Memorandum of Understanding
Cruise Operations in
Washington State
Originally signed April 20, 2004
Amendment No. 4 dated May 19, 2008

Washington State Department of Ecology
Northwest Cruise Ship Association
Port of Seattle

MEMORANDUM OF UNDERSTANDING 

This Memorandum of Understanding, originally signed on April 20, 2004 is amended by
and between the State of Washington, the Port of Seattle, and the Northwest Cruise Ship
Association, hereinafter referred to as NWCA, representing the international cruise lines
identified in Appendix i.
Whereas the State of Washington is charged with the responsibility of protecting and
conserving Washington's environmental resources in relation to the Cruise Industry's
environmental practices in Washington; and
Whereas the United States Coast Guard, herein referred to as USCG, has Federal
jurisdiction over environmental matters in navigable waters in the United States; and
Whereas the Port of Seattle is charged with providing the services and facilities to
accommodate the transportation of passengers, including cruise ship passengers, while protecting
and enhancing the environment of the Port of Seattle; and
Whereas, the NWCA is a non-profit entity organized for the purpose of representing
member cruise lines which operate in and about waters subject to this Memorandum of
Understanding (MOU), whose current membership is identified in Appendix i; and
Whereas, the NWCA has adopted the "Cruise Industry Waste Management Practices
and Procedures" as promulgated by the Cruise Industry's trade association, the Cruise Lines
International Association, herein referred to as CLIA, which practices and procedures are
attached hereto as Appendix ii; and
Whereas, NWCA cruise vessels operate in international waters and move passengers to
destinations worldwide and, consequently, those cruise vessel waste management practices must
take into account environmental laws and regulations in many jurisdictions and international
treaties and conventions; and
Whereas, the NWCA, the State of Washington as represented by the Washington
Department of Ecology (Ecology), the USCG and the Port of Seattle have met to develop waste
management practices that preserve a clean and healthy environment and demonstrate the Cruise
Industry's commitment to be a steward of the environment; and
Whereas, research is ongoing to establish the impact of ships' wastewater discharges on
the ocean environment, and the results of this research will be taken into account in periodic
review of the wastewater discharge practices described in this Agreement; and
Whereas, the cruise industry recognizes Washington's fragile marine environment and is
committed to help protect this environment;

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Now therefore, based upon mutual understanding, the parties enter into this
Memorandum of Understanding to implement the following environmental goals, policies and
practices:
Definition of terms for the purpose of this agreement:
"blackwater" means waste from toilets, urinals, medical sinks and other similar facilities;
"cruise ship" means any vessel that is owned or operated by a member of the NWCA;
"disinfection system upset" means disinfection below levels of four log (99.99%) inactivation of
norovirus based on expected results assuming a minimum intensity of ultraviolet (UV) lights
used for disinfecting effluent or other shipboard administrative controls as may be accepted by
the Washington Department of Health..
"graywater" includes drainage from dishwasher, shower, laundry, bath, galley drains and
washbasin drains;
"monitoring for disinfection effectiveness" means using measuring equipment to determine the
intensity of ultraviolet (UV) lights used for disinfecting effluent, or other shipboard
administrative controls as may be accepted by the Washington Department of Health.
"oily bilge water" includes bilge water that contains used lubrication oils, oil sludge and slops,
fuel and oil sludge, used oil, used fuel and fuel filters, and oily waste.
"residual solids" includes grit or screenings, ash generated during the incineration of sewage
sludge and sewage sludge, which is solid, semi-solid, or liquid residue generated during the
treatment of domestic sewage in a treatment works. Sewage sludge includes, but is not limited
to, domestic septage; scum or solids removed in primary, secondary, or advanced wastewater
treatment processes; and a material derived from sewage sludge.
"solid waste" means all putrescible and nonputrescible solid and semisolid wastes including, but
not limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, demolition and
construction wastes and recyclable materials [RCW 70.95.030 (22), Solid Waste Management:
Reduction and Recycling].
"waters subject to this Memorandum of Understanding (MOU)" include the Puget Sound and the
Strait of Juan de Fuca south of the international boundary with Canada; and for off the west
coast, the belt of the seas measured from the line of ordinary low water along that portion of the
coast which is in direct contact with the open sea and the line marking the seaward limit of
inland waters, and extending seaward a distance of three miles as illustrated in Appendix iii.
1.  Applicability
1.1   The State of Washington agrees that the performance required by the NWCA under the
terms of this Memorandum of Understanding shall be directed only to its member cruise
lines. The NWCA acknowledges that its members operate cruise vessels engaged in
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cruise itineraries greater than one day duration; and further that its members do not
operate one-day attraction ships or casino gambling ships. This agreement only applies
to voyages during which the commercial passenger vessel actually calls at a port in the
State of Washington.
1.2   The State of Washington and Port of Seattle accepts the CLIA Industry Standard E-0l 
01, titled Cruise Industry Waste Management Practices and Procedures (Appendix ii)
as CLIA member policy in the management of solid waste, hazardous wastes and
wastewaters in waters subject to this MOU. In addition to the CLIA Practices, the
member vessels of NWCA operating in Washington agree to allow Ecology to conduct a
minimum of one vessel inspection per season to verify compliance with the MOU and
agree to comply with the following unique practices while operating in waters subject to
this MOU:
2.1   Wastewater Management
In recognition of the sensitive nature of Washington's marine environment, the NWCA
agrees to the following:
2.1.1  to prohibit the discharge of untreated blackwater, untreated graywater, and solid waste
within waters subject to this MOU (Appendix iii); and to prohibit the discharge of oily
bilge water if not in compliance with applicable federal and state laws within waters
subject to this MOU.
2.1.2  other than as set forth in section 2.1.3 below, to prohibit the discharge of treated
blackwater and treated graywater in waters subject to this MOU.
2.1.3  the discharge of treated blackwater and treated graywater from ships equipped with
advanced wastewater treatment systems (AWTS) which meet the higher standards and
the testing regime set out in federal law, Title XIV, Certain Alaska Cruise Ship
Operations, Section 1404 (c) (Appendix vi) is allowed under the following conditions:
A.   For discharges if the ship is at least one nautical mile away from its berth at a port
in Washington and is traveling at a speed of at least 6 knots:
1)   No later than 60 days prior to the date the cruise ship wishes to commence
discharge of AWTS-treated effluent, the cruise line shall submit the following
vessel specific information to Ecology
a.  Documentation on the type of treatment system in use on the ship
including schematic diagrams of the system.
b.  Documentation that the system is certified by the United States Coast
Guard for continuous discharge in Alaska. If the certification has not yet
been provided by the Coast Guard at the time the other documentation is
submitted to Ecology, it may be submitted less than 60 days prior to
commencement of discharge but in no event less than 30 days prior to the
commencement of discharge.
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c.  Provision for daily twenty-four hour continuous turbidity or equivalent
monitoring of the quality of the effluent generated by the AWTS and,
beginning in 2009, daily twenty-four hour continuous monitoring for
disinfection effectiveness.
d.  Documentation of system design that demonstrates the AWTS can be
automatically shut down if monitoring of treated effluent indicates high
turbidity or, beginning in 2009, a disinfection system upset; or
documentation that demonstrates that operational controls exist to insure
system shut down if monitoring of treated effluent indicates high turbidity
or, beginning in 2009, a disinfection system upset. An example of an
acceptable operational control is a system that has the continuous
monitoring device alarmed as to immediately alert engineering staff on
watch to shut down overboard discharges from the system in the event of
high turbidity levels or disinfection ineffectiveness in the treated effluent.
B.   For continuous discharge:
1)   No later than 60 days prior to the date a cruise ship wishes to commence
discharge of AWTS effluent, the cruise line shall submit the following vessel
specific information to Ecology:
a.  Documentation on the type of treatment system in use on the ship
including schematic diagrams of the system.
b.  Documentation that the system is certified by the United States Coast
Guard for continuous discharge in Alaska. If the certification has not yet
been provided by the Coast Guard at the time the other documentation is
submitted to Ecology, it may be submitted less than 60 days prior to
commencement of discharge but in no event less than 30 days prior to
commencement of discharge.
c.  Provision for daily twenty-four hour continuous turbidity or equivalent
monitoring of the quality of the effluent generated by the AWTS and,
beginning in 2009, daily twenty-four hour continuous monitoring for
disinfection effectiveness.
d.  Documentation of system design that demonstrates the AWTS can be
automatically shut down if monitoring of treated effluent indicates high
turbidity or, beginning in 2009, a disinfection system upset; or
documentation that demonstrates that operational controls exist to insure
system shut down if monitoring of treated effluent indicates high turbidity
or, beginning in 2009, a disinfection system upset. An example of an
acceptable operational control is a system that has the continuous
monitoring device alarmed as to immediately alert engineering staff on
watch to shut down overboard discharges from the system in the event of
high turbidity levels or disinfection ineffectiveness in the treated effluent.
e.  Documentation that all treated effluent will receive final polishing for
disinfection immediately prior to discharge.
f.  Copies of water quality tests results taken from the AWTS effluent during
the preceding six months.
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g.  A vessel specific plan that: identifies how effluent will be stored until the
AWTS is repaired and which indicates the storage capacity of holding
tanks; and includes a notification protocol for notifying Ecology of system
shut down which occurs while within waters subject to this MOU.
If Ecology determines that the documentation provided is insufficient, it shall so notify
the cruise line. The cruise line shall provide supplemental documentation as requested by
Ecology.  If Ecology and the cruise line are unable to agree on the supplemental
documentation and cruise line elects to discharge from the AWTS, cruise line
understands that any such discharge will not have been approved by Ecology and further
that Ecology may take appropriate action, including, but not limited to, publicizing, such
fact.
Any cruise ship discharging from an AWTS in waters subject to this MOU operates
within the shipping lanes and this effectively means that vessels are more than a half a
mile from shellfish beds with the possible exception of President's Point, Apple Tree
Cove and Tyee Shoal for the 2008 cruise season. For specific information relative to
shellfish protection measures, see appendix x.
C.   The vessels that have submitted documentation under A or B above agree to:
1)   Not discharge within 0.5 nautical miles of bivalve shellfish beds that are
recreationally harvested or commercially approved to harvest as identified
annually by the Department of Ecology. This season's locations include
President's Point, Apple Tree Cove and Tyee Shoal as referenced in Appendix
x.
2)   Immediately stop all discharges when high turbidity occurs and, beginning in
2009, when a disinfection system upset condition occurs.
3)   Immediately notify the Washington State Department of Health in the event of
a disinfection system upset at (360) 236-3330 during office hours or (360)
786-4183 after hours (24 hour pager). The agreement to provide this notice is
based on the understanding by NWCA that the Department of Health will not
publicize the information provided unless it reasonably determines that a
discharge presents a material public health risk.
4)   Sample the quality of the treated effluent using a Washington state-certified
laboratory at least one time per month while at port in Washington during
each cruise season using the sampling requirements established per the United
States Coast Guard, Captain of the Port, Southeast Alaska Policy for
conventional pollutants continued compliance monitoring regime and as
referenced in Appendix vi. Parameters sampled include pH, Biochemical
Oxygen Demand (BOD), Fecal Coliform, Total Suspended Solids (TSS), and
Residual Chlorine (RC).
5)   Meet the limitations on discharge as set in Alaska regulations (Appendix vi)
for BOD, TSS, pH, Fecal Coliform and Residual Chlorine.1
6)   Split samples with Ecology upon Ecology's request when sampling is
conducted in Washington waters.
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7)   For vessels that have submitted documentation under B above (continuous
discharge), conduct Whole Effluent Toxicity (WET) Testing once every two
years for vessels homeported2 in Washington and once every 40 port calls or
turnarounds to a port in Washington for all other vessels.
8)   Provide Ecology with duplicates of test results obtained for and provided to
the State of Alaska to enable Ecology to monitor the quality of the effluent
from such systems.
9)   Notify Ecology at least a week in advance of sampling and to allow Ecology
staff access to the ship in order to observe sampling events.
10)  Notify Ecology if any material changes are made to the system.
Note 1: There is a presumption that meeting Alaska's standards means that Washington's Water Quality Standards are likely being met and that if
Alaska's standards are not being met, Washington's Water Quality Standards are not being met.
Note 2: A "homeported" vessel is a vessel that makes a call or does a turnaround at a port in Washington at least 20 times per year.
2.1.4  The discharge of residual solids from either a type 2 marine sanitation device or an
advanced waste water treatment system is prohibited in waters subject to this MOU,
within 12 nautical miles from shore, and within the entire boundaries of the Olympic
Coast Marine Sanctuary. All parties acknowledge that most of the Olympic Coast
National Marine Sanctuary lies beyond 3 miles of shore and therefore is outside the
jurisdiction of the State of Washington.
2.2   Hazardous Waste Management
2.2.1  The CLIA in consultation with NWCA has developed, in conjunction with the
Environmental Protection Agency (EPA), a national practice for the assigning of an EPA
Identification Number to each cruise ship as the "generator" of hazardous wastes, which
recognizes the multi-jurisdictional itineraries of a cruise vessel. EPA also proposes that
the state where company offices are located may issue the national identification numbers
provided the criteria and information submitted required for obtaining the number is
standard for the United States. The State of Washington and NWCA agree to a uniform
application procedure for the EPA national identification number in accordance with the
Resource Conservation Recovery Act (RCRA) (Appendix v). The State of Washington
shall have the right to inspect all such records upon written request to the cruise vessel
operator. The State of Washington recognizes that in some cases EPA Identification
Numbers may not be required under federal law for conditionally exempt small quantity
generators.
2.2.2  Appendix ii includes the uniform procedure adopted by the NWCA for the application of
RCRA to cruise vessels disposing of hazardous wastes in the State of Washington. The
State of Washington accepts this procedure as the appropriate process for vendor
selection and management of hazardous wastes in Washington. NWCA member lines
agree to provide an annual report regarding the total hazardous waste offloaded in
Washington by each cruise vessel.
2.2.3  The NWCA acknowledges that the state of Washington regulates some hazardous wastes
differently than EPA and agrees, within the waters subject to this MOU, to comply with
the guidelines for specific waste streams found in Appendix vii.
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2.2.4  The State of Washington and NWCA agree that all hazardous waste disposal records
required by RCRA for cruise vessels entering a Washington port shall be available to the
State of Washington upon written request to the cruise vessel operator.
3.    The State of Washington and the NWCA understand that the U.S. Coast Guard (USCG)
has Federal jurisdiction over environmental matters in navigable waterways in the United
States and conducts passenger ship examinations that include review of environmental
systems, Safety Management System (SMS) documentation and such MARPOL-
mandated documents as the Oil Record Book and the Garbage Record Book.
Additionally, NWCA member cruise vessels will integrate such industry standards into
SMS documentation that ensure compliance through statutorily required internal and
third party audits.
4.    The USCG has developed guidelines relating to the inspection of waste management
practices and procedures, which have been adopted by the cruise industry. The State of
Washington accepts the USCG Navigation and Vessel Inspection Circular and
Environmental Systems Checklist (Appendix iv), which will be incorporated into USCG
840 Guidebook as the procedure to conduct waste management inspections on board
cruise vessels. To reduce administrative burden on the cruise ship industry, the State of
Washington agrees to first request from the USCG any records for cruise vessels entering
waters subject to this MOU to the extent that those records are covered by the
Memorandum of Agreement, dated May 25th, 2001, between the State of Washington
Department of Ecology and the USCG. Other USCG records will be provided to the
State directly by the NWCA member lines upon request.
5.    The State of Washington recognizes that waste management practices are undergoing
constant assessment and evaluation by cruise industry members. It is understood by the
State of Washington and the NWCA that the management of waste streams will be an ongoing
process, which has as its stated objectives both waste minimization and pollution
prevention. Consequently, all parties agree to continue to work with each other in good
faith to achieve the stated objectives. This may require additional meetings with the
parties to this Agreement to discuss specific issues applicable to the cruise industry in the
U.S.
6.    The NWCA acknowledges that its operating practices are required to comply with the
applicable provisions of the Marine Mammal Protection Act, the Invasive Species Act
and the State of Washington Ballast Water Management law, RCW Ch. 77.120. The
NWCA agrees to acknowledge and comply with appropriate rules and regulations related
to the Olympic Coast National Marine Sanctuary, including but not limited to the
regulations for implementing the National Marine Sanctuary Program (subparts A
through E and subpart O of Title 15, Chapter IX, Part 922 of the Code of Federal
Regulations) and the International Maritime Organization (IMO) "Area To Be Avoided"
off the Washington Coast.
7.    This agreement does not prohibit discharges made for the purpose of securing the vessel
or saving life at sea, provided that all reasonable precautions have been taken for the
purpose of preventing or minimizing the discharge.
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8.    All parties acknowledge that ongoing discussions of environmental goals are recognized
as a necessary component to the successful implementation of management practices for
waste minimization and reduction.
9.     Compliance, Modification and Review of MOU: NWCA members agree to immediately
self-report non-compliance with any provision of this MOU to the Department of
Ecology at the following 24-hour number: 425-649-7000. By December 1st of each year,
a report shall be submitted to the Department of Ecology detailing the compliance with
this MOU for each vessel within the NWCA that calls to a port in Washington for the
previous cruise season. The reports should follow the format included in Appendix viii.
All parties acknowledge that this MOU is not inclusive of all issues, rules or programs
that may arise in the future. The State of Washington reserves the right to enter into
additional MOUs to address or refine such issues, to take enforcement action in response
to violations of state law, or to pursue appropriate legislation. All parties agree to at least
one annual meeting to review the effectiveness of the MOU, such meeting to be
scheduled, if feasible, during October of each year. The State of Washington and NWCA
reserve the right to cancel this MOU upon 90 days written notice.
10.    The Port of Seattle and Ecology entered into an interagency agreement for the purpose of
providing funding for Ecology personnel to further the intent of the MOU. The Port of
Seattle is acting solely as a pass-through contracting entity to facilitate the collection of
funds from the individual NWCA members to provide payment to Ecology on behalf of
the NWCA members. The interagency agreement as included in Appendix ix may be
amended or renewed separately from this MOU at any time by the parties of the
agreement without amending the MOU.
Appendix xi includes a summary of amendments.








