Department of Environmental Conservation Division of Water August 13, 2018 Page 1 of 2 2018 – Cruise ship discharge complaints ISSUE Public complaints and concern regarding cruise ship discharges in summer of 2018. Many of these reported discharges resemble exhaust gas cleaning system (scrubber) discharges. Scrubbers are used to remove sulfur from cruise ship air emissions and have recently been installed on large cruise ships. COMPLAINTS AND OBSERVATIONS ON CRUISE SHIP DISCHARGES Exhaust gas scrubber discharges Ocean Ranger observations: Open loop scrubber discharges have increased in 2018 as more scrubbers are being used and more washwater is pumped to meet EPA pH requirements. Ocean Rangers have observed foam, sheens, residues, and discoloration from the discharges. These observations have occurred throughout the cruise ship season. The discharges are large enough to be very visible from docks. The public could confuse these discharges for other wastewater discharges. Some ships are installing filter systems to reduce potential materials from discharge while they are in port. July Ketchikan Facebook discharge video: A video on Facebook in July showed a high volume discharge with bubbles and some foam, the discharge matched Ocean Ranger scrubber discharge observations. Ketchikan public questions: CPVEC (cruise ship) program responded to the City of Ketchikan regarding concern raised at a council meeting. This may have been due to the video on Facebook. The Ketchikan response memo is attached. The program also responded to a public complaint July 24, and responded to a question from Rep. Ortiz on July 25. Ketchikan Harbor office complaints: The Ketchikan harbor office notified CPVEC of a discharge with brown foam and oily appearance from the Golden Princess on July 19. Harbor staff talked to the ship and determined it was from an exhaust gas scrubber, the ship stopped use of the scrubber to stop discharging. Several operators have stopped discharges towards shore while in Ketchikan. Foam compliant Stephens Passage July 31: The CPVEC program received a compliant of a large amount of foam seen from a fishing boat the night of July 31 north of Petersburg. A video resembling the compliant latter appeared on Facebook. CPVEC staff checked vessel tracking, no large cruise ships were in the area at the time or within 12 hours prior to the compliant. BACKGROUND Cruise ship wastewater permitting: Under current state and federal statue authorities the CPVEC Program only issues permits for treated sewage and graywater (water from sinks, laundry, kitchens). The Department issues a general permit for large cruise ships, the current permit was issued in 2014. The current permit includes a mixing zone for metals and ammonia, but requires that bacteria and other indicators such as solids are met at the end of pipe. Large cruise ships are required to have Advanced Wastewater Treatment Systems onboard to remove almost all solids and disinfect wastewater prior to discharge. Exhaust Gas Scrubber Cleaning Systems (EGCS):
Transcript
Department of Environmental Conservation Division of Water
August 13, 2018
Page 1 of 2
2018 – Cruise ship discharge complaints ISSUE Public complaints and concern regarding cruise ship discharges in summer of 2018. Many of these reported discharges resemble exhaust gas cleaning system (scrubber) discharges. Scrubbers are used to remove sulfur from cruise ship air emissions and have recently been installed on large cruise ships. COMPLAINTS AND OBSERVATIONS ON CRUISE SHIP DISCHARGES
Exhaust gas scrubber discharges Ocean Ranger observations: Open loop scrubber discharges have increased in 2018 as more scrubbers are being used and more washwater is pumped to meet EPA pH requirements. Ocean Rangers have observed foam, sheens, residues, and discoloration from the discharges. These observations have occurred throughout the cruise ship season. The discharges are large enough to be very visible from docks. The public could confuse these discharges for other wastewater discharges. Some ships are installing filter systems to reduce potential materials from discharge while they are in port.
July Ketchikan Facebook discharge video: A video on Facebook in July showed a high volume discharge with bubbles and some foam, the discharge matched Ocean Ranger scrubber discharge observations.
Ketchikan public questions: CPVEC (cruise ship) program responded to the City of Ketchikan regarding concern raised at a council meeting. This may have been due to the video on Facebook. The Ketchikan response memo is attached. The program also responded to a public complaint July 24, and responded to a question from Rep. Ortiz on July 25.
Ketchikan Harbor office complaints: The Ketchikan harbor office notified CPVEC of a discharge with brown foam and oily appearance from the Golden Princess on July 19. Harbor staff talked to the ship and determined it was from an exhaust gas scrubber, the ship stopped use of the scrubber to stop discharging. Several operators have stopped discharges towards shore while in Ketchikan.
