newport Bays (f)(3) 41 FR 2274 1/15/76 California Sunset Bay (f)(3) 41 FR 2274 1/15/76 California Pacific Coast Highway Bridge (f)(3) 41 FR 2274 1/15/76 California Richardson Bay (f)(3) 52 FR 33282 9/2/87 California Huntington Harbor (f)(3) 41 FR 2274 1/15/76 California/ Nevada Lake Tahoe (f)(3) 42 FR 59105 11/15/76 Florida Destin Harbor (f)(3) 53 FR 1678 1/21/88 Florida City of Key West waters (f)(3) 64 FR 46390 8/25/99 Massachusetts Westport Harbor (f)(3) 59 FR 45677 9/2/94 Massachusetts Wellfleet (f)(3) 60 FR 30539 6/9/95 Massachusetts Waquoit Bay (f)(3) 59 FR 11271 3/10/94 Massachusetts Nantucket Harbor (f)(3) 57 FR 44379 9/25/92 Massachusetts Wareham Harbor (f)(3) 57 FR 2553 1/22/92 Massachusetts Stage Harbor Complex (f)(3) 62 FR 13885 3/24/97 Massachusetts Harwich (f)(3) 63 FR 44255 8/18/98 Massachusetts Buzzards Bay (f)(3) 65 FR 46712 7/31/00 Michigan All (f)(3) 41 FR 2274 1/15/76 Minnesota Boundary Waters Canoe Area (f)(4)A 42 FR 43837 8/31/77 Minnesota Mississippi River (part) (f)(3) 42 FR 33362 6/30/77 Minnesota Minnesota River (part) (f)(3) 42 FR 33362 6/30/77 Minnesota St. Croix River (f)(3)

DENIAL 61 FR 30868 42

FR 37844 6/18/96 7/25/77

Missouri All (except Miss. River, Missouri River, part of Bull Shoals Lake)

(f)(3) 40 FR 54462 11/24/ 75

New Hampshire All (except coastal waters) (f)(3) 40 FR 36797 8/22/75 New Jersey Shark River (f)(3) 63 FR 12094 3/12/98 New Jersey Manasquan River (f)(3) 63 FR 12094 3/12/98 New Jersey Shrewsbury River (f)(3) 65 FR 32091 5/22/00 New Jersey Navesink River (f)(3) 64 FR 25504 5/12/99 New Mexico All (f)(3) 41 FR 17599 4/27/76 New York Lake Champlain (f)(3) 41 FR 24624 6/17/76 New York Mamaroneck Harbor (f)(3) 62 FR 223 11/19/97 New York Lake George (f)(3) 41 FR 2668 1/19/76

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Table 4. FEDERAL CLEAN WATER ACT NO DISCHARGE ZONES , continued

Type 312(f)(3) which protects aquatic habitats where pump out facilities are available Type 312(f)(4)(A) which protects special aquatic habitats or species Type 312(f)(4)(B) designed to safeguard human health by protecting drinking water intake zones

State Water body CWA Section 312

Type

Federal Register Notice

Date

New York Hudson River (part) (f)(4)(B) 60 FR 63941 12/13/95 New York East Hampton (7 water bodies) (f)(3) 64 FR 7194 2/12/99 New York Greater Huntington-North Port (f)(3) 65 FR 37385 6/14/00 Rhode Island Great Salt Pond, Block Island (f)(3) 58 FR 31202 6/1/93 Rhode Island All (f)(3) 63 FR 42633 8/10/98 South Carolina (North Carolina and Georgia)

Broad Creek, Lake Keowee, Lake Murray, Lake Thurmo nd, and Lake Wylie

(f)(3) 64 FR 10465 3/4/99

South Carolina (Georgia)

Hartwell Lake (f)(3) 60 FR 25215 5/11/95

Texas 24 Freshwater bodies (f)(3) 42 FR 59776 11/21/77 Utah/Arizona Lake Powell (f)(3) 65 FR 56577 9/19/00 Vermont All (including parts of La ke

Champlain and Lake Memphremagog)

(f)(3) 40 FR 42240 9/11/75

Virginia Smith Mountain Lake (f)(3) 65 FR 61166 10/16/00 Wisconsin All (except Lake Superior,

Mississippi River, part St. Croix River)

(f)(3) 41 FR 11875 3/22/76

FEDERAL MURKOWSKI ACT

On December 21, 2000 U.S. Congress passed ``Title XIV--Certain Alaskan Cruise Ship Operations'' of the Miscellaneous Appropriations Bill (H.R. 5666) in the Consolidated Appropriations Act of 2001 (P.L. 106-554) known as the Murkowski Act for the Senator from Alaska, to regulate sewage and graywater in Alaska for large cruise vessels with 500 or more passengers. Specifically excluded from this were vessels of the United States operated by the Federal Government and vessels owned and operated by the government of a State, such as the entire fleet of nine Alaska State ferries. The legislation is currently under a Notice of Proposed Rulemaking by the USCG under 33 CFR 159 to accomplish the following: (a) Ensure that cruise vessels operating in the waters of the Alexander Archipelago and the navigable waters of the United States within the State of Alaska and within the Kachemak Bay National Estuarine Research Reserve comply with all applicable environmental laws, including, but not limited to, the Federal Water

Pollution Control Act, as amended (33 U.S.C. 1251 et seq.), the Act to Prevent Pollution from Ships, as amended (33 U.S.C. 1901 et seq.)

(b) Ensure that cruise vessels do not discharge untreated sewage within the waters of the Alexander Archipelago, the navigable waters of the United States in the State of Alaska, or within the Kachemak Bay National Estuarine Research Reserve.

(c) Prevent the unregulated discharge of treated sewage and graywater while in ports in the State of Alaska or traveling near the shore in the Alexander Archipelago and the navigable waters of the United States in the State of Alaska or within the Kachemak Bay National Estuarine Research Reserve unless underway and proceeding at a speed of not less than six knots and not less than one nautical mile from the nearest shore.

(d) Ensure that discharges of sewage and graywater from cruise vessels are monitored for compliance by examination of environmental compliance records and procedures; inspection of the functionality and proper

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operation of installed equipment for abatement and control of any discharge; and incorporate a plan for sampling and testing.