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Memorandum of Understanding 
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APPENDICES
MEMORANDUM OF UNDERSTANDING 

Appendix i   List of NWCA Member Lines 
Appendix ii   CLIA Standards
Appendix iii  Navigational Chart of the waters subject to this MOU
Appendix iv  USCG Navigation & Vessel Inspection Circular and Environmental Systems
Checklist
Appendix v  Uniform application procedure for EPA National ID Number as per Resource
Conservation Recovery Act.
Appendix vi  Alaska Regulations
Appendix vii  Washington Hazardous Waste Management Best Management Practices
Appendix viii Boilerplate Compliance Letter
Appendix ix  Interagency Agreement (cost-recovery)
Appendix x  Bivalve Shellfish Beds 
Appendix xi  Summary of Amendments

Appendix i
List of NWCA Member Lines
Carnival Cruise Lines
Celebrity Cruises
Crystal Cruises
Holland America Line
Norwegian Cruise Lines
Princess Cruises
Regent Seven Seas
Royal Caribbean Cruises
Silversea Cruises

Appendix ii
CLIA INDUSTRY STANDARD
CRUISE INDUSTRY
WASTE MANAGEMENT
PRACTICES AND PROCEDURES
The members of the Cruise Lines International Association (CLIA) are dedicated to
preserving the marine environment and in particular the pristine condition of the oceans and other
waters upon which our vessels sail. The environmental standards that apply to our industry are
stringent and comprehensive. Through the International Maritime Organization, the United States
and flag and port states, CLIA has developed consistent and uniform international standards that
apply to all vessels engaged in international commerce. These standards are set forth in the
International Convention for the Prevention of Pollution from Ships (MARPOL). The international
standards of MARPOL have in turn been adopted by the United States and augmented by
additional national legislation and regulation. The U.S. has jurisdiction over both foreign and
domestic vessels that operate in U.S. waters where U.S. laws, such as the Federal Water Pollution
Control Act, the Act to Prevent Pollution from Ships, the Ports and Waterways Safety Act, and the
Resource Conservation and Recovery Act - which applies to hazardous waste as it is landed ashore
for disposal, apply. The U.S. Coast Guard enforces both international conventions and domestic
laws.
The cruise industry commitment to protecting the environment is demonstrated by the
comprehensive spectrum of waste management technologies and procedures employed on its
vessels.
CLIA members are committed to:
a.  Designing, constructing and operating vessels, so as to minimize their impact on the
environment;
b.  Developing improved technologies to exceed current requirements for protection of the
environment;
c.  Implementing a policy goal of zero discharge of MARPOL, Annex V solid waste
products (garbage) and equivalent US laws and regulations by use of more
comprehensive waste minimization procedures to significantly reduce shipboard
generated waste;
d.  Expanding waste reduction strategies to include reuse and recycling to the maximum
extent possible so as to land ashore even smaller quantities of waste products;
e.  Improving processes and procedures for collection and transfer of hazardous waste;
and

f.   Strengthening  comprehensive  programs  for  monitoring  and  auditing  of  onboard
environmental practices and procedures in accordance with the International Safety
Management Code for the Safe Operation of Ships and for Pollution Prevention (ISM
Code).
INDUSTRY WASTE MANAGEMENT STANDARDS: CLIA member cruise vessel operators have
agreed to incorporate the following standards for waste stream management into their respective
Safety Management Systems.
1.  Photo Processing, Including X-Ray Development Fluid Waste:  Member lines have
agreed to minimize the discharge of silver into the marine environment through the use of
best available technology that will reduce the silver content of the waste stream below levels
specified by prevailing regulations. 
2.  Dry-cleaning waste fluids and contaminated materials:  Member lines have agreed to 
prevent the discharge of chlorinated dry-cleaning fluids, sludge, contaminated filter
materials and other dry-cleaning waste byproducts into the environment
3.  Print Shop Waste Fluids:  Member lines have agreed to prevent the discharge of
hazardous wastes from printing materials (inks) and cleaning chemicals into the
environment. 
4.  Photo Copying and Laser Printer Cartridges:  Member lines have agreed to initiate
procedures so as to maximize the return of photo copying and laser printer cartridges for
recycling. In any event, these cartridges will be landed ashore. 
5.  Unused And Outdated Pharmaceuticals:  Member lines have agreed to ensure that
unused and/or outdated pharmaceuticals are effectively and safely disposed of in
accordance with legal and environmental requirements. 
6.  Fluorescent And Mercury Vapor Lamp Bulbs: Member lines have agreed to prevent the
release of mercury into the environment from spent fluorescent and mercury vapor lamps
by assuring proper recycling or by using other acceptable means of disposal. 
7.  Batteries: Member lines have agreed to prevent the discharge of spent batteries into the
marine environment. 
8.  Bilge and Oily Water Residues:  Member lines have agreed to meet or exceed the
international requirements for removing oil from bilge and wastewater prior to discharge.
9.  Glass, Cardboard, Aluminum and Steel Cans: Member lines have agreed to eliminate, to
the maximum extent possible, the disposal of MARPOL Annex V wastes into the marine
environment. This will be achieved through improved reuse and recycling opportunities.
They have further agreed that no waste will be discharged into the marine environment
unless it has been properly processed and can be discharged in accordance with MARPOL
and other prevailing requirements. 

10. Incinerator Ash: Member lines have agreed to reduce the production of incinerator ash
by minimizing the generation of waste and maximizing recycling opportunities.

11. Graywater: [ For ships traveling regularly on itineraries beyond the territorial waters of
coastal states], member lines have agreed that graywater will be discharged only while the
ship is underway and proceeding at a speed of not less than 6 knots1; that graywater will
not be discharged in port and will not be discharged within 4 nautical miles from shore or
such other distance as agreed to with authorities having jurisdiction or provided for by
local law except in an emergency, or where geographically limited. Member lines have
further agreed that the discharge of graywater will comply with all applicable laws and
regulations. For vessels whose itineraries are fully within US territorial waters, discharge
shall comply fully with U.S. and individual state legislation and regulations. 
12. Blackwater: CLIA members have agreed that all blackwater will be processed through a
Marine Sanitation Device (MSD), certified in accordance with U.S. or international
regulations, prior to discharge.   For ships traveling regularly on itineraries beyond
territorial coastal waters, discharge will take place only when the ship is more than 4 miles
from shore and when the ship is traveling at a speed of not less than 6 knots.1 For vessels
whose itineraries are fully within US territorial waters, discharge shall comply fully with
U.S. and individual state legislation and regulations. 
Some member cruise lines are field-testing wastewater treatment systems that utilize
advanced technologies. These onboard wastewater treatment systems, which are currently being
referred to as advanced wastewater purification (AWP) systems, are designed to result in effluent
discharges that are of a high quality and purity; for example, meeting or surpassing secondary and
tertiary effluents and reclaimed water.  Effluents meeting these high standards would not be
subjected to the strict discharge limitations previously discussed.
Each CLIA cruise vessel operator has agreed to utilize one or more of the practices and
procedures contained in the attached "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
CLIA 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 blackwater 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.
CLIA and its Environmental Committee will continue to work with the U.S. Coast Guard,
the U.S. Environmental Protection Agency and other appropriate agencies to further implement
the above commitments. 
1 
For vessels operating under sail, or a combination of sail and motor propulsion, the speed shall not be less
than 4 knots. 
ATTACHMENT: CRUISE INDUSTRY WASTE MANAGEMENT PRACTICES AND PROCEDURES
Revised: November 12, 2006
Effective for non-prior ICCL members:July 1, 2007

Appendix ii (cont.)

Discussion

Just as on shore. ship operations and passengers generate waste as part of many daily
activities.  On ships. waste is generated while underway and in port.  Because ships rrrove. the
management of these wastes becomes more complicated than for land-based activities. as the
facilities and laws change with the location of the ship.  Facilities on the ships as well as
management practices must be designed to take into account errvirornrrerrtal laws and regulations
arormd the world and the various local and state laws and regulations. Moreover. because waste
management ultimately becomes a local activity. the local port infrastructru'e. service providers.
and local waste disposal vendors are factors in the decisiorr-rrraking processes.

On an international level.  envirornnerrtal processes  are an important part of the
International Maritime Organization's (IMO's) policies and procedtu'es for the maritime industry.
CLIA member lines have agreed to incorporate errvirormrerrtal performance into Safety
Management Systems (SMS) and MARPOL mandated Waste Management Manuals.  Under
agreements and laws specic to many nations. these programs are routinely reviewed by Port
States to ensure compliance.  For example. in the United States. the US Coast Guard has
jurisdiction over envirormrental matters in ports and waterways and conducts passenger ship
examinations that include review of environmental systems. SMS documentation and such
MARPOL-mandated documents as the Oil Record Book and the Garbage Record Book. Within
the United States. envirornnental laws and regulations apply include the Clean Water Act. the
Refuse Disposal Act. the Resource Conservation and Recovery Act. The Clean Air Act. the Oil
Pollution Act of 1990. and the Pollution Prevention Act. to name a few. which apply to all ships
within US. waters.

The industry effort to develop waste management practices and procedures has focused
on the traditional high volume wastes (garbage. graywrater. blackwater. oily residues (sludge oil)
and bilge water). pollution prevention. and the small quantities of hazardous waste produced
orrboard.   In the process. CLLA members have shared waste management strategies and
teclmologies. while focusing on a corrnrrorr goal of waste reduction.

The process of waste reduction includes waste prevention. the purchasing of products that
have recycled content or produce less waste (e.g. source reduction). incineration. and recycling or
reuse of wastes that are generated. The ultimate goal is to have the waste management culture
absorbed into every facet of cruise vessel operation.  A fully integrated systenr beginning with
the design of the vessel should address envirornnental issues at every step.

Management practices for waste reduction should start before a product is selected. Eco-
purchasing and packaging are vital to the success of any envirornnental prograrrr. as are strategies
to change packaging. processes and management to optimize the resources used.

The commitment of the industry to this cooperative effort has been quite successful. as
companies have shared information and strategies.

Industry Standard Waste Handling Procedures

CLIA member lines have agreed that hazardous wastes and waste streams orrboard cruise
vessels will be identied and segregated for individual handling and management in accordance
with appropriate laws and regulations. They have further agreed. hazardous wastes will not be
discharged overboard. nor be cormnirrgled or mixed with other waste streams.

A.    Hazardous Waste Collection and Storage onboar'd Ship: CLIA member lines have
agreed that specific procedures for hazardous waste collection, storage and crew
training will be addressed in each ship '5 SMS or equivalent onboard instruction in the
Case ofUS registry vessels.

B.    Photo Processing: Including XRav Development Fluid Waste:  CLIA member
lines have agreed to eliminate the discharge of silver from these sources into the
marine environment through the use of best available technology that will reduce the
silver content of the waste sn'eam below levels specified by prevailing regulations or
by treating all photo processing and x-ray development uid waste (treated or
untreated) as a ha:ardous waste and landing ashore in accordance with RCRA
requirements.

There are several waste streams associated with photo processing operations that have the
potential to be regulated under the Resource Conservation and Recovery Act (RCRA). These
waste streams include spent xer. spent cartridges. expired lm and silver ake,

Photographic xer removes the unexposed silver compounds from the hn during the
developing process. The spent xer can have as much as 2000-3000 parts per million (ppm) of
silver.  Silver bearing waste is regulated by RCRA as a hazardous waste if the level of silver
exceeds 5 ppm as determined by the Toxicity Characteristic Leaching Procedure (TCLP) test.

Silver recovery units may be used to reclaim the silver from the used xer waste stream.
There are two types of recovery units. These are active (with electricity) and passive (without
electricity) units. The active rurit uses electricity to plate silver onto an electrode. The passive
unit uses a chemical reaction between steel wool and silver to remove rrrost of the silver from
solution.   Utilizing the best available technology. the equipment currently onboard CLIA
member cruise ships is conservatively estirrrated to reduce the silver content of this efuent below
4 mgu'l (milligrams/1 or ppm)

Handling Method 1 Emploved by Member Lines:

Treat used photographic and x-ray development uids to remove silver for recycling.

Verify that the efuent from the recovery unit is less than 5 parts per million (ppm) silver. as
measured by EPA-approved methodology.

After treatment. the residual waste stream uid is non-hazardous and landed ashore as industrial
waste.

Handling Method 2 Employed bv Member Lines:

Used photographic and x-ray development uids. either treated or untreated. may be assumed to
be a hazardous waste. In this event. they are landed ashore in accordance with the requirements
of the Resoru'ce Conservation and Recovery Act (RCRA).