Foam compliant Stephens Passage July 31: The CPVEC program received a compliant of a large amount of foam seen from a fishing boat the night of July 31 north of Petersburg. A video resembling the compliant latter appeared on Facebook. CPVEC staff checked vessel tracking, no large cruise ships were in the area at the time or within 12 hours prior to the compliant. BACKGROUND
Cruise ship wastewater permitting: Under current state and federal statue authorities the CPVEC Program only issues permits for treated sewage and graywater (water from sinks, laundry, kitchens). The Department issues a general permit for large cruise ships, the current permit was issued in 2014. The current permit includes a mixing zone for metals and ammonia, but requires that bacteria and other indicators such as solids are met at the end of pipe. Large cruise ships are required to have Advanced Wastewater Treatment Systems onboard to remove almost all solids and disinfect wastewater prior to discharge.
Exhaust Gas Scrubber Cleaning Systems (EGCS):
PUBLIC WORKS / ENGINEERING DEPARTMENT CITY OF KETCHIKAN Mark Hilson, P.E., Public Works Director Administrative Offices Seth Brakke, P.E., Assistant Public Works Director PH: 907.228.4727 Kara Jurczak, P.E., Senior Project Engineer FAX: 907.225.8721
MEMORANDUM TO: Karl Amylon, City Manager CC: Lacey Simpson, Assistant City Manager Steve Corporon, Port and Harbors Director Daniel Berg, Acting Port & Harbors Director David Dixon, Port Operations Coordinator FROM: Mark Hilson, P.E., Public Works Director DATE: July 24, 2018 SUBJECT: Cruise Ship Discharges
At the July 19 regular City Council meeting, during the persons to be heard portion of the meeting, public comment was made by Ms. Jessica Miles regarding cruise ship discharges. It appears that the suspect discharges Ms. Miles was referring to are from exhaust gas scrubbers and not from wastewater (nor from greywater). Exhaust gas scrubbing is a relatively new installation that uses water to clean exhaust gas.
Discharges of this nature are permitted, but regulated by the United States Environmental Protection Agency (US EPA) through the administration of a Nationwide General Permit. While the Alaska Department of Environmental Conservation (ADEC) does not authorize the discharge, they do have other water quality standards relative to discharges that they may be able to enforce. Also, ADEC can take compliance actions based on the US EPA’s General Permit standards. And finally, the United States Coast Guard Marine Safety Detachment (USCG MSD) investigates and has authority to take various enforcement actions with regard to discharges that involve petroleum distillates (oily sheen). It is my understanding that the discharges that have been recently observed are not compliant with water quality standards of existing permits or regulations, and as such ADEC and USCG MSD are investigating.
In order to stop the discharges from occurring, staff has notified the cruise ship’s agent to cease the discharge, which resulted in a cooperative response that has ceased the discharge. We have also notified John Kimmel with Cruise Line Agencies of Alaska to cease all such non-compliant discharges while vessels are in port.
It is my understanding that ADEC is gathering information on this new exhaust gas scrubber discharge and working with the US EPA and the vessel operators in order to make permanent modifications to ensure compliant discharges. In the meantime, Port and Harbors staff will remain vigilant in looking out for discharges such as these, and when observed, documenting and notifying appropriate authorities as well as cruise ship agents as necessary.