Additionally, inspections may include unannounced inspections of any aspect of cruise vessel operations, equipment or discharges and require a logbook detailing the times, types, volumes or flow rates and locations of any discharges of sewage or graywater. Until such time as the formal regulations are in place, treated sewage and graywater may be discharged inside of one mile and at speeds less than 6 knots provided that: 1. The discharge satisfies the minimum level of

Secondary treatment effluent quality specified in 40 CFR 133.102:

(a) BOD<INF>5</INF> Biological Oxygen Demand (1) The 30-day average shall not exceed 30 mg/l. (2) The 7-day average shall not exceed 45 mg/l. (3) The 30-day average percent removal shall not

be less than 85 percent. (b) SS (Total Suspended Solids) (1) The 30-day average shall not exceed 30 mg/l. (2) The 7-day average shall not exceed 45 mg/l. (3) The 30-day average percent removal shall not be less than 85 percent.

(c) pH. The effluent values for pH shall be within the limits of 6.0 to 9.0

2. The geometric mean of the samples from the discharge during any 30-day period does not exceed 20 fecal coliform/100 ml and not more than 10 percent of the samples exceed 40 fecal coliform/100 ml;

3. Concentrations of total residual chlorine may not exceed 10.0 mg/l; and,

4. Prior to any such discharge occurring, the owner demonstrates test results from at least five samples taken from the vessel representative of the effluent to be discharged, on different days over a 30-day period, as per 40 CFR Part 136 and demonstrates continued compliance through periodic sampling.

Administrative civil penalties for violations can be up to $10,000 per day for each day during which the violation continues, except that the maximum amount of any class II civil penalty under this section shall not exceed $125,000.00. EPA ACTION On March 17, 2000, the Bluewater Network sent a petition (ref. 15) to the U.S. Environmental Protection Agency (EPA) Administrator Carol Browner on behalf

of 53 organizations, asking the EPA to take regulatory action on measures to address pollution by cruise ships. The petition specifically calls for an investigation of wastewater, oil and solid waste discharges from cruise ships, and the implementation of policy or regulatory changes if necessary to assure that these discharges do not threaten the marine environment. In response to the petition, EPA agreed to study cruise ship discharges and waste management approaches. A Cruise Ship White Paper (ref. 6) by the EPA dated August 20, 2000 provides preliminary information regarding cruise ships and waste management practices. Preliminary recommendations regarding EPA’s response to the petition are given stating the options presented in the paper should not be interpreted as Agency recommendations or as a decision on the Bluewater Network petition. The Cruise Ship White Paper recommends the following EPA actions:

(1) Conduct an assessment of: • the volumes and characteristics of cruise ship waste streams and their potential impact on water quality and the marine environment; • the effectiveness of existing programs (regulatory and non-regulatory) for managing those waste streams; and • options for better environmental management of cruise ship waste streams including the issuance of regulations and/or voluntary environmental management programs such as public-private partnerships.

(2) Solicit additional information from the petitioners, other environmental groups, the cruise ship industry, government agencies, and the public for incorporation into the assessment. Hold public information hearings in Los Angeles, California (Sept. 6, 2000); Juneau, Alaska (Sept. 8, 2000); and Miami, Florida (Sept. 12, 2000) where there is a large amount of cruise ship traffic as a way to solicit this information. (3) Once the assessment is drafted, make it available to the public. (4) Establish an interagency workgroup with EPA and the Coast Guard in primary roles to review the assessment and take appropriate action. (5) Continue to support Coast Guard, State and industry efforts to improve cruise ship waste management practices while assuring that these efforts are consistent with national policy and regulations.

Subsequent to this, a Cruise Ship Plume Tracking Survey (ref. 9) was carried out August 10-13, 2001 on Carnival Cruise Lines’ Fascination and Paradise. The project objectives were:

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(1) Determine the effluent dilution characteristics in the wake of the cruise ship; (2) Track the longer-term location and mixing dynamics of the effluent plume; (3) Provide preliminary information on whether discharge plumes behave as predicted by the model; (4) Assess the utility and feasibility of monitoring fecal coliforms (tracers of sewage) in the wake of the cruise ship.

Results are pending, with one comment being “dilution is the solution to pollution” which was supported by the previous Rosenblatt & Son/ICCL “Cruise Ship Waste Dispersion Analysis - Report on the Analysis of Graywater Discharge ” September 14, 2000. (ref. 11) GAO ACTION In February 2000 the Resources, Community and Economic Development Division of the United States General Accounting Office released a report on cruise ship pollution (ref. 9) at the request of House Representatives John D. Dingell and Henry A Waxman. 87 illegal discharges in U.S. waters were noted between 1993 to 1998, all oil, garbage or plastic related. However, concern was noted regarding the large volume of wastewater from sinks, showers, drains and sewage systems that cruise ships legally discharge at sea and the possible effects of these discharges on sensitive marine life. IMO ISM CODE In 1998, new amendments to IMO SOLAS Chapter IX entered into force to make mandatory the International Safety Management (ISM) Code, which had been adopted by the IMO in November 1993 (Assembly resolution A.741(18)). Chapter IX applies to passenger ships and tankers from that date and to cargo ships and mobile drilling units of 500 gross tons and above from July 1, 2002. These requirements are administered by USCG under 33 CFR 96. The ISM Code establishes safety management objectives which:

• Provide for safe practices in ship operation and a safe working environment; • Establish safeguards against all identified risks; and • Continuously improve safety management skills of personnel, including preparing for emergencies.

The Code requires Safety Management System (SMS) Plans to be established by owners or any person who has assumed responsibility for operating a ship. A plan for the above objectives, details of resources and shore-based support must be developed in a Safety Management Manual which is kept on board and audited periodically, usually by the Class Society on

behalf of the administration. The primary focus is safety, but also included is environmental protection. STATE REGULATIONS Various state, county and city regulations also come into effect within their jurisdiction. An example is Washington State RCW 90.48.080. The criteria developed on the international and national level theoretically should allow for the operation of properly maintained MSD in the navigable waters of the U.S. This is dependent upon interpretation of the Clean Water Act, state and local regulations as to the definition of the harmful effects of discharges and the sensitivity of the surrounding water such as captive freshwater and remote saltwater bays with poor tidal action. States that have stricter sewage discharge regulations such as Washington with 14 fecal coliform bacteria per 100 ml, as opposed to the Federal 200/1000 ml limits, are precluded from enforcement without the special sewage area designation. However, there is no prohibition from enforcement of State pollution standards as they apply to graywater discharge (ref. 5). These definitions can be strict and subject to interpretation, as an example the Revised Code of Washington RCW 90.48.080 defines pollution as:

“such contamination, or other alteration of the physical, chemical, or biological properties of any waters of the state, including changes in temperature, taste, color, turbidity or the odor of the waters, or such discharge of any liquid, gaseous, solid, radioactive, or other substance into any waters of the state as will or is likely to create a nuisance or render such waters harmful, detrimental or injurious to the public health, safety or welfare, or to domestic, commercial, industrial, agricultural recreational or other legitimate beneficial uses, or to livestock, wild animals, birds, fish or other aquatic life.” Effective July 1, 2001 the state of Alaska enacted the first state law in the country to regulate cruise ship pollution. The legislation requires cruise ships to: • Register with the state. • Maintain records of black (sewage) and graywater

pollution. • Sample its discharges at least twice per year. • Allow the state access to the vessel for the purpose of

additional sampling if the state requests. Pay a fee of $0.75 - $1.75 per passenger, depending on number of passengers, to the state to pay for the administration of this program.