C.    Drv-cleaniuo waste uids and contaminated materials: CLIA member lines have
agreed to prevent the discharge of chlorinated dry-cleaning uids, sludge,
contaminated lter materials and other dry-cleaning waste byproducts into the
environment.


Waste Management Practices and Procedures   Page 3

Shipboard dry cleaning facilities use a chlorinated solvent called perclrloretlrylerre (also
known as PERC or tetrachloroethylene) as a dry cleaning uid. This is the approved dry cleaning
solvent for these units. Operators nrust receive specic required training for the correct use of
this chemical and its associated precautions. This solvent should be used in accordance with all
safety procedures including appropriate personal protective equipment (PPE).

The dry cleaning units produce a small volume waste from condensate. the bottoms of the
internal recovery stills. waste products from button and lint traps. spent perclrloroethylene and
lter media. This waste is comprised of dirt. oils. lters material. and spent solvent. Each ship
utilizing these dry-cleaning units produces approximately two porurds of waste material weekly.
However. the amounts may vary greatly by season and passenger load. This material is classied
as hazardous waste under RCRA and must be disposed of accordingly.

Handling Method 1 Employed by Member Lines:

Perchloroethylene (PERC) and other chlorinated dry-cleaning uids. contaminated sludge and
lter materials are hazardous waste and landed ashore in accordance with the requirements of
RCRA.

C.    Print Shop Waste Fluids: CLL4 member lines have agreed to prevent the discharge
of hazardous wastes from printing materials (inks) and cleaning chemicals into the
environment.

Print shop waste may contain hazardous waste. Printing solvents. inks and cleaners all
may contain hydrocarbons. chlorinated hydrocarbons. and heary metals that can be harmful to
human and aquatic species. Recent advances in printing technology and substitution of chemicals
that are less hazardous reduces the volume of print shop waste generated and reduces the impact
of these waste products.

CLIA member lines have agreed to utilize. whenever possible. printing methods and
printing process chemicals that produce both less volume of waste and less hazardous waste
products. that shipboard printers will be trained in ways to minimize printing waste generated.
and that alternative printing inks such as soy based. non-chlorinated hydrocarbon based ink
products will be used whenever possible. The member lines have further agreed that all print
shop waste including waste solvents. cleaners. and cleaning cloths will be treated as hazardous
waste. if such waste contains chemical components that may be considered as hazardous by
regulatory denitions. and that all other waste may be treated as non-hazardous.

Handling Method 1 Ernploved by Member Lines:

When using traditional or non-soy based inks and chlorinated solvents. all print shop waste is
treated as hazardous. and discharged ashore in accordance with RCRA.

Handling Method 2 Ernploved by Member Lines:

Shipboard printing processes use non-toxic based printing ink such as soy based. non-chlorinated
solvents. and other non-hazardous products to eliminate hazardous waste products.




Waste Management Practices and Procedures   Page 4

D.    Photo Copviug and Laser Printer Cartridges: CLIA member lines have agreed to
initiate procedures so as to maximise the return ofphotocopying and laser printer
cartridges for recycling, and in any event, have agreed that these cartridges will be
landed ashore.

Increased use of laser and photo copying equipment on shore as well as onboard ship
results in the generation of increased volumes of waste cartridges. inks. and toner materials.
CLIA member lines have agreed to use only such inks. toners and printing/copying cartridges that
contain non-hazardous chemical components. and that none of these cartridges or their
components should be disposed of by discharge into the marine environment. In recognition of
the member lines' goal of waste minimization, they have further agreed these cartridges should,
whenever possible. be returned to the manufacturer for credit. recycling or for relling

Handling Method Employed by Member Lines:

CLIA member lines have agreed that wherever possible, photo copying and laser printer
cartridges will be collected. packaged and returned for recycling and when this is not possible.
that these materials will not be discharged into the sea or other bodies of water but will be
handled as other shipboard waste that is landed ashore for further disposal.

F.  Unused And Outdated Pharmaceuticals: CLIA member lines have agreed to ensure
that unused and/or outdated pharmaceuticals are eectively and safely disposed in
accordance with legal and environmental requirements.

In general ships carry varying amounts of pharmaceuticals. The pharmaceuticals carried
range from over-the-counter products such as anti-fungal creams to prescription drugs such as
epinephrine. Each ship stocks an inventory based on its itinerary and the demographics of its
passenger base. CLIA nrernber lines have agreed that all pharmaceuticals will be managed to
ensure that their efcacy is optimized and that disposal is done in an environmentally responsible

1118111181'.

CLIA member lines have fruther agreed that when disposing of pharmaceuticals. the
method used will be consistent with established procedru'es. and that pharmaceuticals and
rrredicatiorrs which are off specication or which have exceeded their shelf-life, and stocks that
are Lurused and out of date. carnrot be used for patients and therefore will be removed from the
ship. Further. each regulatory jurisdiction lras a posting of listed pharmaceuticals that rrrust be
considered hazardous waste once the date has expired or the item is no longer considered good
for patient use.

Through onboard management of the rrredical facility. CLIA nrember lines have agreed
that stocks of such listed pharmaceuticals are returned to the vendor prior to date of expiration.
Pharmaceuticals that are being returned and which have not reached their expiration date are
shipped using ordinary practices for new products.

Safety and Health

CLIA member lines have agreed that all expired listed pharmaceuticals will be handled in
accordance with established procedru'es and all personnel handling this waste will receive



Waste Management Practices and Procedures   Page 5

appropriate training in the handling of hazardous materials. As guidance. the US Enviromnental
Protection Agency (EPA) has issued a report that claries the fact that residuals. such as
epineplnine. found in syringes after injections are not considered an acutely hazardous waste by
denition and may be disposed of appropriately in sharps containers. Member litres have agreed
that all Universal Precautions will be adhered to when handling sharps.

Handling Method 1 Employed by Member Lines:

Establish a reverse distribution system for returning unexpired. unopened non-narcotic
pharmaceuticals to the original vendor.

Handling Method 2 Employed by Member Litres:

Appropriately destroy narcotic pharmaceuticals onboard ship in a marmer that is witnessed and
recorded.

Handling Method 3 Employed by Member Lines:

Land listed pharmaceuticals in accordance with local regulations. Listed pharmaceuticals are a
hazardous waste having chemical compositions which prevent them from being incinerated or
disposed of through the ship's sewer system. Listing of such pharmaceuticals may vary from
state to state.

Handing Method 4 Emploved by Member Lines:

Dispose of other non-narcotic and non-listed pharmaceuticals through onboard incineration or
landing ashore.

G.  Fluorescent and Mercurv Vapor Lamp Bulbs: CLL"! member lines have agreed to
prevent the release of mercury into the environmentfrom spentfluorescent and mercury
vapor lamps by assuring proper recycling or by using other acceptable disposal methods.

Fluorescent and Mercury Vapor lamps contain small amounts of mercury that could
potentially be harmful to human health and the errviromnent. To prevent human exposure and
contamination of the envirornnent. CLIA member lines have agreed that these lamps will be
handled in an envirormrentally safe manner. Recycling of mercury from lamps and other mercury
containing devices is the preferred handling method and is encouraged by various states. The
recycling of uorescent lamps and high intensity discharge (HID) lamps keeps potentially
hazardous materials out of landlls. saves landll space and reduces raw materials production
needs.

The recycling of uorescent and HID lamps is a proven technology capable of reliably
recovering greater than 99 percent of the mercruy in the spent lights. At the recycling facility.
this is done by using a crush-and-sieve method. In this process. the spent tubes are rst crushed
and then sieved to separate the large particles from the mercury containing phosphor powder.
The phosphor powder is collected and processed under intense heat and negative pressure. a
process called retorting. The mercury is volatized and then recovered by condensation. The glass
particles are segregated and recycled into other products such as berglass.  Aluminum
components are also recycled separately.


Waste Management Practices and Procedures   Page 6

Storage and handling of used lamp bulbs pose no compatibility problems. Disposal of
the glass tubes can be accomplished by (1) processing with shipboard lamp crusher units that
filter and adsorb the nrercruy vapor tln'ouglr H.E.P.A. and activated carbon or (2) by keeping the
glass tubes intact for recycling ashore.  The intact lamps or crushed bulbs are classied as
"Universal Waste" when they are shipped to a properly permitted recycling facility; as such.
testing is not required.  The lters are disposed of as a hazardous waste in accordance with
applicable US EPA or other prevailing laws and regulations.

Handling Method Employed by Member Lines:

(1) Fluorescent and mercury vapor lamps are collected and processed aboard by lamp crusher
units and disposed of as stated above; or

(2) Fluorescent and mercury vapor lamps are collected intact and landed for recycling or disposal
in accordance with prevailing laws and regulations.

H.  Other Mercurv Containing Products: CLLal Member lines have agreed to prevent the
discharge ofmercury containingproducts into the sea.

Reduction in use:  Where feasible. CLIA members will reduce the use of mercruy
containing products.

Disposal: Once mercury-containirrg products are no longer able to be used. or require
disposal. these products shall be landed ashore as universal or hazardous waste as
appropriate.

I.    Batteries: CLM member lines have agreed to prevent the discharge ofspent batteries
into the marine environment.

If not properly disposed of. spent batteries may constitute a hazardous waste stream.
Most of the large batteries are on tenders and standby generators.  Small batteries used in
ashlights and other equipment and by passengers. account for the rest. There are four basic
types of batteries used.

Lead-acid batteries  These are used in tenders and standby generators. They are wet.
rechargeable, and usually six-celled.  They contain a sponge lead anode. lead dioxide
cathode. and sulfuric acid electrolyte.  The electrolyte is corrosive.  These batteries
require disposal as a hazardous waste. unless recycled or reclaimed.

Lead-acid batteries use sulfuric acid as an electrolyte.  Battery acid is extremely
corrosive. reactive and dangerous. Darrraged batteries will be drained into an acid-proof
container. A damaged and leaking battery is then placed in another acid-proof container.
and both the electrolyte and the damaged battery placed in secure storage for proper
disposal as a hazardous waste.

Nickel-cadmium ngiCadz batteries - These are usually rechargeable. and contain wet or
dry potassiurrr hydroxide as electrolyte. The potassium hydroxide is corrosive and the
cadrrriuru is a characteristic hazardous waste. Therefore. NiCad batteries will be disposed
of as hazardous waste. unless recycled or reclaimed.


\Vaste Management Practices and Procedures   Page 7

Lithium batteries  These are used as a power som'ce for ashlights and portable
electronic equipment. All lithium batteries will be disposed of as hazardous waste, or
sent out for reclamation.

Alkaline batteries  These are common ashlight batteries and are also used in many
camera ash attachments, cassette recorders. etc.  They should be recycled, properly
disposed or reclaimed.

Handling Method Employed by Member Lines:

Spent batteries are collected and returned for recycling andior disposal in accordance with
prevailing regulations. Discarded batteries are isolated from the refuse waste stream to prevent
potentially toxic materials from inappropriate disposal. The wet-cell battery-recycling program is
kept separate from the dry battery collection process. Intact wet-cell batteries are sent back to the
supplier. Dry-cell batteries are manifested to a licensed firm for recycling.

J.   Bilge and Oily Water Residues: CLIA member lines have agreed to meet or exceed the
international requirements for removing oil from bilge and wastewater prior to
discharge.

The area of the ship at the very bottom of the hull is known as the bilge. The bilge is the
area where water collects from various operational sources such as water lubricated sha seals.
propulsion system cooling, evaporators. and other machinery. All engine and machinery spaces
also collect oil that leaks from machinery fittings and engine maintenance activities. In order to
maintain ship stability and eliminate potential hazardous conditions from oil vapors in engine and
machinery spaces. the bilge spaces should be periodically pumped dry. In discharging bilge and
oily water residues. both international regulations (MARPOL) and United States regulations
require that the oil content of the discharged efuent be less than 15 parts per million and that it
not leave a visible sheen on the surface of the water.

All ships are required to have equipment installed onboard that limits the discharge of oil
into the oceans to 15 parts per million when a ship is en route and provided the ship is not in a
special area where all discharge of oil is prohibited.  Regulations also require that all oil or oil
residues. which carmot be discharged in compliance with these regulations. be retained onboard
or discharged to a reception facility. The equipment and processes implemented onboard cruise
ships to comply with these requirements are complex and sophisticated.

The term "en route" as utilized in MARPOL (73/78) Regulation 9(b) is taken to mean
while the vessel is underway. The US Coast Guard has informed CLIA that it agrees with this
meaning of "en route. "

In accordance with MARPOL (73.578) Regulation 20 and as appropriate. US regulations
(33CFR151.25). CLIA member lines have agreed that every cruise ship of 400 gross tons and
above shall be provided with an oil record book which shall be completed on each occasion
whenever any of numerous specied operations take place in the ship and that operations include:

Ballasting or cleaning of fuel oil tanks.
9935'?"  Discharge of dirty ballast or cleaning water from the fuel oil tanks above.
Disposal of oily residues.
And discharge of bilge water that accumulated in machinery spaces.


Waste Management Practices and Procedures   Page 8

Requirements regarding the keeping of an Oil Record Book as well as the form of the Oil
Record Book are also found in MARPOL and in US. Coast Guard regulations
(3 3CFR15 1).

Handling Method Employed by Member Litres:

Bilge and oily water residue are processed prior to discharge to remove oil residues. such that oil
content of the efuent is less than 15 ppm as specied by MARPOL Annex 1.

K.  GlassI Cardboard, Aluminum and Steel Cans: CLIA member lines have agreed to
eliminate. to the maximum extentpossible, the disposal ofMARPOL Annex Vwastes into
the marine environment. This will be accomplished through improved reuse and
recycling opportunities. They have further agreed that no waste will be discharged into
the marine environment unless it has been properly processed and can be discharged in
accordance with M4RPOL and otherprevailing requirements.

Management of shipboard generated waste is a challenging issue for all ships at sea. This
is true for cruise vessels. other commercial vessels. military ships, shing vessels and recreational
boats.  Waste products in the past were made from natural materials and were mostly
biodegradable. Today's packaging of food and other products present new challenges for waste
management. A large cruise ship today can carry over three thousand passengers and crew. Each
day. an average cruise passenger will generate two pounds of dry trash and dispose of two bottles
and two cans.

A strategy of source reduction. waste minimization and recycling has allowed the cruise
industry to signicantly reduce shipboard generated waste. To attain this. CLIA member lines
have agreed to adopt a multifaceted strategy that begins with waste minimization to decrease
waste from provisions brought onboard. This means purchasing in bulk. encouraging suppliers to
utilize more efficient packaging. reusable packaging. and packaging materials that are more
enviromnentally friendlythose that can be more easily disposed of or recycled. In fact. through
this comprehensive strategy of source reduction. total waste on passenger vessels has been
reduced by nearly half over the past ten years.

Another important component of the industry's waste reduction strategy is product or
packaging recycling. Glass, aluminum. other metals. paper. wood and cardboard are. in most
cases. recycled. Wood and cardboard may be incinerated when appropriate.

Handling Method Employed by Member Lines:

MARPOL Annex V ship waste is minimized through purchasing practices. reuse and recycling
programs. landing ashore and onboard incineration in approved shipboard incinerators.  Any
Annex V waste that is discharged at sea will be done in strict accordance with MARPOL and any
other prevailing requirements.