Should the public observe continued discharges, ADEC is the regulatory agency with the most resources here in Alaska to deal with the issue:
ADEC Ed White Environmental Program Manager I Commercial Passenger Vessel Environmental Compliance Program 410 Willoughby Ave, Suite 303 Juneau, AK 99811 907-465-5138 [email protected] Albert Faure Environmental Engineer Associate Commercial Passenger Vessel Environmental Compliance Program 410 Willoughby Ave Suite 303 Juneau, AK 99811 907-465-5279 [email protected]
To report discharges with an oily sheen contact:
USCG MSD 1621 Tongass Ave Suite 202 907-225-4496
Attachment 2: Scrubber discharge examples
Alaska Department of Environmental Conservation
2018 Large1 Commercial Passenger Vessel Discharge Status and Wastewater Treatment
Underway Stationary Railroad Ore Broadway1 Carnival Cruise Lines 2124 17 36,108 Unknown Triton Type MSTP9 No No No No No2 Carnival Cruise Lines 3006 1 3,006 Unknown Unknown No No No No No3 Celebrity Cruises 2170 14 30,380 Unknown Zenon Zeeweed No No No No No4 Celebrity Cruises 2449 19 46,531 Unknown Hydroxyl CB-100 MSD No No No No No5 Celebrity Cruises 3148 18 56,664 Unknown Kruger WABAG MSD No No No No No6 Crystal 975 4 3,900 Unknown Unknown No No No No No7 Disney 2834 16 45,344 920 Hamworthy MBR AWTS Yes No No No No8 Holland America Amsterdam 1380 17 23,460 Unknown Hamworthy Super Trident MSD No No No No No9 Holland America 2106 20 42,120 929 2 Hamworthy MBR AWTS Yes No No No No
10 Holland America Nieuw Amsterdam 2106 21 44,226 929 2 Hamworthy MBR AWTS Yes No No No No11 Holland America 1916 21 40,236 Unknown Rochem UF MSD No No No No No12 Holland America 1432 21 30,072 647 Zenon AWTS Yes Yes Yes Yes Yes13 Holland America 1916 22 42,152 Unknown Unknown No No No No No14 Holland America 1432 10 14,320 647 Zenon AWTS Yes Yes Yes Yes Yes15 Norwegian Cruise Line 3500 17 59,500 1706 Scanship AWP 60 Type II AWTS Yes Yes Yes No No16 Norwegian Cruise Line 2376 18 42,768 1100 Scanship Type II AWTS Yes Yes Yes Yes Yes17 Norwegian Cruise Line Norwegian Pearl 2394 22 52,668 1100 Scanship Type II AWTS Yes Yes Yes Yes Yes18 Oceania 777 15 11,655 373 Triton Water MBR AWTS Yes Yes Yes Yes Yes19 Ponant 264 1 264 136 Rochem Bio-filt AWTS No No No No No20 Ponant 264 2 528 136 Rochem Bio-filt AWTS Yes Yes Yes Yes Yes5
21 Princess Cruise Line 1986 18 35,748 900 Hamworthy MBR AWTS Yes No No No No22 Princess Cruise Line 3084 17 52,428 1127 DeNora Ozone AWWTP- Graywater Only Yes Yes - Graywater only No No No23 Princess Cruise Line Golden Princess 2606 17 44,302 1060 Hamworthy MBR AWTS Yes Yes - Graywater only Yes No No24 Princess Cruise Line 2606 14 36,484 1100 Hamworthy MBR 16 AWTS Yes Yes - Graywater only Yes No No25 Princess Cruise Line 1974 20 39,480 900 Hamworthy MBR AWTS Yes No No No No26 Princess Cruise Line Ruby Princess 3084 21 64,764 1201 Hamworthy MBR 16 AWTS Yes Yes - Graywater only No No No27 Princess Cruise Line 2600 19 49,400 1150 Hamworthy MBR AWTS Yes Yes - Graywater only No No No28 Regent Seven Seas 769 17 13,073 431 Hamworthy MBR 240C AWTS Yes No No No No29 Royal Caribbean Cruises 4000 17 68,000 Unknown Two Scanship Mussel FA45 No No No No No30 Royal Caribbean Cruises 2502 17 42,534 Unknown Hamann MSD No No No No No31 Seabourn 450 11 4,950 338 2 Hamworthy MBR AWTS Yes Yes Yes Yes No32 Silver Seas 435 18 7,830 305 Bio Epure/Marisan AWTS Yes No No No No
Totals 502 1,084,895MBR is a Membrane Bioreactor
Vessels highlighted in gray in the above table did not discharge wastewater in Alaskan waters in 2018.1A large vessel has overnight accommodations for 250 or more passengers. 2Capacity is the number of lower berths and is calculated from Registration, Vessel Specific Sampling Plan, or Notice of Intent. Actual number of passenger aboard varies.3 Alaska water includes the Alexander Archipelago and extends 3 miles from the coastline. Only vessels that discharge into Alaska waters are required to sample for wastewater. 4 Assumes full capacity on every voyage5 Discharge at Broadway Dock allowed unless another ship is discharging at the Ore Dock6 Nondischarging vessels are not required to provide crew or treatment system information.
Silver Shadow
Radiance of the Seas
Volendam
Zaandam
Emerald Princess
Grand Princess
RegattaLe Boreal
Coral Princess
Explorer of the SeasSeven Seas Mariner
Island Princess
Sojourn
Westerdam
Le Soleal
Star Princess
Norwegian Jewel
Vessel Operator Vessel NamePassenger Capacity 2 Wastewater Treatment System 6Voyages