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The law also prohibits the discharge of untreated sewage, provides standards for total suspended solids (TSS) and fecal coliform in treated sewage and gray water discharges, authorizes the Alaska Department of Environmental Conservation (ADEC) to establish standards for additional pollutants in sewage and gray water, and generally allows discharges only at distances greater than one mile from shore and speed more than 6 knots. It provides for civil penalties of $500 - $100,000 for an initial violation of these provisions, plus $10,000 maximum per day for each day of continuing violation. It makes it a misdemeanor to, with criminal negligence, violate the law or an ADEC order or regulation enforcing it, or make false statements. Some of these provisions already exist in federal law, but the legislation gives the state a more active oversight and enforcement role. FLORIDA MOU and ICCL POLICY On March 14, 2000 the 15 Member Lines of the Florida-Caribbean Cruise Association (FCCA) as representatives of the cruise industry signed a Memorandum of Understanding (ref. 12) with the Florida Department of Environmental Protection (FDEP) regarding its environmental practices and policies.

The cruise industry, through the FCCA and International Council of Cruise Lines (ICCL), developed cruise industry policy with regards to waste minimization, waste recycling and waste management based on the following underlying principles:

• Comply with applicable laws and regulations. • Maintain cooperative relationships with the

regulatory community. • Manage waste streams. • Minimize waste generated. • Maximize reuse and recycling. • Educate and training cruise vessel personnel in waste

management practices. • Embrace new technology in the management of

waste streams. • Design cruise vessels to be environmentally friendly. The International Council of Cruise Lines (ICCL) has published the “Cruise Industry Waste Management Practices and Procedures”,(ref. 7) effective date July 1, 2001, revised December 14, 2001. Each ICCL cruise vessel operator has agreed to utilize one or more of the practices and procedures contained in the “Cruise Industry Waste Management Practices and Procedures” in the management of their shipboard waste streams. Recognizing that technology is progressing at a rapid rate, any new equipment or

management practices that are equivalent to or better than those described, and which are shown to meet or exceed international and federal environmental standards, will also be acceptable. Member lines have agreed to communicate to ICCL the use of equivalent or other acceptable practices and procedures. As appropriate, such practices and procedures shall be included as a revision to the attached document. As an example, when improved systems for treating sewage and graywater are perfected and shown to meet the requirements for MSDs and accepted by appropriate authorities, the new systems and associated technology will be included in the attachment as a revision. ICCL and its Environmental Committee will work with the U.S. Coast Guard, the U.S. Environmental Protection Agency and other appropriate agencies to further implement the above commitments. LOCAL REGULATION Concern for the cleanliness of water is evident past the federal and state levels all the way down to the county and city governments. An example of this is the formation of Washington’s King County Interagency Regulatory Analysis Committee (IRAC) Boating/Sewage Compliance Task Force. This work group was formed primarily to focus on the recreational boating sewage problems that cross city, county and port boundaries but includes the interface of federal rules and commercial shipping. Agencies and their regulations were identified in the IRAC Boating/Sewage Compliance Matrix (ref. 8) with a recommendation to pursue the Clean Water Act no discharge areas for both treated and untreated sewage under 40 CFR 140.3/4 section 312. CLASSIFICATION SOCIETY RULES The major Classification Societies have developed voluntary standards for shipboard environmental compliance. These rules are based on the principles established under ISO 14000, similar to the methodology employed in the International Shipboard Management (ISM) code, which is rooted in the ISO 9000 philosophy. An example is Lloyd’s Register of Shipping (LR), which classes the Holland America Line Westours fleet, recently published revised Provisional Rules for Environmental Protection. First published in 1998, these provisional rules apply to both new and existing ships with voluntary compliance for the environmentally conscious who want to more effectively manage environmental and business risk. The LR Environmental Protection (EP) notation covers the major areas of concern with regard to operational

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pollution from shipping. The rules aim to help owners: • control operational pollution • provide public validation of onboard environmental performance • demonstrate a pro-active approach to environmental protection.

This system enables owners to highlight substantial investment in particular aspects of pollution control, while demonstrating a high all-round level of environmental performance. The core LR EP rule requirements demand a level of environmental performance in excess of international legislative requirements and cover:

• oxides of nitrogen (NOx) and oxides of sulphur (SOx) emissions • refrigerants and fire-fighting agents • oil pollution prevention • garbage handling and disposal • sewage treatment • hull anti-fouling systems • ballast water.

Compliance leads to assignment of the LR Environmental Protection EP letter notation. Compliance with additional more stringent requirements in a range of specific areas, such as graywater treatment and protected fuel tanks, will lead to assignment of supplementary characters, further enhancing recognition of owners’ proactive commitment to the environment ahead of international requirements. SOLID WASTE

The United States approved MARPOL Annex V (Garbage) in December 1987. The IMO Annex was implemented by law via the Act to Prevent Pollution from Ships 33 USC 1901-1911. Garbage consisting of victual, domestic and operational waste is regulated by the USCG in 33 CFR 151.51 to 151.77, see table 5. IMO Special Areas are areas where the discharge of all garbage, with the exception of ground food waste at greater than 12 miles, is prohibited and include the Mediterranean Sea, Baltic Sea, Black Sea, Red Sea, the Gulfs from Ras al Hadd to Ras al Fasteh, North Sea and the Antarctic. The wider Caribbean Region, which includes the Gulf of Mexico, has the same Special Area status with ground garbage permitted at greater than 3 miles. MARPOL Annex V Regulation 9 and 33 CFR 151.55/57 both require strict development of an onboard Waste Management Plan and to report and maintain records of refuse discharge. Willful violators are guilty of a Class D felony and subject to fines of up to $250,000 per individual or $500,000 per organization as well as prison terms of up to 6 years. Additionally, the solid waste disposal from vessels is subject to further restrictions as per 33 CFR 151.65 with 24-hour notice required before arrival with the following wastes from a foreign port excluding Canada:

(a) Garbage regulated by the U.S. Department of Agriculture’s' Animal and Plant Health Inspection Service (APHIS) 7 CFR 330.400 and 9 CFR 94.5

(b) Medical Wastes (c) Hazardous waste as per 40 CFR 261.3

Table 5. MARPOL/US Solid Waste Disposal Regulations

Garbage Type Outside Special Areas

In Special Areas

Plastics, synthetic ropes, fishing nets, and plastic bags Disposal Prohibited Disposal Prohibited

Floating dunnage, lining and packing material > 25 miles off shore Disposal Prohibited

Paper, rags, glass, metal, bottles, crockery, and simila r refuse > 12 miles Disposal Prohibited

All other garbage, paper, rags, glass comminuted or ground (1) > 3 miles Disposal Prohibited

Food waste not comminuted or ground >12 miles Disposal Prohibited

Food waste comminuted or ground (1) >3 miles > 12 miles (2)

Mixed refuse types (3) (3) 1. Ground garbage must be able to pass through a screen with a mesh size no larger than 25 mm. 2. Western Caribbean Region is >3 miles for ground garbage only. 3. When garbage is mixed with other harmful substances having different disposal or discharging requirements,

the more stringent disposal requirements will apply.

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HOLLAND AMERICA LINE WESTOURS CASE STUDY CORPORATE OPERATING PHILOSOPHY Holland America Line Westours is a cruise ship company operating ten large passenger vessels worldwide, and marks its 130th year in business in 2002. In 1872 the Dutch steamship Rotterdam was launched in answer to the high demand for travel to America. Up to this point the English and Germans dominated the lucrative European steamship business. With the opening of a canal linking the city of Rotterdam with the North Sea a new era was born in transporting travelers, immigrants and cargo from Holland to America - the Holland America Line. Today, Holland America’s fleet of passenger vessels includes the 1,214-passenger ms Noordam (1984), the 1,266-passenger sister ships ms Statendam and ms Maasdam (1993) ms Ryndam (1994) ms Veendam (1996) ms Rotterdam (1997) ms Volendam (1998) ms Zaandam (1999) ms Amsterdam (2000) ms Prinsendam (2002) with four new class vessels under construction. In addition to these larger vessels, Holland America also operates the Windstar Cruises fleet of four motor sailing ships, three each of approximately 150-passenger capacity, msy Wind Star, msy Wind Song and msy Wind Spirit and one large motor sailing vessel msy Wind Surf. The company is proactive instead of reactive and well ahead of the learning curve of regulatory compliance. This approach takes compliance of existing regulations into account, anticipates new regulations and incorporates pollution prevention strategies into the process. In 1994 a corporate committee was founded to coordinate the environmental efforts being made on the vessels and expand that effort. The committee's challenge was to coordinate and expand an already impressive environmental program. Holland America Line Westours is committed to maintaining a clean and healthy environment for its passengers, employees and the communities visited by the company's ships. Holland America's concern with the environment predates most of the legislation governing waste disposal. Environmental issues are regarded as integral with all of the functions of operating the ships and are included in everything from job descriptions to performance evaluations. Environmental sensitivity and impact of the vessels is regarded as a high priority of the total operations. In

1995 Holland America made a significant commitment in establishing the "Seagoing Environmental Awareness" (S*E*A) committee to coordinate and expand the environmental program and maintain a high level of commitment. The S*E*A program reaches from the corporate headquarters out to all the Holland America Line Westours fleet. The program acts as a communications hub for the individual ship's sanitation and environmental committees and communicates their observations, recommendations and needs to the company's planning and operations management. These committees also oversee the development of educational programs for employees and guests that highlight environmental subjects. PREVIOUS SEWAGE TREATMENT PLANT The previous sewage only treatment system was manufactured by Hamworthy, which consisted of four separate treatment tanks of 38 tons each. The approved MSD was designed to take only black water and biologically treat the effluent to an acceptable quality in three stages with chlorine injection into the final effluent. Effluent testing was initiated in 1998 and discovered that the units did not meet discharge requirements. Fortunately, the holding of wastewater in port had already initiated. The manufacturer was contracted to initiate an improvement program for operation, which consisted of a complete overhaul of the system to replace blowers, diffusers, level switches and contact time controls for treatment. The effluent was also treated with chlorine dioxide rather than chlorine to help achieve the bacterial load reduction required for compliance. At that same time Holland America began researching wastewater treatment technologies and discovered the previously land-based ZENON system at Seatrade in 1999. Holland America Management have always tried to stay ahead of the combined black and graywater treatment curve on new regulations, a demonstration installation was carried out for the ms Statendam. After successful start-up and refinement of the system for cruise ship applications, the installation onboard the ms Zaandam and four other vessels were carried out at a cost of approximately $2,000,000 per vessel.

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ms ZAANDAM PRINCIPAL CHARACTERISTICS

Length Overall..............................................................................................................780.6 feet, 238.00 m. Length between Perpendiculars.................................................................................662.6 feet, 202.00 m. Beam..............................................................................................................................105.8 feet, 32.25 m. Draft ................................................................................................................................. 26.6 feet, 8.10 m. Depth................................................................................................................................ 36.1 feet, 11.00 m. Air Draft ........................................................................................................................160.1 feet, 48.8 m. Passengers.................................................................................................................................. 1,805 Persons Crew................................................................................................................................................620 Persons Displacement .................................................................................................................................... 33,950 LT Propulsion Power (2 @ 13 megawatt each)................................................................................31,765 HP Main Electrical Generation (5 @ 8,640 kW each)....................................................................43,200 kW Maximum Speed ................................................................................................................................. 23 knots International Tonnage.......................................................................................................................63,000 grt Capacities Fuel Oil ............................................................................................852,591 US gal., 3,227.4 cu. m. Fresh Water......................................................................................580,493 US gal., 2,197.4 cu. m. Sewage & Graywater Holding ....................................................... 70,613 US gal., 267.3 cu. m. Lube Oil.............................................................................................. 26,946 US gal., 102.0 cu. m. Oily Water Tank………………………………………………12,865 US gal., 48.7 cu. m. Waste Water Design Criteria Total People Onboard .................................................................................................... 2,425 Persons Sewage .................................................................................................... 29,059 gal/day (110 m3/day) Graywater............................................................................................. 158,503 gal/day (600 m3/day) Total Design Load ................................................................................187,562 gal/day (710 m3/day) SYSTEM DESIGN SUMMARY