L.  Incinerator Ash: CLIA member lines have agreed to reduce the production of incinerator
ash by minimi:ing the generation ofwaste and maximizing recycling opportunities, and that
the discharge of incinerator ash containing hazardous components will be prevented
through a program ofwaste segregation andperiodic ash testing.


Waste Management Practices and Procedures   Page 9

Incinerator ash is not normally a hazardous waste. Through relatively straightfom'ard
waste management strategies, items that would cause the ash to be hazardous are separated from
the waste stream and handled according to accepted hazardous waste protocols.  In general,
source segregation for waste streams is foundational for onboard waste management and is
incorporated into the waste management manual required by MARPOL. Waste management for
onboard waste streams include the following: source reduction, minimization. recycling,
collection. processing and discharge ashore. This allows the incinerator to be used primarily for
food waste. contaminated cardboard. some plastics. trash and wood.

Member lines have agreed that incinerator ash will be tested at least once quarterly for
the rst year of operation to establish a baseline and that testing nray then be conducted once a
year.  The member lines have further agreed that a recognized test procedure will be used to
demonstrate that ash is not a hazardous waste.  A recognized test procedure includes the
following metals as indicators for toxicity - arsenic. barium. cadmium. chromium. lead, mercury.
selenium. and silver. Special attention is placed on the removal of batteries from the incinerator
waste stream. The use of incinerators saves landfill space and prevents the build up of material
onboard that could become the breeding ground for insects, rodents and other vermin.

Handling Method Employed by Member Lines:

Proper hazardous waste management procedures are to be instituted onboard each ship to assure
that waste products, which will result in a hazardous ash. are not introduced into the incinerator.
Non-hazardous incinerator ash may be disposed of at sea in accordance with MARPOL Armex V.
Ash identified as being hazardous is disposed of ashore in accordance with RCRA.

M. Wastewater reclamation

Because of the amounts of fresh water involved and its restricted availability onboard
ship (all fresh water must be either purchased or generated onboard). fresh water is a
valuable commodity. Therefore. water management is extremely important and takes the
form of both minimizing water usage and the potential reclamation and reuse of water for
non-potable purposes.  Many CLIA companies are researching new technology and
piloting graywater treatment systerrrs onboard their vessels. CLIA member operators also
take numerous steps in onboard water rnanagenrent.  Water management teclnriques
include:

a.  Use of technical water (for example: air conditioning condensate) where possible.
b.  Use of water recovery systems (for exarrrple: ltering and reuse of laundry water 
last rinse use for rst wash).
c.  Reclamation and reuse as technical water (ushing toilets.  laundry. open deck
washing) of properly treated and ltered wastewaters.
(1.   Active water conservation (for example: use of reduced ow showerheads, vacuum
systems for toilets. vacurun food waste transportation and larurdry equipment that
utilizes less water).

N. Graywater: For ships n'aveling regularly on itineraries beyond the territorial waters of
coastal states, CLL~1 member lines have agreed to discharge grayrr'ater only while the
ship is underway and proceeding at a speed ofnot less than 6 knots}; that graywater will
not be discharged in port and will not be discharged within 4 nautical miles 'om share

or such other distance as agreed to with authorities having jurisdiction or provided for
by local law except in an emergency, or where geographically limited. The member lines

Waste Management Practices and Procedures   Page 10

havefurther agreed that the discharge ofgraywater will comply with all applicable laws
and regulations. For vessels whose itineraries are fully within US territorial waters.
discharge shall comply fully with U.S. and individual state legislation and regulations.

The term graywater is used on ships to refer to wastewater that is generally incidental to
the operation of the ship. The International Maritime Organization (IMO) denes graywater as
including drainage from dishwasher, shower. laundry. bath and washbasin drains. The US Clean
Water Act (formally know as the Federal Water Pollution Control Act) includes galley. bath and
shower water in its denition of graywater. The US regulations implementing this act do not
include a further denition of gray water. However. the regulations do include a provision that
exempts all of the wastewater included in the IMO definition and other discharges incidental to
the operation of a ship from the Clean Water Act's permitting program (formally known as the
National Pollution Discharge Elimination System (NPDES) program). Finally. the US Coast
Guard regulations include provisions that essentially combine the two definitions from the IMO
and the Clean Water Act.  None of the denitions of graywater include blackwater (discussed
below) or bilgewater from the machinery spaces. Recent U.S. Legislation places limits on the
discharge of graywater in the Alaska Alexander Archipelago.

Handling Method Employed by Member Lines:

Graywater is discharged only while ships are underway and proceeding at a speed of not less than
6 knots. in recognition that dispersal of these discharges is desirable and that mixing of these
waters. which are discharged approximately 10-14 feet below the surface. by the action of the
propellers and the movement of the ship. provides the best dispersal available.

0. Blackwater:  Waste from toilets, urinals, medical sinks and other similar facilities is
called "blackwater. " CLIA members have agreed that all blackwater will be processed
through a Marine Sanitation Device (MSD), certied in accordance with U.S. or
international regulations, prior to discharge. For ships traveling regularly on itineraries
beyond the territorial water ofcoastal states, discharge will take place only when the ship
is more than 4 milesfrom shore and when the ship is traveling at a speed ofnot less than 6
I
knots.
For vessels whose itineraries are fully within US territorial waters, discharge shall
complyfully with U.S. and individual state legislation and regulations.

P.  Advanced Wastewater Purification Svstems:

To improve enviromnental performance. cruise lines are testing and installing wastewater
piu'ification systems that utilize advanced teclmologies.  These onboard wastewater
treatment systems are designed to result in efuent discharges that are of a high quality
and purity: for example. meeting or surpassing standards for secondary and tertiary
efuents and reclaimed water.  Efuents meeting these high standards would not be
subjected to the strict discharge limitations previously discussed

1
For vessels operating under sail. or a combination of sail and motor propulsion. the speed shall
not be less than 4 knots.




Waste Management Practices and Procedures   Page 11

Q.  Training and Educational Materials

Training is an important and ongoing part of every position and tasking onboard cruise
ships. Not only is training necessary for the safe and economical operation of a ship it is
required by numerous international conventions and ag state regulations.  The
International Convention on Standards of Training Certication and Watchkeeping
(STCW) for example. sets forth requirements for knowledge. experience and
demonstrated competency for licensed ofcers of the deck and engineering departments
and for ratings forming part of the navigation or engineering watch. Equivalent national
standards apply to ships in United States registry. These detailed requirements address
not only the navigation of the ship but also the proper operation of the shipboard
machinery and knowledge of and ability to assure compliance with the environmental
protection requirements of MARPOL and the safety regulations of The International
Convention on Safety of Life at Sea (SOLAS). SOLAS also requires that the ship's
training manual (which contents are prescribed by regulation) be placed in the crew
messes and recreation rooms or in individual crew cabins.

CLIA member lines have developed programs that raise the level of envirornnental
awareness on the part of both the passengers and the crew. Each ship's crew receives training
regarding shipboard safety and enviromnental procedures.    Advanced training in shipboard
safety and eriviromnental management procedures is provided for those directly involved in these
areas.  Those directly responsible for processing wastes are given specic instruction in their
duties and responsibilities and in the operation of the various equipment and waste management
systems. Specic actions that our member lines have taken to train employees and increase
passenger awareness include:

a.  Announcements over the public address system and notices in ship newsletters that
caution against throwing any trash overboard.
b.  Signage and colorful posters placed in crew and passenger areas encouraging
envir'ornnental awareness and protection.
c.  Safety and enviromnental information booklets in crew cabins and crew lounges.
(1.   Regular meetings of ship safety and enviromnental committees consisting of ofcers
and crew from all departments to review methods of improving performance.
including better and more effective envirorunental practices.

For ships on an international voyage. STCW. SOLAS. the International Management
Code for the Safe Operation of Ships and for Pollution Prevention (ISM Code). require that
training be fully docrunented. Individual training is documented in each crewrneiiibers file. Ship
training exercises. such as fire drills and emergency response exercises. are documented in the
appropriate ship's logs. All of these training docrunents are required to be available for oversight
examination by both the ship's ag state inspectors and by port state authorities such as the
United States Coast Guard.

Placards warning of the prohibition of the discharge of oil are posted on all ships
operating in the navigable waters of the United States as required by US. Coast Guard
regulations (33CFR155.450).  Additionally. as part of required shipboard waste management
plans. both Coast Guard regulations (33CFR151.59) and MARPOL (Aimex V Regulation 9)
require the posting of placards that notify the passengers and the crew of the disposal
requirements for garbage. These placards are to be written in the ofcial language of the State
whose ag the ship is entitled to y and also in English or French if neither of these is the ofcial

language. Once again, oversight of compliance with these requirements is conducted by ISM
audits and frequent inspections by ag states and the United States Coast Guard.

For those ships on an international voyage. the Safety of Life at Sea Convention
mandates compliance with the ISM Code. This comprehensive Code requires that each vessel
operating company and each vessel participate in a_very strictly defined management program.
under both internal and external audit and regulatory oversight that sets forth detailed procedures
for assuring compliance with safety. enviromnental protection. emergency response and training
mandates.

Equivalent equipment, practices and procedures

CLIA member lines have agreed that the use of equivalent or other acceptable practices
and procedures shall be connnunicated to CLIA. As appropriate. such practices and procedures
shall be included as a revision to this document. As an example. when improved systems for
treating blackwater and graywater are perfected. shown to meet the requirements for MSDs and
accepted by appropriate authorities for the treatment of graywater. the new systems and
associated technology will be included together with their impact on the current standard of
discharging graywater only while turdeiway.














Waste Management Practices and Procedures   Page 13

Appendix iii:
Navigational Chart of Waters Subject to this MOU

Appendix iv
Commandant             2100 Second Street, S.W.
US. Department of
United States Coast Guard        Washington, DC 20593-0001
Homeland Security                                   Staff Symbol: G-MOC-2
Phone: (202) 2672978
United States                Fax: (202) 267-0506
Email: dr~g"moc@comdt.uscg.mil
Coast Guard


COMDTPUB P167004
NVIC 0404

13 FEBRUARY 2004

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO, 04-04

Subj:  ENVIRONMENTAL INSPECTION CHECKLIST; ADDENDUM TO FOREIGN
PASSENGER VESSEL EXAMINATION BOOK, CG~84O

Ref:  (a)  General Accounting Ofce (GAO) Report of February 2000 on "MARINE
POLLUTION  Progress Made to Reduce Marine Pollution by Cruise Ships, but
Important Issues Remain."
(b)  Title XIV "Certain Alaskan Cruise Ship Operations" contained in Section 1(a)(4) Of
Public Law 106-554 enacted on December 21, 2000
(c)  33 CFR 159, Subpart E  Discharge of Efuents in certain Alaskan Waters by Cruise
Vessel Operations
((1)   Memorandum of Understanding (MOU) dated March 14, 2000 entered between Florida
and the FloridaCaribbean Cruise
Department ofEnvironmental Protection (FDEP)
Association (FCCA), a representative of the cruise industry in Florida
(e)  International Council of Cruise Lines (ICCL) Industry Standard EOlOl, "Waste
Management Practices and Procedures"

PURPOSE. As the result of a GAO report and Bluewater Network petition, the FCCA, FDEP,
and the Coast Guard began discussing the means to improve and ensure the compliance of large
Federal and state environmental standards. These discussions
passenger vessels with existing
Enclosure
have resulted in the checklist contained in        1. This checklist is an extensive list Of
and
possible inspection items related to pollution prevention equipment, operation, plans
records It is intended as a job aid to be used by Coast Guard personnel during certicate of
vessels.
compliance examinations onboard foreignagged passenger      Additionally, this
is intended to provide
document does not change or establish new Coast Guard authorities, but

Distribution " SDL Not 141
IOTll'HUOUJ)
NONSTANDARDDISTRIBUTION: B:a GMOC, GMOl, GMSE (l)

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 04-04

a framework and focus on responsibilities currently possessed. This checklist will be
incorporated into a future revision of the existing Foreign Passenger Vessel Examination Book,
CG-840.
2. ACTION. Officers in Charge Marine Inspections (OCMIs) and their designated marine
inspectors should:
a.  Bring this circular to the attention of appropriate individuals in the marine industry within
their zones, especially those in the industry who are not members of ICCL. This circular is
available on the world-wide web at: http://www.uscg.mil/hq/g-m/nvic/index.htm. Internet
release authorized.
b.  Follow the guidance in this circular while conducting Certificate of Compliance
examinations on foreign-flag passenger vessels, choosing one of the five waste streams to
inspect.
c.  If any non-conformities are noted between the procedures listed in the vessel's Safety
Management System (SMS) documentation and the actual procedures being followed on
the ship, notify the Company immediately and follow the guidance contained in NVIC 4-
98. If major non-conformities are identified, an OCMI should use risk-based decisionmaking
and exercise discretion with regard to the level of control action utilized on the
vessel.
d.  If deficiencies or discrepancies are noted in the execution of the hazardous waste
management program, notify the applicable Environmental Protection Agency (EPA) office
or the State Resource Conservation and Recovery Act (RCRA) program office immediately.
3. DIRECTIVES AFFECTED. The existing Foreign Passenger Vessel Examination Books CG-
840, CV1, CV2 and CV3 will be revised to include the checklist contained in Enclosure (1), as
.
soon as practicable.
4. BACKGROUND. 
a. From 1993 to 1998, nearly 2400 documented cases of pollution by foreign-flagged vessels
were investigated, of which nearly four percent involved passenger vessels. As a result,
Congress requested the GAO to examine the nature and extent of cruise ship involvement
in these incidents; current and planned federal agency enforcement efforts; and cruise
company actions to prevent future recurrences of pollution incidents. On February 1, 2000,
the GAO completed a report to Congress, reference (a), recommending that the Coast
Guard initiate discussions with the cruise ship industry, other federal and state agencies,
and environmental groups as appropriate, on the need for improved water quality standards
for gray water and black water discharged from cruise ships and other vessels. In addition,
the report recommended an assessment of the need to periodically monitor the water quality
of these discharges. This GAO report is available on the world-wide web for review at
http://frwebgate. access.gpo.gov/cgibin
/useftp.cgi?IPaddress=162.140.64.21 &filename=rc00048.pdf&directorv=/diskb/wais/data/gao. 


