Department of Environmental Conservation Division of Water August 13, 2018 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): Page 1 of 2
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: CC: FROM: Karl Amylon, City Manager Lacey Simpson, Assistant City Manager Steve Corporon, Port and Harbors Director Daniel Berg, Acting Port & Harbors Director David Dixon, Port Operations Coordinator 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 edward.white@alaska.gov Albert Faure Environmental Engineer Associate Commercial Passenger Vessel Environmental Compliance Program 410 Willoughby Ave Suite 303 Juneau, AK 99811 907-465-5279 albert.faure@alaska.gov 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 Large 1 Commercial Passenger Vessel Discharge Status and Wastewater Treatment Annual Permitted to discharge in Skagway Docks discharge Passenger Passenger Crew Alaska in 2018 3 permitted? Vessel Operator Vessel Name Capacity 2 Voyages capacity 4 Capacity Wastewater Treatment System 6 Underway Stationary Railroad Ore Broadway 1 Carnival Cruise Lines Carnival Legend 2124 17 36,108 Unknown Triton Type MSTP9 No No No No No 2 Carnival Cruise Lines Carnival Splendor 3006 1 3,006 Unknown Unknown No No No No No 3 Celebrity Cruises Celebrity Infinity 2170 14 30,380 Unknown Zenon Zeeweed No No No No No 4 Celebrity Cruises Celebrity Millennium 2449 19 46,531 Unknown Hydroxyl CB-100 MSD No No No No No 5 Celebrity Cruises Celebrity Solstice 3148 18 56,664 Unknown Kruger WABAG MSD No No No No No 6 Crystal Crystal Symphony 975 4 3,900 Unknown Unknown No No No No No 7 Disney Disney Wonder 2834 16 45,344 920 Hamworthy MBR AWTS Yes No No No No 8 Holland America Amsterdam 1380 17 23,460 Unknown Hamworthy Super Trident MSD No No No No No 9 Holland America Eurodam 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 No 11 Holland America Noordam 1916 21 40,236 Unknown Rochem UF MSD No No No No No 12 Holland America Volendam 1432 21 30,072 647 Zenon AWTS Yes Yes Yes Yes Yes 13 Holland America Westerdam 1916 22 42,152 Unknown Unknown No No No No No 14 Holland America Zaandam 1432 10 14,320 647 Zenon AWTS Yes Yes Yes Yes Yes 15 Norwegian Cruise Line Norwegian Bliss 3500 17 59,500 1706 Scanship AWP 60 Type II AWTS Yes Yes Yes No No 16 Norwegian Cruise Line Norwegian Jewel 2376 18 42,768 1100 Scanship Type II AWTS Yes Yes Yes Yes Yes 17 Norwegian Cruise Line Norwegian Pearl 2394 22 52,668 1100 Scanship Type II AWTS Yes Yes Yes Yes Yes 18 Oceania Regatta 777 15 11,655 373 Triton Water MBR AWTS Yes Yes Yes Yes Yes 19 Ponant Le Boreal 264 1 264 136 Rochem Bio-filt AWTS No No No No No 20 Ponant Le Soleal 264 2 528 136 Rochem Bio-filt AWTS Yes Yes Yes Yes Yes 5 21 Princess Cruise Line Coral Princess 1986 18 35,748 900 Hamworthy MBR AWTS Yes No No No No 22 Princess Cruise Line Emerald Princess 3084 17 52,428 1127 DeNora Ozone AWWTP- Graywater Only Yes Yes - Graywater only No No No 23 Princess Cruise Line Golden Princess 2606 17 44,302 1060 Hamworthy MBR AWTS Yes Yes - Graywater only Yes No No 24 Princess Cruise Line Grand Princess 2606 14 36,484 1100 Hamworthy MBR 16 AWTS Yes Yes - Graywater only Yes No No 25 Princess Cruise Line Island Princess 1974 20 39,480 900 Hamworthy MBR AWTS Yes No No No No 26 Princess Cruise Line Ruby Princess 3084 21 64,764 1201 Hamworthy MBR 16 AWTS Yes Yes - Graywater only No No No 27 Princess Cruise Line Star Princess 2600 19 49,400 1150 Hamworthy MBR AWTS Yes Yes - Graywater only No No No 28 Regent Seven Seas Seven Seas Mariner 769 17 13,073 431 Hamworthy MBR 240C AWTS Yes No No No No 29 Royal Caribbean Cruises Explorer of the Seas 4000 17 68,000 Unknown Two Scanship Mussel FA45 No No No No No 30 Royal Caribbean Cruises Radiance of the Seas 2502 17 42,534 Unknown Hamann MSD No No No No No 31 Seabourn Sojourn 450 11 4,950 338 2 Hamworthy MBR AWTS Yes Yes Yes Yes No 32 Silver Seas Silver Shadow 435 18 7,830 305 Bio Epure/Marisan AWTS Yes No No No No Totals 502 1,084,895 MBR is a Membrane Bioreactor Vessels highlighted in gray in the above table did not discharge wastewater in Alaskan waters in 2018. 1 A large vessel has overnight accommodations for 250 or more passengers. 2 Capacity 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 voyage 5 Discharge at Broadway Dock allowed unless another ship is discharging at the Ore Dock 6 Nondischarging vessels are not required to provide crew or treatment system information.