Holland America Line Westours has installed a ZENON Environmental Inc. immersed membrane bioreactor wastewater treatment system on the ms Zaandam. This system is designed to process a maximum of 187,562 gallons per day (710 m3/day) of all blackwater and graywater (i.e. accommodation, laundry, galley and Somat pulper effluent) generated aboard the ship. The system is designed to produce effluent (permeate) with Biological Oxygen Demand BOD5 < 15 mg/l, TSS < 2 mg/l and fecal coliform < 10/100 ml. Commissioned in May 2001, the system’s performance has been fully validated and was certified as a Type II MSD by the United States Coast Guard in October 2001. The actual performance has exceeded the design specifications; effluent BOD typically ranges between 2 and 5 mg/l, and both TSS and fecal coliform count are below detectable limits. In practice, the actual combined gray and black wastewater generation rate is approximately 15 per cent less than the design capacity, or approximately 158,503 gallons per day (600 m3/day). Holland America has installed the same system on other vessels engaged in the Alaskan passenger trade and governed by the Murkowski Act (i.e. ms Statendam, Volendam, Veendam and Ryndam)

PROCESS SUMMARY The ZENON system is a typical application of the company’s proprietary ZeeWeed/ZenoGem technologies, which combine bio-oxidation and membrane ultrafiltration into a single process such that system operation is simplified and space requirements are minimized. The Zaandam system features the same processes that have been applied in hundreds of ZENON’s land-based municipal wastewater treatment plants. Four basic processes are used in the system: Equalization - The graywater streams are combined and temporarily placed in a holding tank to equalize the biological and solids loading, and provide a reservoir from which the bioreactor can be fed at a constant rate.

Bio-oxidation - The organic content of the mixed liquor is processed biologically in an aerated bioreactor.

Membrane Ultrafiltration - The bioreactor mixed liquor is filtered through a hollow-fiber ultrafiltration membrane system. The membranes are immersed directly in the bioreactor and operate under vacuum, causing the purified water to permeate though the membrane surfaces into the hollow cores of the fibers.

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UV Disinfection - Prior to overboard discharge or reuse, the permeate is exposed to ultraviolet light to kill any residual bacteria which may have penetrated the membranes. ZeeWeed - ZenoGem Process The ZENON ZeeWeed ZenoGem process combines the best features of biological processing and membrane filtration. Used individually, neither method provides a satisfactory solution given the space constraints aboard a cruise ship. Stand-alone biological treatment for gray and black water is limited by available tank volume, which is typically inadequate to achieve the required SRT and HRT levels necessary to satisfy the effluent quality requirements. Membrane filtration alone is not suitable for processing blackwater or graywater, either individually or combined, as conventional membrane systems foul rapidly when processing either type of waste in their raw form. The ZENON system utilizes a proprietary process, whereby the combined blackwater and graywater streams are biologically treated and concentrated in a tank containing ZeeWeed® membrane modules. ZeeWeed® utilizes hollow-fiber ultrafiltration membranes, figure 1, that are tolerant of high concentrations of suspended solids. This feature allows high solids levels to be achieved in the bioreactor, thereby minimizing the working volume required. In addition, the ZeeWeed® membranes produce extremely high quality effluent that does not require chlorination to achieve USCG and IMO discharge criteria. The ZenoGem process is a proprietary membrane bioreactor (MBR) process that has been applied for the treatment of industrial and commercial wastewaters for over ten years. In the process, ultrafiltration membranes separate the treated water from the mixed liquor. In effect, the membranes perform the functions of the secondary settler and tertiary filter of the activated sludge process in a conventional wastewater treatment plant. Historically, energy costs associated with pumping the mixed liquor under high pressure through tubular or reverse osmosis membranes precluded widespread application of the process for the treatment of municipal wastewater. However, development of immersed hollow fiber ZeeWeed membrane technology has eliminated the need for high-pressure pumping and greatly reduced energy requirements.

ZeeWeed are proprietary hollow-fiber ultrafiltration membranes that are immersed within the bioreactor, in direct contact with the mixed liquor. The ZeeWeed hollow fiber membranes are contained in bundles called modules, which are assembled into cassettes of 8-12 modules. The membrane modules are directly immersed in the aeration tank, in direct contact with the mixed liquor. Through the use of a centrifugal or positive displacement pump, a vacuum varying between 2 and 9 psi is applied to a header connecting the membrane modules. The vacuum draws the treated water through the hollow fiber membranes. The treated water passes through the hollow fibers and is pumped out by the permeate pump. All particulate matter and the mixed liquor solids are rejected at the surface of the membrane. The ZeeWeed membranes are automatically back pulsed on a regular basis using collected permeate. A coarse bubble air diffuser is located at the base of each membrane module. The airflow provided by the diffuser scours the external surface of the membrane transferring the rejected solids away from the membrane surface. This airflow also provides a portion of the biological oxygen requirements. Supplemental coarse or fine bubble diffuser grids may be used to supply the remainder of the biological oxygen requirements. Sludge is wasted directly from the aeration tank at the operating MLSS concentration between 10,000 – 15,000 mg/l. Figure 2 shows a simplified process flow diagra m, illustrating the major process stages.

Figure 1. ZeeWeed® Membranes

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Figure 2. ZenoGem Shipboard Process Flow Diagram

The membrane module is the building block of the system. An individual membrane module is the smallest replaceable unit within any ZeeWeed filtration system. ZeeWeed hollow fiber membranes are strong polymeric membranes cast on the outside surfaces of porous support lumens. ZeeWeed membranes create an absolute barrier to biomass, solids

and Oocysts, resulting in a clear effluent independent to settling characteristics of the sludge. ZeeWeed® membranes exclude any particles larger than 0.035 µm in size. Figure 3 illustrates the relative particle sizes that are separated or rejected by typical filtration processes; ZeeWeed falls within the ultrafiltration range.