2

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 04-04

b. At the time reference (a) became public, federal responsibilities were in place for various
vessel waste stream control systems including effluent from the oily water separators,
effluent from the sewage treatment plants, hazardous waste, and garbage. Subsequently,
legislation was passed and regulations were promulgated (see references (b) and (c)) that
expanded federal responsibilities to include requirements for gray water discharge and for
monitoring and sampling of black water and gray water waste streams on cruise ships in
Alaska'.
c. On March 14, 2000, the Florida Caribbean Cruise Association (FCCA) signed a MOU with
the Florida Department of Environmental Protection (FDEP), reference (d), that is available
for review on the world-wide web at http://www.iccl.org/resources/fdep_mou.htm. Under this
MOU, the FDEP recognized ICCL's Industry Standard E-01-01, "Waste Management
Practices and Procedures," reference (e), as meeting or exceeding the standards set forth in
Florida laws and applicable regulations. Though not a party to the MOU, the Coast Guard
participated in discussions that resulted in the MOU. In the MOU, the FDEP recognized
the Coast Guard as the primary federal agency with responsibility for examining passenger
vessel waste streams. As a result, the Coast Guard worked in conjunction with FDEP and
ICCL to develop a checklist related to monitoring of hazardous waste and disposal.
5. DISCUSSION. The enclosed checklist reflects the collective work of the USCG, FCCA and
FDEP and has been tested for use by several Coast Guard Marine Safety Offices. The checklist
is not a listing of all items to be inspected; rather the marine inspector should use it as a
reminder of the various items that may be examined during a certificate of compliance
examination of a foreign passenger vessel. As always, the marine inspector's experience,
knowledge, and judgment will determine the depth and scope of each examination. However,
each marine inspector should select at least one waste stream for a thorough and detailed
inspection during every annual or periodic foreign passenger vessel examination. The stream
selection will be based on the marine inspector's discretion, taking into account the inspector's
impression about the condition of the various waste stream systems on board the vessel. The
selection will also be based on the need to inspect all systems over a reasonable period of time,
whether a particular waste stream is applicable for examination (e.g. there may be no
requirement applicable to gray water at the port of examination or the vessel does not
discharge/offload hazardous waste), and maintaining randomness so that the operator has no
advance knowledge of the waste stream that may be selected. During the examination, the
operator should be able to present to the marine inspector a clear description of the practices
and procedures for handling each waste stream and also to produce such records, as the
inspector might need to verify compliance with these guidelines. In performing pollution
prevention examinations, inspectors should be especially familiar with the contents of the
Marine Safety Manual (MSM), Volume II, Material Inspection, Section B, Chapter 6,
"Pollution Prevention," and Section C, Chapter 2, Paragraph K, "Marine Sanitation Devices"
and this NVIC. Marine inspectors should also be familiar with ICCL's Industry Standard E-01-
01 "Waste Management Practices and Procedures", reference (e), and the vessel's Safety
Management System (SMS) documentation, which should address all the elements discussed in
1 Presently, there are no other federal requirements applicable to the control or filtering of gray water discharge from
foreign-flagged passenger ships.

3

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 04-04
this standard. Note reference (e) is available at the ICCL website at
http://www.iccl.org/resources/exhibit a.pdf. If any elements are not addressed there should be a
rationale for its omission. The different waste streams may be categorized as follows:
a.  Oil pollution prevention systems: include the oily water separator, the fuel/lubricating oil
transfer, and sludge containment system. The marine inspector should verify that the oily
water separator is operating within the desired range; that the alarms are working; that crew
is knowledgeable and operating instructions are posted; and that maintenance is carried out
at regular intervals. Actual piping may be verified against the approved piping diagram if
the marine inspector notices modifications made to the system.
b.  Black water system: includes marine sanitation devices (MSDs) and other systems to treat,
store, and discharge sewage. The checklist is designed to guide the marine inspector
through some basic questions to ascertain whether the system is working as designed and
that the crew is properly trained in its operation. For example, does the MSD appear to be
properly installed? Is the MSD approved for use on this particular vessel (USCG
Approved, IMO or Administration Approved to MARPOL Annex IV)? Is there adequate
capacity or throughput for the number of persons on board? Are maintenance procedures
being followed, including procedures outlined in the vessel's SMS? Are there records of
expendables being ordered: filters, chemicals, et cetera? Are the units operating within the
manufacturer's design specifications? Are there clear and simple operating instructions? Is
the crew knowledgeable in the use of the equipment/system?
c.  Hazardous waste: includes dry cleaning (containing Perchloroethylene, or commonlycalled
"PERC") waste, used paints and thinners that contain hazardous substances, silverbearing
photo-processing waste, cleaning solutions and other items that contain hazardous
substances. Each vessel may vary in both the type and volumes of hazardous waste
generated depending on the technology and processes used aboard. This checklist is
designed to evaluate onboard management of hazardous waste streams, to ensure that
hazardous constituents are not released into the environment, and that accountability is
demonstrated via adequate waste disposal records.
d.  Non-hazardous waste: includes shipboard garbage including plastics and synthetic
material, medical waste, food wastes and recyclables such as glass, cardboard, aluminum
and metal cans. Items to be checked should include: disposal and incineration records;
waste sorted to prevent hazardous waste from entering the non-hazardous waste stream; no
plastics or synthetics discharge overboard; separate and proper disposal of hazardous and
non-hazardous incinerator ash; and proper disposal of cooking grease from grease traps.
e.  Gray water system: includes discharges from galley, sinks, washbasin drains, showers, and
baths, excluding drains and sinks from medical spaces. These may be held in large tanks
before being pumped overboard. The handling and discharge of gray water will vary from
ship to ship and the inspector should ensure the procedures followed by the ship correspond
to those described in its SMS documentation. If gray water is directed to MSD systems, the
marine inspector shall ensure that combined gray water/black water throughput does not
exceed the throughput of the MSD systems. Other waste streams such as hazardous waste



4

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 04-04
or medical waste must also not be mixed with gray water. Drains from hospitals, photo labs
(if hazardous substances are used and stored therein), and slops, must be separate from the
gray water system.

T. H. GILMOUR
Rear Admiral, U. S. Coast Guard
Assistant Commandant for Marine Safety,
Security, and Environmental Protection
Encl: (1) Foreign Passenger Vessel Pollution Survey Exam Book (CG-840 PSEB)














5

Enclosure (1) to NVIC 04-04

United States Coast Guard



FOREIGN PASSENGER VESSEL
POLLUTION SURVEY EXAM BOOK
(FOR ALL PASSENGER VESSELS)

Name of Vessel                        Flag
0 No Change
IMO Number                      Case Number

Date Completed

Location

Senior Marine Inspectors / Port State Control Officers
1.                                         5.
2.                                         6.
3.                                         7.
4.                                         8.






CG-840 PSEB
Pollution Survey Exam Book
Rev. 12JAN2004


1

Use of Foreign Passenger Vessel Pollution Survey Exam Book
This Checklist is an extensive list of possible examination items related to pollution prevention equipment, operation, plans and records.
It is intended as a job aid to be used by Coast Guard senior marine inspectors during boardings of foreign-flagged passenger vessels. It
is not the Coast Guard's intention to inspect all the items listed in the checklist at every exam; rather the inspector should use it as a
reminder of the various items that may be examined during a foreign passenger vessel certificate of compliance examination. As
always, the inspector's experience, knowledge, and judgment will determine the depth and scope of each examination; however, the
inspector should select at least one waste stream for a thorough and detailed inspection. The stream selection will be based on the
marine inspector's discretion, taking into account the inspectors impression about the condition of the various waste stream systems on
board the vessel, weighing the need to inspect all systems over a reasonable period of time, and maintaining randomness so that the
operator has no advance knowledge of the waste stream that may be selected.
It is incumbent on the vessel operator to be familiar with this checklist. The individuals responsible for different segments of the various
waste streams should be able to present to the inspector a clear description of the practices and procedures for handling each waste
stream and also to produce such records, as the marine inspector might need, to verify compliance with these guidelines. Inspectors
should obtain a clear picture about the selected waste stream(s) and associated environmental processes by observing onboard
practices and through questioning of the individuals that perform these practices. Inspectors should avoid circumstances in which a
shore-side representative is the sole company liaison during the environmental inspection.
As a port state responsibility, marine inspectors and port state control officers must verify that the vessels and their crews are in
substantial compliance with international conventions and applicable U.S. laws. The marine inspectors and port state control officers,
based on their observations, must determine the depth and scope of the examination.
This document does not establish or change Federal laws or regulations. References given are only general guides. Refer to IMO
publications, United States Code, Code of Federal Regulations, the Port State Control Job Aid, NVIC's, and any locally produced 
guidance for specific regulatory references. Marine inspectors should be especially familiar with all equipment standards and the
contents of the Marine Safety Manual (MSM), Volume II, Material Inspection, Section B, Chapter 6, "Pollution Prevention," Section C,
Chapter 2, Paragraph K, "Marine Sanitation Devices," and Volume IV, Technical, Chapter 3, Section K, "Special Engineering
Applications for Pollution Prevention".
NOTE: Guidance on how to examine foreign passenger vessels for compliance with pollution prevention equipment standards, can be
found in NVIC _-04.

Conductinq the exam 
Complete Certificates/Equipment Data/Records information (Section A).
Review SMS Environmental Procedures (Section B).
Examine MSD, OWS, Garbage logs, Oil Record Book as per CG-840 Exam books.
Determine if gray water requirements apply in the vessel's AOR and in inspection zone (If not, do not select C2)
Make waste stream selection for a detailed exam (Section C)
Section
Cl Oil Pollution Handling Waste Stream (Bilge, Sludge, Fuel, Lube Oil etc)
C2 Gray Water Waste Stream
C3 Black Water/Sewage Waste Stream
C4 Hazardous Waste Stream
C5 Non-hazardous Waste Stream
NOTE: Many items listed are not mandatory requirements, but fall under the umbrella of "Management Policy". Marine inspectors
should be familiar with ICCL's Industry Standard E-01-01 "Waste Management Practices and Procedures," and SMS documentation on
all cruise ships should address all the elements discussed in this standard. If any elements are not addressed there should be a
rationale for its omission. If the areas listed are corporate policy as set out in the company's SMS documentation, then the vessel
should be held accountable for the actions as required in 33 CFR 96 and SOLAS Chapter IX. If state or local laws exist that are more
stringent than U.S. or international law, then the local or state laws must be followed. These vessels are not exempt simply because
they are a foreign-flagged vessel.
Pre-inspection Items                       Post-inspection Items 
Review MISLE records                  Issue letters/certificates to vessel
Deficiency History                        Issue Port State Control Report of Inspection-Form A
Critical Profile                       Issue Port State Control Report of Inspection-Form B (if
Review Court-ordered requirements and           needed)
environmental audit reports, if applicable          Complete COC endorsement (include "Waste Stream" area
CG Activity History                           inspected)
Print Center for Disease Control Green Sheet       MISLE activity case
http://www2. cdc.gov/nceh/vsp/vspmain. asp 

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Enclosure (1) to NVIC 04-04
Section B 
Environmental Procedures
Environmental Procedures can be found in the ship's Safety Management System (SMS) documentation or in company
polices and maintenance manuals, inspection logs, oil record books, etc. Marine inspectors should question the ship staff
on procedures and normal operations, and compare the answer to what is written in procedures and manuals. For each
waste stream, persons with specific responsibilities should be questioned at each step in the waste handling process.
Inspectors should require being shown specific process step by the person responsible for that step. Inspectors should
ask extensive questions regarding availability of documents and supporting material relevant to the individual performing
the specific activity in the waste handling process. Other questions should focus upon training provided and reporting
procedures when problems with waste management processes are identified.               33 CFR 155.700
Current pollution prevention records                                    33 CFR 156.150
Person-in-charge designated and qua lified(certificated/licensed)                                  33 CFR 156.170
Transfer equipment tests and inspections                                                 ISM Code/SMS
Declaration of Inspection (available and retained for at least one month)                             33 CFR 96
Ship to provide PMS logs and required PMS activities for the selected waste stream for verification.
Verify SMS incorporates PMS activities and logs for all Waste Streams.
Court required logs to track oil usage in systems having oil to sea interfaces (if applicable)
Recent environmental audit reports when available
Oil Record book (Part 1) (spot-check)
Each operation signed by person-in-charge
Each complete page signed by master
Book maintained for 3 years                                                          MARPOL Annex. 1/20
Use of proper codes and version for vessel                                                33 CFR 151.25
Transfer receipts/manifest match oil record book entries
OWS rates not exceeding design criteria
Incinerator rates not exceeding design criteria
Consistent bilge water management patterns
Comparison of oil record book entries to vessel's daily tank sounding book
Shipboard Oil Pollution Emergency Plan                      MARPOL Annex.
Approved by Administration (class society)                                                 1/26.1
Updated and current                                                               33 CFR 151.26
In English and working language of crew
Correct contact numbers for National and Local Authorities (Port Authorities for ports visited not every COTP)
Immediate Actions List
Non Mandatory Provisions (if listed in SOPEP). Spill kits located and inspected
MARPOL Annex V
Placard posted
Record book
Garbage management plan                                                           MARPOL Annex V/9 
Non-Hazardous Waste Disposal Documentation (if applicable)
EPA Generator ID#______________________ (if applicable)
Records
Non-Hazardous Waste Manifests
U.S. Local
Regulations as
Recycling policy being followed (requires a detailed assessment)                       applicable
Hazardous Waste Disposal Documentation (if applicable)
EPA Generator ID#______________________ (if applicable)                                    Shipboard policy
Records                                                                       SMS
Uniform Hazardous Waste Manifests
40 CFR 262
Land Disposal Restriction Notification Certification Forms (LDR)                                  Shipboard policy
Shipping Document for Regulated Medical Waste                                            SMS 
Interview Person(s) responsible for landing of wastes
Specialized training for Responsible person(s) and related documentation
Evidence of disposal in other countries to bona fide receivers documented

4

Section Cl
Oil Pollution Handling Waste Stream (Bilge. Sludge. Fuel. Lube Oil etc)
Oil pollution prevention systems include, but are not limited to, the oily water separator, other filtering or flocculation
devices, bilge water management, fuel/lubricating/waste oil transfer, purifier and lantern space sludge collection, transfer
and containment systems. Marine inspectors should verify that the oily water separator is operating within the required
range; that the alarms are working and sound at appropriate levels; that crew is knowledgeable and operating instructions
are posted; that maintenance is carried out at regular intervals and repairs are documented; and that system operation
and maintenance are in accordance with the vessel's SMS. Marine inspectors should verify the actual pollution
prevention system piping against vessel's approved piping diagrams, if modifications such as blanked off tees,
connections points, hoses, or temporary piping segments associated with these systems are observed.
Oily Water Separator (OWS)
Verify bilge piping, no modifications & matches approved diagram (direct to OWS, to holding tank, etc.)    MARPOL Annex 1/16
No blanked flanges, pipe caps, or dead-ended valves, or tees on inlet or outlet piping                33 CFR 155.360/370 
Evidence of bolting/unbolting of associated piping segments
Recent paint on pipe segments
Observe general housekeeping and cleanliness
Witness operational test of OWS, evaluate operator competency. System operating in published ranges
Verify unit is processing contaminated source. Operate system for sufficient time (15 minute minimum) to
identify reduction in contaminated source
Test 15 ppm Oil Content Meter and alarm
On units with multiple Oil Content Meters, compare readings
Ensure sample analyzed by Meter is OWS output (Trace sample line for presence of unacceptable clean
water connection)
Verify no electrical bypasses, jumpers, extra switches on or within unit or Meter control panel
Verify system automatically re-circulates (3-way valve) or shuts down when >15ppm. Verify proper
operation of valve
Verify proper operation of system backflush or oil purge cycle
Visually sample processed water for gross contamination (sheen or visible oil)
Compare ship's operational maintenance routine with actual Preventative Maintenance conducted.
Request proof/documentation of maintenance completed (used consumables from OWS, receipts of
service, technician reports, contractor disposal records)
Review meter calibration records
Review strip charts if fitted
Examine other machinery space overboard piping for unusual connections
Review records pertaining to system repairs
Oil Pollution placard posted                        33 CFR 155.450
Oil Transfer Procedures                                      33 CFR 154.340
Posted / available in crew's language                                                 33 CFR 155.720
Person in Charge (PIC) fluent in English or language mutually agreed upon w/ shoreside PIC           33 CFR 155.750
Format in CFR order or cross reference index page                                       33 CFR 154.310
List/description of products carried by vessel
Description of transfer system including a line diagram of piping system (pumps, vents, valves, alarms,
shutoffs, etc.)
Number of persons required on duty
Duties by title of each person
Means of communication (two-way voice)
Procedures to top off tanks and disconnect
Procedures to report oil discharges
Emergency response procedures (fire, spill, human exposure)
Standard discharge connection                                  MARPOL Annex 1/19
Fuel/lube/sludge oil fill, vent & overflow discharge containment                     33 CFR 155.430
Size (<1600GT'/2 bbl, >1600GT 1 bbl)                                                    33 CFR 155.320
Fixed (Built after 30Jun74) or Portable (before 30Jun74)
Drains
Scupper closures
Prohibited oil spaces (no oil/hazardous substances carried fwd of collision bulkhead)            33 CFR 155.470


5

Lighting at each Transfer Operations Work Area                              33 CFR 155.790
Adequate
Located/Shielded to not interfere with navigation
Oil transfer hose (if vessel uses to transfer in U.S. waters) including LifeboatlTender Hoses          33 CFR 155.800/805
Condition                                                                          33 CFR 154.500
Markings (MAWP, Mfg. Date, Test date) -                                                 33 CFR 156.170
Hose assembly requirements (blanked off if not new, gas free or in use)
Tests and inspections
Bilge Water Management                                          MARPOL Annex I
Examine machinery space bilges (stem to stem)
Contamination / oily residues in bilges on bulkheads, piping, structures, within roseboxes
Leakage from systems and engines into machinery spaces (may not be seen during port ops)
Engine oil usage, quantities, where lost, consumed or in bilges
Evidence of recent cleaning of systems, equipment and components
Status of oily bilge water tanks, last cleaned, at capacity
Adequate capacity all tanks
Levels of tanks during inspection  high or low?
If tanks near full  what are the vessel's processing plans?
Evidence of detergent usage (Note- emulsions cannot separate in gravity separator and are likely to result
in discharges over 15 PPM)
Other methods to discharge bilge water
Evidence of excess water ingress, pump glands, seals, valve glands
Portable (diaphragm /other) pumps present
Hoses, fittings, and connections in areas  usage unknown
Unlocked overboard valves on bilge, bilge & ballast, salt water service
Seal management program-used
Designated clean or exempted areas  oil free status
Lifeboat / Security / Tender vessel engineering systems leak free
Lifeboat / Security / Tender vessel bilges clean
Lifeboat / Security / Tender vessel- oily bilge handling when leakages present ( when in use off vessel or
once reloaded)
Waste/Sludge oil incineration
Tests and inspections
Record keeping
Incinerator operates with sludge / waste oils
Clean / dirty furnace, evidence of use
Operators capable & prove operation
Purifier sludge tanks full / empty
Connections to bilge main or other areas
Transfer pump operable
Transfer pump to sludge system, ashore, incinerator settler only
Estimated quantities of sludge produced  normal or excessive (fuel sludge production can exceed 2% of
total fuel used)
Systems with Oil to Sea Interfaces
Oil lubricated stern tubes, bow and stern thruster seals, fin stabilizer seals, etc.
Exterior examination in way of systems for evidence of leaking seals
Presence of barrels, drums, hoses, pumps, and other equipment/supplies/arrangements necessary to refill
systems at equipment.
Check consumption records if SMS or environmental compliance programs require such records.






6

Section C2 
Gray Water Waste Stream 
Gray water system includes discharges from galley, sinks, washbasin drains, showers, and baths. These may be held in
large tanks before being pumped overboard. The handling and discharge of gray water will vary from ship to ship and the
marine inspector should ensure the procedures followed by the ship correspond to those described in its SMS
documentation. If gray water is pumped through a/the Marine Sanitation Device(s) (MSD), ensure that the total volume
does not exceed the MSD's capacity. Other waste streams such as hazardous waste or medical waste (RCRA
biomedical wastes) must not be mixed with gray water. Drains from hospitals (U.S. restriction), photo labs (if commingled
with hazardous wastes), slops, must be separate from the gray water system.
Sources
Galley (ex. Dishwashers, floor drains, sinks)                                          (Clean Water Act) 
Showers/Baths & washbasin drains                                                33 USC 1251 et seq.
Laundry                                                                   33 CFR 159.300
Subpart E for (D17)
Deck drains throughout vessel                                                    Local Regulations
Prohibited Sources (hazardous materials, bilges, photo shop & print shop if hazardous wastes are commingled,    ISM Code
hospital spaces (U.S. only), etc.)                                                           33 CFR 96 
Evidence of other drained fluids into scuppers or other entry points (photo lab, hospital, specialty spaces)
Drains from spaces containing machinery (fan rooms, hotel equipment, etc.) oil free or segregated
Connections to the Black Water System (if permitted in MSD Operation Manual, if so, is MSD capacity sufficient?)
Connections to Ballast Water System
Number of tanks
Total tank capacity ________________m3
Volume Produced_______________ (m3 per day)
Maximum number of days in port without discharging.
Current capacity sufficient for persons on board and time in port?
Review vessel's gray water handling procedures (SMS).
Ensure that Quality Assurance / Quality Control Plan is vessel specific.
Is Gray water processed and discharged?
What are Gray water disposal procedures: Shore and at Sea. (company policy)
Does vessel have sampling procedures? (if so, review)
Types of tests performed, equipment and useable testing supplies readily available?
Sampling equipment/supplies useable and available?
How often do they take samples? Review samples record book.
What are the state, federal and local regulations for gray water discharge?
Responsible crew interviewed
Disposal and Records
Shore (receipts available)
At sea (logs maintained)
Sampling/Testing (logs maintained)
Note some gray water treatment employs advanced ultra-filtration systems, these systems claim to
reduce gray water waste by 85% - 90%, or more.
Alaska - Effective July 2001, Operators of cruise vessels carrying 500 or more passengers & transiting
applicable waters of Alaska are restricted in where they may discharge effluents & will be required to
perform testing of sewage & gray water discharges. The Coast Guard will inspect, monitor, & oversee
this process to ensure compliance with applicable water quality laws & regulations. (33 CFR 159)





7

Section C3 
Black Water/Sewage Waste Stream 
Black water system includes MSDs and other systems to collect, treat, store, and discharge sewage. This checklist is
designed to guide the marine inspector through some basic questions to ascertain whether the system is working as
designed and that the crew is properly trained in its operation. For example, does the MSD appear to be properly
installed? Is there adequate capacity for the number of persons on board? Are maintenance procedures, including SMS
procedures, being followed? Are there records of expendables being ordered: filters, chemicals, et cetera? Are the units
operating within the manufacturer's design specifications? Are there clear and simple operating instructions? Is the crew
knowledgeable in the use of the equipment/system?
MARPOL Annex IV*
Sources                                                   40 CFR 140.3 & .4
Toilets, Urinals, scuppers                                                         33 CFR 159.57
All Drainage from Medical Premises (U.S. restriction)                                        33 CFR 159.7
System installed, maintained and operated in accordance with approved plans and manufacturers           33 CFR 159.55
specifications.                                                                     33 CFR 159.59
Tank Capacity and Volume Produced                                            MARPOL Annex IV/9*
Current volume in tanks                                                       40 CFR 140.3
Modifications documented                                                    MARPOL Annex IV/11 *
Resolution MEPC.2(VI)
33 CFR 159.65
Operations and Treatment (new section)                                             NVIC 9-82
Chemical/Biological treatment & protective equipment                                    ISM Code
Chemical Treatment Level                                                33 CFR 96
Sufficient chemicals, additives, approved cleaning materials onboard. (enzymes, "Gamazyme", chlorine)
Compressors operating, inlet filters maintained                                          33 CFR 159
Vacuum system operable, if applicable
Flow indicators clear  indicating flow
Last system cleaning
Macerator operating maintenance
Methods to dilute discharge?
Operating instructions/SMS procedures
U.S. Marine Sanitation Device Requirements
Type (II, III)
Nameplate (Should be designed to resist efforts of removal or efforts to alter the information)
Placard                                                                       MARPOL Annex IV/2*
Proper operation (macerators, treatment chemicals) and structural integrity, no leaks                   MARPOL Annex IV/10*
Certificate of Type Test. For Foreign Flag Vessels in U. S. Waters 
A foreign flag vessel that has a "Certificate of Type Test" under MARPOL Annex IV indicating that its sewage
treatment plant meets the test requirements of Resolution MEPC.2 (VI) of the International Maritime         MARPOL Annex IV*
Organization (IMO) will be accepted by the Coast Guard as being in compliance with 33 CFR 159.7(b) or (c). The  33 CFR 159.7
Certificate of Type Test must be issued by or on behalf of a government that is a party to the MARPOL       40 CFR 140.4
convention. Such a plant will be considered as fully equivalent to a Coast Guard certified Type II MSD as long  40 CFR 136
as the unit is in operable condition. However, the unit may not be labeled as USCG certified. U.S. registered
vessels will continue to be required to have Coast Guard certified MSDs per 33 CFR 159.
Standard Discharge Connection (NLT 27 Sep 03)
New ships 200 gross tons and above
New ships less than 200 gross tons and carry more than 10 persons.
Existing ships 200 gross tons and above and exiting ship less than 200 gross tons and carry more than 10
persons after 27 Sep 13 (10 years after the date entry into force of Annex IV)
Disposal
Shore (last done, reasons?)
Overboard valves secured
MSD bypass piping noted? (Condition of valves, pipe tees and caps, evidence of frequent usage)
At sea (provide proof of discharge location)
Logged position, speed (if required by management) MARPOL Annex IV*
When comminuted and disinfected greater than 3 miles. 33 CFR 159
Company policy followed?
When not comminuted or disinfected greater than 12 miles.
Both to be discharged while ship is underway at greater than 4 knots.
Locations of discharges compared to deck logs.
Not in EPA "No Discharge Zones"
Connections to the gray water system (effluent routed to gray water system to dilute effluent?)
8

Alaskan Waters:
Effective July 2001, Operators of cruise vessels carrying 500 or more passengers and transiting applicable
waters of Alaska are restricted in where they may discharge effluents and will be required to perform testing
of sewage and gray water discharges. The Coast Guard will inspect, monitor, and oversee this process to
ensure compliance with applicable water quality laws and regulations. (33 CFR 159).
Sampling/Testing
Lab analysis of fecal coliform/total suspended solids in effluent (recorded on ISPP if issued)
Results of residual chlorine content in effluent testing
Calibration records for dosing pump/proportioner
* Although the United States is not signatory to MARPOL Annex IV, the requirements of Annex IV may be enforced for
those vessels that have committed to comply with Annex IV requirements in addition to 33 CFR Part 159 requirements
as part of the vessels' SMS. This commitment is typical for ICCL Member vessels and many other cruise ships.



















9

Section C4 
Hazardous Waste Stream 
Hazardous waste must be handled in accordance with the ship's SMS. If such waste is disposed of in U. S. waters, the
SMS hazardous waste handling procedures must meet or exceed 40 CFR Part 262 requirements. Hazardous waste
includes dry cleaning (PERC) waste, used paints and thinners that contain hazardous substances, silver-bearing photoprocessing
waste, cleaning solutions and other similar items. Each vessel may vary in both the type and volumes of
hazardous waste generated depending on the technology and processes aboard ship. This checklist is designed to
evaluate on-board management of hazardous waste streams and to ensure that hazardous constituents are not released
into the environment, disposed of properly and that accountability is demonstrated via adequate waste disposal records.
Hazardous Waste                                           40 CFR 262
49 CFR 173
RCRA
Has the company conducted a waste determination? Through Process Knowledge or Waste Analysis      SARA Title III
(circle one)? If not, hazardous waste may not be landed.                                   42 USC 11002(a)(3) 40
Have responsible personnel received initial and refresher training? Has the training been documented?     CFR 355 App A / B ISM
Code
Is there any evidence that hazardous wastes are being incinerated, diluted, neutralized, or evaporated as
a means of disposal.                                                         33 CFR 96
Is there any evidence (e.g. lack of disposal records) of hazardous material being discharged overboard?
Are hazardous wastes being properly stored, maintained, labeled, and placarded? Note any observations
made of deficiencies, dates and nature of repairs.
Are proper storage devices available?
Waste not commingled
Quantities on board consistent with receipt/disposal documentation?
Does the crew have ready access to spill control and decontamination equipment?
Are records maintained and manifests completed for potential hazardous waste streams, for example:
Silver Bearing Photo Processing Waste (developers, wash water, Silver Recovery Units)
X-Ray equipment
Print Shop Waste (inks, dyes, cleaning solvents)
Used Solvents, Paints & Thinners
Fluorescent/Mercury Vapor Bulbs
Batteries (universal wastes): Nickel Cadmium (Nicad); Lead Acid; Lithium; Alkaline
Certain Pharmaceuticals/Narcotics
Dry Cleaning Waste (PERC, lint, sludge, filters, condensate water)
Aerosol Cans
Cleaning Solutions (de-scalers, acids, bases, other corrosives)
Expired pyrotechnics (from safety equipment and entertainment use)
Rags contaminated with hazardous wastes (also - in approved storage containers?)
Incinerator ash if contaminated with toxic/hazardous substances (plastics containing heavy metals)
Do records reflect reasonable accumulations of waste with respect to the capacity of the vessel, its age,
technologies onboard, and amounts of repair/maintenance?
Used lead acid batteries not mixed and kept dry?
Records of hazardous consumables kept updated                  Shipboard Records
Used and unused                                                       ISM Code
33 CFR 96
The following excerpt from 40 CFR 262 regarding Resource Conservation and Recovery Act (RCRA) requirements is
provided for background information only. The Federal or State RCRA program office must be consulted if any
clarifications are needed for a particular situation.
HAZARDOUS'WASTE HANDLING REQUIREMENTS
262.11 Hazardous waste determination.
A person who generates a solid waste, as defined in 40 CFR 261.2, must determine if that waste is a hazardous waste using the following method: (a)
Determine if the waste is listed as a hazardous waste in subpart D of 40 CFR part 261.
(c) Or if not listed in subpart D of 40 CFR part 261, generator must determine if the waste is identified in subpart C of 40 CFR part 261 by either:
(1) Testing the waste according to the methods set forth in subpart C of 40 CFR part 261
(2) Applying knowledge of the hazard characteristic of the waste in light of the materials or the processes used.