RelativeSize of Common

Materials

ApproximateMolecular Weight

Angstroms Units(Log Scale)

Micrometers(Log Scale)

ST Microscope

Ionic Range

0.001 0.01 0.1 1.0 10 100 1000

10 710610 5104103102101

100

Reverse Osmosis

Nanofiltration

Ultrafiltration

Microfiltration

Particle Filtration

200 1000 10,000 20,000 100,000 500,000

Molecular Range Macro MolecularRange

Micro Particles Range

Scanning Electron Microscope Optical Microscope Visible to Naked Eye

Macro Particle Range

Processfor

Separation

Aqueous Salt Carbon Black

Endotoxin/Pyrogen

Paint Pigment

Cryptosporidium

GiardiaCyst

Human Hair

Beach Sand

Mist

Yeast Cell

Bacteria

Coal Dust

RedBloodCellBlue Indigo Dye

Tobacco Smoke

Gelatin

Metallon Synth.Dye

Virus

PinPoint

Pollen

A.C. Fine Test Dust

Latex/Emulsion

GranularActivated

Carbon

Colloidal Silica

Asbestos Milled Flour

AtomicRadius

Sugar

Albumin Protein

Figure 3. – Process Comparison Filtration Spectrum

Nominal Pore Size of ZeeWeed® Membrane

Black Water (Sewage)

Ventilation

Screening

ZeeWeed® ZenoGem®

Bioreactor UV Disinfection

Backpulse Tank Collection

Tank

Permeate Discharge Overboard

Permeate Reuse

Aerated Solids Tank

Overboard Discharge > 12 Miles

Bioreactor Waste Tank

Shoreside Discharge

Macerator/ Recirculate

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The membrane fibers are assembled in individual modules, with the ends of each fiber potted in polyurethane resin in top and bottom headers. The modules in turn are configured in cassettes, which are immersed in the bioreactor mixed liquor.

Figure 4. ZeeWeed 500c Cassette PROCESS EQUIPMENT - MAJOR COMPONENTS All of the process equipment is installed immediately adjacent to the bioreactors. The system is configured in two process trains to provide a measure of redundancy, and to facilitate cleaning. Although the membranes feature a continuous self-cleaning back pulse function and air scouring, the modules will require periodic chemical soaking (i.e. once every six to twelve months) to remove biological foulants. The major components of the system include:

• One (1) graywater equalization tank (existing

double-bottom tank N.3.C.); • Two (2) graywater feed pumps; • Two (2) mechanical screening units to remove hair,

string and other solids which are potentially hazardous to the hollow-fiber membranes;

• One (1) break tank to collect screened water from the units;

• One (1) aerated solids collection tank (36 m3) to receive screened solids from the screening units.

• Two (2) solids recirculation/macerator pumps to keep the solids mixed and in suspension in the aerated solids collection tank;

• One (1) offload pump for discharge of solids ashore;

• Two (2) bioreactor feed pumps which transfer water from the break tank to the bioreactors;

• Two (2) bioreactor tanks, converted from a single existing potable water tank, each equipped with fine-bubble diffuser aeration systems;

• (24) ZeeWeed® membrane cassettes, twelve immersed in each bioreactor (6 per train), with aeration supplied to each train by a blower;

• One (1) bioreactor waste water tank port double bottom tank no. 3;

• Two (2) permeate pumps; • Two (2) mixed liquor recirculation pumps, used to

keep the bioreactor tank contents mixed and to periodically pump waste from the bioreactors to the bioreactor waste water tank;

• One (1) UV disinfection unit. PROCESS DESCRIPTION Graywater Equalization Graywater from the laundry, accommodation sources, the galley and the Somat system are transferred, either automatically via continuous feed pumps or under manual control by an engineer from the Engine Control Room, from existing collection tanks to the equalization tank, double-bottom tank N.3.C. Prior to entering the equalization tank, the galley and Somat streams pass through an existing grease trap to remove free oils and grease. The blended graywater is pumped from the equalization tank to the mechanical screens. The transfer pumps are controlled by the ZENON system PLC, which receives level signals from transmitters in the equalization tank and the screened water tank. Screening Black water is transferred from four vacuum collection system tanks. Each collection system is equipped with a discharge pump that empties the collection tank based on timer and level control operation. The flow of blackwater to the ZENON system is usually continuous; there can be periods of intermittent and varying flow due to the manner the discharge pumps operate. The black and graywater streams are blended immediately before entering the twin (parallel) mechanical screening units. Screened filtrate flows by gravity into a collection tank; the screened solids are discharged into a separate solids holding tank. Screened solids rejected by the mechanical screens are collected in the (36 m3) aerated solids collection tank and re-hydrated using by the wasted sewage sludge;

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approximately 700 kg/day are filtered from the combined raw blackwater/graywater influent stream. The holding tank is aerated to inhibit the development of anaerobic conditions, which would cause odor problems and generate potentially dangerous explosive gases. A macerator pump recirculates the contents of the solids holding tank to chop large size solids and keep the solids in suspension. All waste solids are pumped off the ship directly from the solids collection tank to shore approximately every four weeks. Contents of this mixture can include plastics and other prohibited compounds from such items as condoms. Bioreactor Feed System The screened filtrate is pumped directly from the collection tank to the two bioreactor tanks. The pumps operate when water in the collection tank is above the low-level set point and liquid in each bioreactor is below the high-level set point. The pumps shut off when the low-low level in the collection tanks or high-high levels in both bioreactors are reached. Bioreactors The bioreactors are converted potable water tanks. The ZeeWeed® membrane modules are contained in open-topped ‘tubs’ installed in the main bioreactor tanks, isolated from the main bioreactor volume by a vertical partition and horizontal floor which span the width of each bioreactor tank (Note: the tank modifications included the construction of a cofferdam to separate the bioreactor tank from the adjacent potable water tank). Organics (BOD5/COD) in the screened wastewater are bio-oxidized and converted to CO2, H2O and bio-cells in the bioreactors. Dissolved oxygen required for bio-oxidation is supplied by two aeration systems that consist of two air blowers and a fine bubble diffuser array installed in the bottom of each bioreactor. Recirculation pumps transfer the mixed liquor in the bioreactor to the two ZeeWeed membrane ‘tubs’ for solid-liquid separation; the mixed liquor then flows over the edge of the tub partition back into the main bioreactor volume. A portion of the mixed liquor volume (bioreactor waste) is periodically pumped to double bottom tank 3 port to limit the mixed liquor suspended solids concentration to approximately 10,000 to 15,000 mg/l. Liquid levels in the bioreactors are monitored and maintained at a constant liquid level by controlling the permeate (effluent) production rate. The permeate flow rate increases or decreases in proportion to corresponding changes in the mixed liquor level until the capped (pre-set) maximum or minimum permeate flow is reached. Alternatively, limiting the differential pressure measured through the membranes can be used to regulate production.