10

262.12 EPA identification numbers.PA identification numbers.
(a) A generator must not treat, store, dispose of, transport, or offer for transportation,(a) A generator must not treat, store, dispose of, transport, or offer for transportation, hazardous waste without having received an EPA identification
number from the Administrator.
262.20 General requirements.
(a)       A generator who transports, or offers for transportation, hazardous waste for offsite treatment, storage, or disposal must prepare a
Manifest OMB control number 2050-0039 on EPA form 8700-22, and, if necessary, EPA form 8700-22A, according to the appendix to part
262.
(b)       Generator must designate on manifest one facility that is permitted to handle the waste described on the manifest.
262.23 Use of the manifest.
(a) The generator must:
(1) Sign the manifest certification by hand; and
(2) Obtain the handwritten signature of the initial transporter and date of acceptance on the manifest; and
(3) Retain one copy, in accordance with  262.40(a) and give the transporter the remaining copies of the manifest.
262.30, .31, .32 & .33 Packaging, Labeling, Marking and Placarding.
Before transporting hazardous waste or offering hazardous waste for transportation off-site, a generator must package, label, mark and placard the
waste in accordance with the applicable Department of Transportation regulations on packaging under 49 CFR parts 172, 173, 178, and 179. Before
transporting hazardous waste or offering hazardous waste for transportation off-site, a generator must mark each container of 110 gallons or less used
in such transportation with the following words and information displayed in accordance with the requirements of 49 CFR 172.304: HAZARDOUS
WASTE Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental
Protection Agency. Generator's Name and Address -------------. Manifest Document Number ---------------.
262.34 Accumulation time.
A generator may accumulate hazardous waste on-site for 90 days or less for large quantity generator and 180 days or less for small quantity generator,
without a permit or without having interim status.
The date upon which each period of accumulation begins must be clearly marked and visible for inspection on each container and while being
accumulated on-site, each container and tank is labeled or marked clearly with the words, "Hazardous Waste."
262.40 Recordkeeping.
(a) A generator must keep a copy of each manifest signed in accordance with  262.23(a) for three years or until he receives a signed copy from the
designated facility which received the waste. This signed copy must be retained as a record for at least three years from the date the waste was
accepted by the initial transporter.
(b) A generator must keep a copy of each Biennial Report and Exception Report for a period of at least three years from the date of the report.
(c) A generator must keep records of any test results, waste analyses, or other determinations made in accordance with  262.11 for at least three years
from the date that the waste was last sent to on-site or off-site treatment, storage, or disposal.















11

Section C5 
Non-Hazardous Waste Stream 

Non-hazardous wastes include shipboard garbage containing plastics and synthetic material, certain medical wastes,
food wastes and recyclables such as glass, cardboard, aluminum and metal cans. Items to be checked should include
waste sorted to prevent hazardous waste from entering the non-hazardous waste stream; no plastics or synthetics are to
be discharged overboard, separate; proper disposal of hazardous (i.e. containing residual plastics or un-burnt food
waste) and non-hazardous incinerator ash; and proper disposal of cooking grease from grease traps.

Shipboard Garbage Management Plan                                 33 CFR 151.63
MARPOL Annex V
Shipboard garbage properly handled in accordance with Garbage Management Plan                  MARPOL Annex V/9
Garbage Record Book entries                                                 MARPOL Annex V/3
Type, amount, location, date/time                                                 7 CFR 330.400
Receipts
Each entry signed by Officer-in-Charge and each page by Master
Any reports of alleged inadequacy of port reception facilities for garbage on file
Person-in-Charge Designated
No plastics or synthetics discharged overboard
Waste sorted to prevent hazardous waste entering non-hazardous waste stream or incinerated. Separate
defined storage areas for hazardous/non-hazardous  no commingled waste.
Signage in working language of crew and in English, French or Spanish
Incinerator ash if discharged overboard free of plastic residue (clinkers) or free of unburned food wastes if
landed ashore.
Trash chutes clean, free from oil residue (No oil stains on decks, side of hull adjacent to trash chutes)
Foreign Food Wastes handled per APHIS regulations
Medical Wastes-incinerated or manifested as Bio-Hazardous Waste.
Discharged outside of special areas only (when special area restrictions are in effect)
Incinerator operation observed (if in operation)
MARPOL Annex V/
33 CFR 151
Garbage Pollution Placards posted
Procedures to minimize amount of potential garbage
Is vessel encouraging ship suppliers to consider alternate means of packing, use of other than plastics?
Examine stores being loaded.
Is vessel using reusable packing? Examine stockpiles for use
Is waste generated while in port disposed to shore reception facility prior to sailing? Examine waste being
offloaded.
Recycling
Is ships crew following policy for recycling. Interview crewpersons in varied work areas, casino, galley,
housekeeping, etc. with recycling responsibilities for procedures used.
Maintenance and repair conducted on equipment
Incinerator
Grinders
Valves and flappers on chutes
Human factors
Warning signs posted around equipment.
Master and crew familiar with essential shipboard garbage handling procedures.
Personal protective equipment available, functioning and in place (ILO 134).
Sanitation, from a health standpoint, being maintained (ILO 147).






12

Glossary of Terms
AGENT
Vessel representative hired by the ship's owners. Ship's agent may be tasked with various jobs such as: ensuring
proper vessel documentation and compliance.
AUTOMATIC STOPPING DEVICE
Is a control mechanism that ensures discharge of an oily water separator is stopped when the oil content of the
effluent exceeds 15 parts per million (PPM). The automatic stopping device may be initiated by the operation of the
oil content meter.
BALLAST
Used to improve the stability and control the draft of a ship. (In Ballast - having only ballast for a load)
BLACK OIL
A viscous and black or very dark brown colored oil. Depending on the quantity spilled, oil tends to quickly spread out
over the water surface to a thickness of about one-millimeter.
BLACK WATER (sewage)
Examples - possible sources toilets, urinals and drainage from medical facilities (U.S. restriction).
COC
Certificate of Compliance, CG Form 3585.
COTP
Captain of the Port.
CWA
Clean Water Act.
CVE
Control Verification Examination is the examination of vessel for compliance with SOLAS requirements and applicable
U. S. regulations. More properly referred to as the Passenger Vessel Certificate of Compliance Examination.
DISPERSION
The breaking up of an oil slick into small droplets which are mixed into the water column as a result of breaking waves
and other sea surface turbulence.
EFFLUENT
To flow out. (Waste material, refuse, and sewage)
EMULSIFICATION
The formation of a water - in - oil mixture. In the environment, the tendency for emulsification to occur varies with
different oils and is much more likely to occur under high-energy conditions (wind and waves). Emulsions may also
be formed by surfactants, including detergents, which cause the oil and water to mix, or by mechanical means such
as pressure washing or pump action.
EPA
Environmental Protection Agency
EQUIPMENT HAVING AN OIL TO SEA INTERFACE
Equipment that uses a seal to prevent leakage of oil into the sea. Examples, oil-lubricated stern tube seals,
hydraulically-driven stabilizer fin seals, bow and stern thruster seals. An indicator that system seals are leaking to the
sea may be evidence of frequent filling of system reservoirs, presence of barrels, drums, hoses, pumps, and other
equipment/supplies/arrangements necessary to refill systems. Some ships' SMS or environmental compliance
programs may require that records of refilling such systems are kept. If so, these records should be checked.

13

15 PPM ALARM
An alarm that activates when the effluent passing though oil-filtering equipment exceeds 15 parts per million (ppm) of
oil.
GRAY WATER
Includes discharges from galley, sinks, washbasins, drains, showers and baths. These may be held in large tanks
prior to being discharged overboard (State, Fed, regulation permitting).
HSSC
International Convention to Harmonized System of Survey and Certification.
ICCL
International Council of Cruise Lines, a cruise ship industry association which participates in industry standards and
policy development process to promote all measures that foster a safe, secure, healthy cruise ship environment.
ICLL
International Convention for Load Lines.
IMO
International Maritime Organization; a specialized agency of the United Nations concerned solely with maritime
affairs. IMO is responsible for international treaties, conventions, resolutions and codes to improve maritime safety.
ISM Code
International Safety Management Code. (Chapter IX of SOLAS)
MARPOL
The International Convention for the Prevention of Pollution from Ships, 1973 as modified by the Protocol of 1978.
MSC
Maritime Safety Committee. One of five technical committees of the IMO which deals with issues such as aids to
navigation, vessel equipment and construction, manning requirements, handling dangerous cargoes, hydrostatic and
marine casualty information.
MSD
Marine Sanitation Device.
OIL CONTENT METER
An instrument used to measure continuously the oil content of the effluent in the OWS output line, in parts per million,
to ensure that the operation does not contravene the convention.
OIL FILTERING EQUIPMENT
Equipment that uses any combination of a separator, filter or coalescer, and also a single unit designed to produce an
effluent with oil content less than 15 parts per million (ppm). (MARPOL Annex I, Reg 16)
OILY WATER SEPARATOR (OWS)
The basic principle of oil / water separation is their difference in specific gravity. The specific gravity of most oils is
less than water; therefore, it will naturally float to the top of an oil and water solution. Small droplets of oil float to the
top much slower than large droplets. This is due to the large surface area to mass ratio. To speed up the process of
separation, OWS units form larger oil droplets out of smaller ones, thus decreasing the surface area to mass ratio.
The increased mass of the oil droplet increases its buoyancy, thus causing it to rise more quickly. Gravitational-based
systems are not effective processors of oil-water emulsions formed by detergents or mixtures containing high specific
gravity oils.
PASSENGER SHIP
A ship which carries more than 12 passengers.
PMS
Preventative Maintenance System
QUALIFIED INDIVIDUAL (QI)
The person authorized by the responsible party to act on their behalf, authorize expenditures and obligate
organization's resources.

14

RCRA
Resource Conservation and Recovery Act (RCRA), was enacted by the U.S. in 1976 to address the issue of how to
safely manage and dispose of the huge volumes of municipal and industrial hazardous waste generated nationwide.
RECOVERABLE OIL
Oil that is in a thick enough layer on the water to be recovered by conventional techniques and equipment. Only black
or dark brown oil, mousse, and heavy sheens (dull brown) are generally considered thick enough to be effectively
recovered by skimmers.
SEPARATION EQUIPMENT
A device designed to remove enough oil from an oil-water mixture to provide a resulting mixture with an oil content of
less than 100ppm, or 15ppm, such as an Oily Water Separator (OWS).

SLICK
Oil spilled on the water, which absorbs energy and dampens out the surface waves making the oil appear smoother or
slicker than the surrounding water.
SHEEN
A sheen is a very thin layer of oil (less than 0.0001 inches or 0.003mm) floating on the water surface and is the most
common form of oil seen in the later stages of a spill. According to their thickness, sheens vary in color ranging from
dull brown for the thicker layers to rainbows, grays silvers and almost transparent for the thinnest layers.
SLUDGE TANKS
Tanks used to contain sludge formed by fuel and lube oil purifiers and from other sources or cleaning activities.
Sludge is not readily processed by many oily water separators and frequently requires treatment ashore or
incineration. Every ship of 400 GT or more must be provided with a tank or tanks of adequate capacity, in regard to
type of machinery and length of voyage, to receive the oil residues (sludge) that cannot be dealt with otherwise in
accordance with MARPOL Annex I.
SMS
Safety Management System (sometimes referred to as an SQM). Required by the ISM Code and Chapter IX of
SOLAS.
SOLAS
Safety of Life at Sea. The International Convention for the Safety of Life at Sea.
SOPEP
Shipboard Oil Pollution Emergency Plan. (MARPOL Annex I, Reg. 26)
STCW
The International Convention on Standards of Training, Certification and Watchkeeping for Seafarers.
TANKER
Is a self-propelled vessel constructed or adapted for the carriage of bulk liquid cargoes of oil or hazardous materials.
TRANSFER
Any movement of oil or hazardous material to, from or within a vessel by means of pumping, gravitation, or
displacement.





15

Appendix v
MEMORANDUM SUBJECT: Cruise Ship Identification Numbers and State Required
Annual Reporting Components
FROM: Elizabeth Cotsworth, Director Office of Solid Waste
TO: RCRA Senior Policy Managers
Regions 1-10
Over the last several months, the Environmental Protection Agency (EPA), Office of Solid
Waste has been working with Region 4, Region 9, Region 10, and ten states having cruise ship
traffic to facilitate national acceptance of one EPA hazardous waste identification (ID) number
per individual cruise ship. This came about because the ships were receiving different numbers
from each state in which hazardous waste was off-loaded. Having multiple identification
numbers causes the ships to create and maintain duplicate copies of hazardous waste
management records, leading to an increased paperwork burden.
Through meetings and conference calls, the participants on this project reached an agreement on
the issue. Today, we are asking that individual cruise ships be assigned only one EPA hazardous
waste identification number as a generator of hazardous waste for purposes of the Resource
Conservation and Recovery Act. The following procedures would apply:
a) A cruise ship would determine its American-based home port state (the state in which it has
corporate offices or its main port of call).
b) After determining the home port state, the cruise line will notify the selected state or
corresponding EPA regional office of its hazardous waste activities. c) The cruise ship will
identify its hazardous waste generator size in accordance with 40 CFR 261.5(c).
d) The home port state or EPA regional office will issue an EPA hazardous waste identification
number for each individual cruise ship using the current established procedure. The number will
reflect the home port state initials and ten alphanumeric characters.
We are recommending that the state or region consider using a ship = s registry number, which is
known as the International Maritime Organization (IMO) number, as part of the EPA hazardous
waste identification number. The IMO number is generally a five to seven digit number; zeros
can be added before or after the number to reach the ten characters required for the EPA
hazardous waste identification number. Using the IMO number will allow for coordination with
the Coast Guard, as this is the number they use most often.
After the identification number is assigned, it will remain with that ship and be used on all
hazardous waste manifests regardless of where the waste is off-loaded in the U.S. The
assignment of the EPA ID number will not impact the applicability of state-specific RCRA
requirements. For example, when waste is off-loaded in a state, the cruise ship will comply with
that particular state = s RCRA requirements whether or not that state assigned the ID number. 
The ship will be required to provide records to the individual state as required by state law.