ZeeWeed® Membrane Ultrafiltration The cassettes are immersed in the tub assemblies contained within the bioreactor tanks, in direct contact with the mixed liquor. Through the use of a positive displacement pump, a vacuum is applied to the top headers of the membrane modules, which draws clean water (permeate) through the hollow fiber membranes while the solids rejected by the ZeeWeed membranes overflow back to the bioreactors. To minimize membrane fouling, air is introduced to the bottom of the membrane modules to scour the external surface of the hollow fibers and move the rejected solids away from the membrane surface. This airflow also provides a portion of the oxygen that is required for biological process. Bioreactor Waste Typically 10 to 15 m3/day solids concentrated and generated in the bioreactor mixed liquor are periodically pumped to double bottom tank 3 port by discharging a portion of the bioreactor contents. This concentrated effluent is than pumped overboard whenever the vessel is outside the 12-mile limit as established in compliance with MARPOL regulations and federal laws. UV Disinfection The permeate is subjected to a final polishing stage and is discharged through a UV disinfection unit to assure residual bacteria that may have penetrated the membrane system is killed. A high level of ‘kill’ efficiency is achieved given the extremely low turbidity of the permeate produced by the ZeeWeed membranes. System Operation Control The system is controlled via a PLC in either fully automatic mode or manual modes, which are accessed and manipulated via a Human Machine Interface (HMI). The HMI enables the operator to start and stop the system and make adjustments to the default settings that govern the system in various operation modes. EFFLUENT QUALITY The treated water is almost potable and would meet Environmental Protection Agency (EPA) drinking-water standards with the exception of a few parameters, most notably the total dissolved solids (TDS) and nitrate limits. The performance criteria for the ms Zaandam system did not require either parameter to be controlled, however, the process could be modified to

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reduce both to comply with EPA requirements if specified by a client. Holland America installed an onboard laboratory to monitor system performance via means of simple analytical methods. In addition, Holland America uses independent shore-based laboratories to periodically test preserved permeate samples to verify system operation and validate their own monitoring methods. The analyses routinely indicate the permeate has no detectable fecal coliform per 100 milliliters and no detectable suspended solids, surpassing the effluent requirements of a Type II MSD defined by Code of Federal Regulations 33 CFR 159. The Zaandam installation was issued U.S. Coast Guard certification as a Type II MSD (Certification No. 159.015/6500/0) although the system’s actual performance far exceeds Type II requirements. In the absence of any regulations governing the operation and performance of MSDs designed to process graywater, or combined gray and blackwater, Type II certification was considered to be

the best existing match for the ZENON system’s capabilities. Machinery Arrangement The installation centers on the existing potable water tank, which was converted to the combination bioreactor/ZeeWeed process tank. Fresh Water Tank N.51 Port, with an original capacity of 119,142 gallons (451 cubic meters), was divided longitudinally in two equal portions to accommodate the individual process trains. A steel partition divided the two sections; a cofferdam was also installed along the inboard side of the converted tank to isolate the new bioreactor from the adjacent fresh water tank N.51 Center. A steel tub was fabricated in the aft end of each bioreactor volume to contain the ZeeWeed membranes; this isolation was required to facilitate chemical soak cleaning of the membranes without resorting to draining the entire bioreactor volume.

Figure 5. – ZENON Immersed Membrane Bioreactor General Arrangement The membranes are installed and accessed for maintenance through watertight doors installed on the bioreactor aft bulkhead. A fine bubble diffuser grid was installed in the bottom of each bioreactor; the grid provides the air required to support the

biological processes. The cassettes are supported by upper and lower steel rails; the cassettes are installed by positioning them by the watertight doors, hoisting them up to the level of the rails, pushed into location and secured with bolts; Figure 6 illustrates the diffuser grid

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and membrane module installations. Although the ZeeWeed tub volume constitutes a portion of the total bioreactor volume, there was no need to install a diffuser grid as the membrane modules feature coarse bubble diffusers, which provide air to facilitate ZeeWeed operation. Operating in two separate

trains, mixed liquor is recirculated between the tubs and the main bioreactor volumes by pumps to assure the solids stay in suspension and are well mixed; the liquor is pumped from the bioreactors to the tubs, then overflows from the tubs back to the bioreactors.

Figure 6. – Bioreactor Fine Bubble Diffuser Grid Membrane Modules Installations All process equipment, with the exception of the four blowers, was installed in the machinery space immediately aft of the bioreactor. The blowers were installed in the space outboard of the bioreactor on the

port side, primarily to accommodate their large size, but also to provide a measure of noise isolation (sound attenuating enclosures will be installed on all future installations).

Figure 7. – Process Equipment and Membrane Module Access Watertight Doors All system functions are controlled by the operator by a Human Machine Interface (HMI) located on the main electrical and motor control center panel. The operator may regulate permeate production of each train separately by setting the production flow rate or limiting the differential transmembrane pressure (TMP)

applied to the membranes. The HMI displays all critical system parameters, including instantaneous flow, TMP, pH, mixed liquor temperature and total dissolved solids (TDS) concentration, and permeate turbidity. The system will also record total daily permeate production.

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Figure 8. – Human Machine Interface Control Panel ONBOARD LABORATORY AND SYSTEM STARTUP

In addition to monitoring system performance and parameters through the HMI, the system operator performs daily manual measurements. The data is sent to ZENON daily for the first six to eight weeks of operation, the biological seeding and start-up period, then weekly thereafter, allowing ZENON to provide on-going support to operators as they rotate through their postings to the ship. Monitoring through the start-up period is critical to assure the bacteria grow at a desired rate and become acclimatized to the influent characteristics of the blackwater and graywater streams. The bacteria may be added either as commercially available seed or return activated sludge (RAS) collected from a shore based municipal wastewater treatment plant. Manual testing and monitoring is performed only where on-line methods either don’t exist or are considered unreliable. The tests performed include:

• Dissolved Oxygen (DO) measurements in the bioreactor mixed liquor, to assure sufficient oxygen is delivered to the bacteria via the fine bubble diffuser grids;

• Chemical Oxygen Demand (COD) in both the mixed liquor and the permeate, to assure the

effluent quality is within acceptable limits by inferring the Biological Oxygen Demand (BOD) based on the COD measurement (BOD measurements must be performed by professional laboratories; samples are periodically collected and preserved for later analysis; • Total Solids (TS), Total Dissolved Solids (TDS) and Total Suspended Solids (TSS) measurements to determine the concentration of bacteria and biological solids in the mixed liquor, and;

• Ammonia measurement to determine the quality of the nutrients supplied to the bacteria from the influent streams.

In addition, a simple 30-minute settling test is performed on samples of mixed liquor collected from each bioreactor to provide a quick qualitative means of estimating TSS. Over time, a correlation between the settling tests and direct TSS measurements can be established such that the TSS tests need only be performed on a weekly basis. The TSS test requires several hours to complete as the mixed liquor samples must be baked to dehydrate the solids prior to weighing them. Weighing the samples using a laboratory balance can also be difficult due to the rolling and pitching motion of the ship in rough seas.

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Figure 9. – Onboard Test Laboratory

CONCLUSIONS The Holland America Line Westours sewage and graywater waste management system onboard the ms Zaandam was found to far exceed the International and U.S. Regulations and industry standard marine practice. Additional ZENON bioreactor ultrafiltration systems retrofitted to the fleet operating in Alaska ensure compliance with the recently enacted Murkowski legislation. Four newbuildings currently under construction will be outfitted with similar systems. A commitment has been made by Holland America Management to raise the traditional bar of operation, maintenance and performance of the MSD that has been traditionally installed on vessels. This radically new and different waste treatment system approach requires minimal maintenance and attention and has proved very reliable. This leadership role is enhanced with the addition of a new environmental engineer position to aid in enhancing operation of all pollution prevention equipment onboard each vessel. Holland America has taken the extra step to review all chemicals used onboard and standardize to compatible cleaning agents, environmentally compatible solvents and eliminated all products that could create foaming or disrupt the biological ecosystem necessary for the bacteria to survive and flourish. Operation procedures for each waste stream such as galley cooking oil have been developed to ensure correct handling and disposal. Further recognition was recently given by the USCG in awarding Holland America Line Westours QUALSHIP 21 designation for on-board safety, environmental and health regulation compliance. Holland America Line Westours is to be commended for this high level of compliance and the waste management equipment, procedures and internal reporting in excess of the regulations. Of particular note is the investment in

additional onboard Environmental Engineers and the next generation of combined sewage/graywater treatment plants that help promote clean water operations. Holland America is now exploring additional steps in improving operations including reuse onboard of the ZENON permeate as non-potable technical water for service in the laundry and engine room. Another possible area of conservation is the technology to dry the sludge for incineration. As the question of detrimental invasive species in ballast water comes to the environmental forefront, feasibility of using the 600 tons per day of clean permeate for ballast looks promising. This may be the ultimate clean and environmentally sound solution to the often dangerous regulations to exchange ballast water 200 miles out at sea, which is also impractical due to routing. Due to the double duty served, systems such as ZENON could be an effective alternative to the added space, weight and cost of ballast water treatment plants. This commitment by Holland America to follow each and every waste stream to finality is an example that would go a long way to protect the marine environment, if everyone in the marine industry would follow their lead.

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REFERENCES

1. Dixon, Doug “Enhanced MARPOL Oil Pollution

Prevention - Holland America Line Case Study” SNAME Pacific Northwest Section Meeting,

March 17, 2000 2. Dixon, Doug and Hughes, Greg “Coastal Cruise

Ship Waste Management” SNAME Joint California Sections Meeting, May 13, 1999

3. Bonomo, Frank “Questionnaire on Annex IV of MARPOL 73/78” USCG Position Statement

4. USCG email on MARPOL IV Signing, Frank Bonomo to Doug Dixon, 9 January 2002

5. EPA Memorandum from Carol Ann Siciliano, Attorney, Water Division (LE-132W) to Ann Prezyna EPA Office of Regional Counsel Region X re: State’s (Washington State Department of Ecology) Authority to Prohibit the Discharge of Sewage and Graywater from Vessels, September 4, 1992

6. EPA “Cruise Ship White Paper” United States Environmental Protection Agency, August 22, 2000

7. ICCL “Cruise Industry Waste Management Practices and Procedures” International Council of Cruise Lines, May 14, 2001, Revised December 14, 2001

8. IRAC “Boating/Sewage Compliance Matrix” Interagency Regulatory Analysis Committee

9. GAO “Marine Pollution - Progress Made to Reduce Marine Pollution by Cruise Ships, but Important Issues Remain” United States General Accounting Office Report GAO/RCED-00-48, February 2000

10. EPA Oceans and Coastal Protection Division “Cruise Ship Plume Tracking Survey” July 30, 2001

11. Kim, Don K., P.E., M. Rosenblatt & Son “ICCL Cruise Ship Waste Dispersion Analysis - Report on the Analysis of Graywater Discharge ” September 14, 2000

12. Florida Department of Environmental Protection (FDEP) “MEMORANDUM OF UNDERSTANDING Florida-Caribbean Cruise Association (FCCA)” March 14, 2000.

13. IMO “International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 (MARPOL 73/78)” International Maritime Organization, consolidated edition 2002.

14. Peterson, Randall; Monti, Sandro; Kopser,

Christopher “Application of Membrane Bioreactor Technologies to Ship Gray and Black Water Treatment” Maritime Environment International Conference, Genoa, Italy, March 17, 2000

15. Bluewater Network “Petition to EPA to Address Cruise Ship Pollution”, March 17, 2000

16. International Maritime Organization (IMO) Web Site www.imo.org

17. International Council of Cruise Lines (ICCL) Web Site www.iccl.org

18. Alaska Department of Environmental Conservation (ADEC) Web Site www.state.ak.us/local/akpages/ENV.CONSERV/press/cruise/cruise.htm

19. North West CruiseShip Association (NWCA) Web Site www.alaskacruises.org

20. Environmental Protection Agency (EPA) Web Site Cruise Ship Discharges www.epa.gov/owow/oceans/cruise_ships

21. Holland America Line Environmental Policy Site www.hollandamerica.com/aboutus/policies/environmental.htm

22. U.S. Navy Shipboard Environmental Information Clearinghouse Web Site http://navyseic.dt.navy.mil/

23. EPA Web Site www.epa.gov/owow/oceans/vessel_sewage/vsdnozone.html No-Discharge Zone for Vessel Sewage