Many of the states who will not be issuing the ID number expressed an interest in obtaining

information provided by the cruise ship in either an annual or biennial report to its home port
state. This request for annual report information can be addressed through the existing Biennial
Reporting System (BRS). The attachment to this memo provides more specific information on
how the ID numbers and annual reports will be incorporated into the EPA = s BRS databases.
If you have any questions, please contact Teena Wooten at (703) 308-8751.
Attachment (1)
cc: Key RCRA Contacts, Regions 1 - 10
RCRA Enforcement Contacts, Regions 1 - 10
RCRA Data Management Contacts, Regions 1-10
Tom Kennedy, Association of State and Territorial Solid Waste
Management Officials (ASTSWMO)
Anne Dobbs, Texas Natural Resource Conservation Commission (TNRCC)

Dangerous Waste Site Identification Form                 Site ID
Washington State Department of Ecology
Hazardous Waste Information                   For Ecology Use Only  Date Received:
P.O. Box 47658                          Form      Reviewed     Entered      Verified
Olympia, WA 98504-7658                   Site ID
(800) 874-2022 (within state)                   GM
(360) 407-6170                          WR
OI
Web site: www.ecy.wa.gov/programs/hwtr 
1. Reason for Submittal
To provide New Notification of Regulated Waste Activity (complete entire form)
To provide Revised Site Identification information (complete entire form)
To Withdraw Site Identification Number (skip sections 10 and 11)
To Reactivate Site Identification Number (complete entire form)       Effective Date: __________ (mm/dd/yyyy)
A component of the Dangerous Waste Annual Report (skip section 11)     Reporting Year: __________ (yyyy)
2. RCRA Site ID Number:
3. Site Location Information
Company Name: ________________________________________________________________________________________________ 
Site Address: ________________________________________________________________________________________________
City/State/Zip: ________________________________________________________________________________________________
County: ________________________________________________________________________________________________
Tax Registration Number: ________________________________________________________________________________________________
NAICS Code: ________________________________________________________________________________________________
Type of Business: ________________________________________________________________________________________________
4. Company Mailing Address
Name: ________________________________________________________________________________________________
Mail Address: ________________________________________________________________________________________________
City/State/Zip: ________________________________________________________________________________________________
Country: ________________________________________________________________________________________________
5. Legal Owner
Name: ________________________________________________________________________________________________
Mail Address: ________________________________________________________________________________________________
City/State/Zip: ________________________________________________________________________________________________
Phone Number (Ext):  (_____) ________________________________________________________________ ________________________
Owner Since:  _______________________ (mm/dd/yyyy)
Owner Type:   Federal  State  County  Municipal
District   Private   Tribal   Other
6. Land Owner
Name:
________________________________________________________________________________________________
Mail Address:
________________________________________________________________________________________________
City/State/Zip:
________________________________________________________________________________________________ 
Phone Number (Ext):
(_____) ________________________________________________________________________________________ 
Owner Type:
Federal  State  County  Municipal
District   Private   Tribal Land
Puyallup Trust  Other

Dangerous Waste Site Identification Form (continued)             Site ID
RCRA Site ID Number:
7. Site Operator
Name: _________________________________________ _______ _ __________________________________________ 
Mail Address: ________________________________________________________________________________________________
City/State/Zip: ________________________________________________________________________________________________ 
Phone Number (Ext):  (_____) ________________________________________________________________________________________
Operator Since:  _______________________ (mm/dd/yyyy)
Operator Type:    Federal  State  County  Municipal
District   Private   Tribal   Other
8. Site Contact
Name: _________________________________________ _______ ___ ________________________________________ 
Mail Address: ________________________________________________________________________________________________
City/State/Zip: ________________________________________________________________________________________________
Phone Number (Ext):  (_____) ________________________________________________________________________________________
Email Address: ________________________________________________________________________________________________
9. Form Contact
Name: _________________________________________ _______ ___________________________________________ 
Mail Address: ________________________________________________________________________________________________
City/State/Zip: ________________________________________________________________________________________________
Phone Number (Ext):  (_____) ________________________________________________________________________________________
Email Address: ________________________________________________________________________________________________
10. Type of Regulated Waste Activity (Mark the appropriate boxes for activities that apply to your site) 
A. Hazardous Waste Activities 
1. Generator of Hazardous Waste                         10. Treatment, Storage, Disposal or Recycling (TSDR)
(Choose only one of the following four categories)           Facility
a. LQG: Large Quantity Generator (Greater than 2,200         (Note: A RCRA Permit is required for this activity)
lbs/mo)                                        11. 24-Hour Recycler of Off-Site Waste
b. MQG: Medium Quantity Generator (Between 220  2,200     (i.e., Immediate Recycler)
lbs/mo)                                       12. Dangerous Waste Fuel Activity 
c. SQG: Small Quantity Generator (Less than 220 lbs/mo)        a. Generator of dangerous waste fuel
d. XQG: No Regulated Waste Generated                 b. Generator marketing to burner
2. Frequency of Generation                                 c. Other marketers (i.e., blender, distributor, etc.)
(Choose only one of the following three types)            d. Burner (indicate type of combustion unit)
a. Monthly                                         1. Utility boiler
b. Batch                                           2. Industrial boiler
c. One-time only                                      3. Industrial furnace
3. Transporter of Hazardous Waste                       e. Deferrals/Exemptions (in federal registry only)
a. Transport own waste                                1. Smelter deferral
b. Transport for commercial purposes                        2. Small quantity exemption
4. Recycler of On-Site Waste                               3. Other (specify):
(i.e., on-site use, reuse or reclamation of a waste after it has
been generated)
5. Transfer Facility of Hazardous Waste 
6. Permit-by-Rule (PBR)
7. Treatment-by-Generator (TBG)
8. Generator of Mixed Radioactive Waste
9. Importer of Hazardous Waste

Dangerous Waste Site Identification Form (continued)             Site ID
RCRA Site ID Number:
B. Universal Waste Activities                         C. Used Oil Activities
1. Large Quantity Handler of Universal Waste              1. Off-specification used oil burner Indicate type(s) of
(Mark all boxes that apply)                    combustion devices
1. Utility boiler
2. Industrial boiler
Generate Accumulate 
3. Industrial furnace
a. Batteries                                        2. Used oil transporter Indicate type(s) of activity(s)
b. Mercury containing                                  a. Transporter
thermostats                                      b. Transfer facility
c. Lamps                                   3. Used oil processor/re-refiner Indicate type(s) of activity(s) 
a. Process
2. Destination Facility for Universal Waste                   b. Re-refine
(Note: A RCRA Permit is required for this activity)             4. Used Oil Fuel Marketer
a. Directs shipment of used oil to used oil burner
b. First claims the used oil meets the specifications
11. Description of Hazardous Wastes
A. Waste Codes for Federally Regulated Hazardous Wastes: Identify those codes that best describe your waste. (e.g., D001  Ignitable, D002 
Corrosive, D003  Reactive, etc.)


B. Waste Codes for State Regulated (i.e., non-Federal) Hazardous Wastes: Identify those codes that best describe your waste. (e.g., WT02 
Toxic, WP02  Persistent, WL02  Labpack, WSC2  Solid Corrosive, etc.)


12. Comments



Additional sheets may be attached for comments if needed. 
13. Certification                                    This form cannot be processed without a signature
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there
are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

______________________________________________ __________________________________________
Signature                                         Date 

______________________________________________ __________________________________________ 
Name (print or type)                                      Title
If you have special accommodation needs or require this document in an alternative format, please contact the Hazardous Waste and
Toxics Reduction Program at 1-800-833-6388 (TTY) or quick dial 711-833-6388 (TTY).
14. Electronic Submittals
I am interested in the electronic filing of my Dangerous Waste Annual Reporting and Site Identification information to Ecology over
the Internet. Ecology will issue a PIN number, along with electronic filing instructions, in a letter addressed to the Form Contact in
Section 9 on this form.

Appendix vi
Alaska Regulations
Title XIV  Certain Alaskan Cruise Ship Operations
SEC. 1404. LIMITATIONS ON DISCHARGE OF TREATED SEWAGE OR
GRAYWATER. 

(c) Until such time as the Administrator promulgates regulations under paragraph (b) of this
section, treated sewage and graywater may be discharged from vessels subject to this Title in
circumstances otherwise prohibited under paragraphs (a)(1) and (a)(2) of this section, provided
that
(1) the discharge satisfies the minimum level of effluent quality specified in 40 CFR
133.102, as in effect on the date of enactment of this Section;
(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% of the samples exceed 40 fecal
coliform/100 ml;
(3) concentrations of total residual chlorine may not exceed 10.0 g/l; and,
(4) prior to any such discharge occurring, the owner, operator or master, or other person
in charge of a cruise vessel, can demonstrate test results from at least five samples
representative of the effluent to be discharged, taken from the vessel on different days over a
30-day period, conducted in accordance with the guidelines promulgated by the
Administrator in 40 CFR Part 136, which confirm that the water quality of the effluents
proposed for discharge is in compliance with paragraphs (1), (2) and (3) of this subsection.
To the extent not otherwise being done by the owner, operator, master or other person in
charge of a cruise vessel pursuant to section 1406, the owner, operator, master or other
person in charge of a cruise vessel shall demonstrate continued compliance through periodic
sampling. Such sampling and test results shall be considered environmental compliance
records that must be made available for inspection pursuant to section 1406 (d) of this Title.
Title 40 CFR 133.102 Secondary treatment.
The following paragraphs describe the minimum level of effluent quality attainable by
secondary treatment in terms of the parametersBOD5, SS and pH. All requirements for each
parameter shall be achieved except as provided for in  133.103 and 133.105.
(a) BOD5.
(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.

(4) At the option of the NPDES permitting authority, in lieu of the parameter BOD5 and
the levels of the effluent quality specified in paragraphs (a)(1), (a)(2) and (a)(3), the
parameter CBOD5 may be substituted with the following levels of the CBOD5 effluent
quality provided:
(i) The 30-day average shall not exceed 25 mg/l.
(ii) The 7-day average shall not exceed 40 mg/l.
(iii) The 30-day average percent removal shall not be less than 85 percent.
(b) SS.
(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 maintained within the limits of 6.0 to 9.0 unless
the publicly owned treatment works demonstrates that: (1) Inorganic chemicals are not added
to the waste stream as part of the treatment process; and (2) contributions from industrial
sources do not cause the pH of the effluent to be less than 6.0 or greater than 9.0.

Appendix vii
Hazardous Waste Management 
This Appendix is to be used as guidance for hazardous waste discharged in Washington State
waters or landed ashore in Washington. The following is a list of Resource Conservation
Recovery Act (RCRA) and Washington State Criteria hazardous waste that may be found on
cruise ships, and appropriate guidance for its discharge or offloading from the ship.
Terms 
Hazardous Waste  Includes all hazardous waste as defined by RCRA and Chapter 173-303 of
the Washington Administrative Code (WAC), where Washington State Criteria hazardous waste
is defined.
Publicly Owned Treatment Works (POTW) - Ecology's Hazardous Waste Toxics Reduction
(HWTR) Program will acknowledge Advanced Wastewater Treatment Systems (AWTS) as a
substitute for a POTW. Type 2 Marine Sanitation Devices (MSDs) are not considered a POTW
for purposes of this MOU.
WASTE STREAMS 
Antifreeze- Excluded as a hazardous waste if recycled. (WAC 173-303-522)
Aqueous Degreasing - If the resulting waste is hazardous it can be treated to remove the hazard
and the resulting effluent can be sent to the AWTS or Oily Water Separator. If no treatment is
performed it can be landed ashore for proper disposal.
Batteries & Mercury Containing Thermostats - These are universal waste if sent for
recycling. (Ecology Publication Number 98-407, Universal Waste Rule for Batteries and
Mercury Containing Thermostats) 
Spent Lead Acid Batteries - Spent lead-acid batteries are conditionally excluded if recycled.
(WAC 173-303-520)
Cathode Ray Tubes (CRTs) - Excluded if recycled, otherwise are to be managed as a hazardous
waste. (Ecology Publication Number 02-04-017, Interim Enforcement Policy Conditional
Exclusion for Cathode Ray Tubes* and Related Electronic Wastes)
Dry Cleaner  Perchloroethylene (PERC) and other chlorinated dry cleaning fluids,
contaminated sludge and filter materials are hazardous waste and must be landed ashore in
accordance with RCRA requirements. 
Florescent Tubes - Handling procedures for fluorescent tubes do not allow for crushing of the
bulbs. (WAC 173-303-573 and Ecology Focus Sheet, Publication # 00-04-020, Universal Waste
Rule for Dangerous Waste Lamps)

HVAC - CFC's or HCFC's are excluded as a hazardous waste if recycled. (WAC 173-303-506)
Filters from HVAC units that use Halogenated Organic Compounds (HOC's) as fire retardants
would be a State Criteria hazardous waste and must be managed as such.
Mercury Switches - Are a hazardous waste and must be managed as such.
Painting - Discarded Paints & Cleanup Solvents. All spent paints and solvents must be
properly designated and if hazardous waste, managed as such.
PCB's - Regulated as a state hazardous waste if they come from transformers, capacitors and
bushings if PCB's are from 2ppm to 50ppm. If PCB's are above 50 ppm they must be managed
as a TSCA waste. (WAC 173-303-9940)
Pharmaceuticals - Drugs that designate as RCRA waste, but that are not controlled substances
must be sent ashore as hazardous waste. If the drug is a RCRA waste and a controlled substance,
contact the US Drug Enforcement Agency (DEA) about suitable destruction methods and then
manage the residue from destruction as a hazardous waste (disposal to water, regular garbage or
incineration would be illegal). If the drug is not a RCRA waste, regardless whether it is a
controlled substance or not, it can be incinerated on board or sent ashore for incineration at a
facility permitted to incinerate municipal solid waste. (WAC 173-303-071(nn))
Photo Waste - Silver can be removed from fixer and the resulting effluent would be allowed to
go to an advanced wastewater treatment system (AWTS), but not to graywater or to a Type 2
MSD. If the fluids can not go to the AWTS, they must be landed ashore in accordance with
RCRA requirements. (Ecology Publication 94-138R, A Guide For Photo Processors) 
Printer Wastes - Inks, solvents and rags, used for cleaning, will need to be properly designated,
and if hazardous waste, managed as such.
Spray Cans  Cans that are not empty must be properly designated, and if hazardous waste,
managed as such.
Solvent Degreasing - Solvents, when used, must be properly designated, and if hazardous waste,
managed as such.

Appendix viii

Regional Director
Washington State Department of Ecology
Northwest Regional Office
3190 160th Avenue SE
Bellevue, WA 98008-5452
Dear Director:
Re:  Washington Cruise MOU Compliance Report: XXXX (enter year) Cruise Season
Section 9 of the Memorandum of Understanding for Cruise Operations in Washington State
(signed XXX (enter signature date)), requires an annual submittal detailing the compliance with
the MOU for the each vessel within the NWCA that calls to a port in Washington for the
previous cruise season. Please accept this letter on behalf of XXX (name your cruise line) for
the XXXX (enter year) cruise season.
The following ships operated Washington waters during XXXX (enter year):
Name the ship or ships; list the port of call and the dates.
XXX's operations in Washington State addressed the following key provisions of the MOU as
follows:
Section 2.1 Wastewater Management. XXX managed its wastewater in compliance with this
section as follows:
[Choose one or more options as appropriate]
In compliance with Section 2.1.1 and 2.1.2, XXX held all treated and untreated gray and
black water while in Washington waters and did not discharge solid waste or oily bilge water
if not in compliance with applicable federal and state laws while in Washington waters. List
the ships that held their effluent and describe the type of treatment system each ship in this
category has. Based on a thorough review of ships' logs and records we certify that our
ship(s) complied with these provisions of the MOU. XXX will make these records available
to Ecology upon request.
In compliance with Section 2.1.3 (A), XXX submitted the information required to allow
discharge of treated wastewater one mile from berth to Ecology on XX date for the
following ship(s): -------. Describe the type of treatment system each ship in this category
has. Approval of the information was received from Ecology on XX date.
In compliance with Section 2.1.3 (B), XXX submitted information supporting its request to
discharge treated wastewater continuously to Ecology on XX date for the following ship(s) --

---. Describe the type of treatment system each ship in this category has. Approval to
discharge while at berth was received from Ecology on XX date.
Section 2.1.3 (C)(1-3) Shellfish and "upset" conditions. Based on a review of XXX ship's logs
and records, XXX certifies that we complied with the prohibition on discharging within 0.5
nautical miles of bivalve shellfish beds that are recreationally harvested or commercially
approved to harvest as identified annually by the Department of Ecology and that any "upset"
conditions were stopped and immediately reported to the Washington State Department of
Health.
Section 2.1.3 (C)(4-10) Other discharge approval requirements. Based on a review of XXX
ship's logs and records and other knowledge, XXX certifies that the requirements in this section
were met.
Section 2.1.4 Discharge of Residual Solids. Based on a review of XXX ships' logs and records,
XXX certifies that we complied with the prohibition on discharging residual solids coming from
any type of treatment system within 12 nautical miles from shore and within the Olympic Coast
National Marine Sanctuary. XXX will make these records available to Ecology upon request.
Section 2.2.1 through 2.2.4 Hazardous Waste Management. Based on a review of XXX ship's
logs and records, XXX certifies that Hazardous Wastes were managed in accordance with these
sections of the MOU. XXX will make these records available to Ecology upon request. Add a
description of how hazardous waste is managed while in Washington.
Section 6. Marine Mammal Protection Act, Invasive Species Act, and the Washington Ballast
Water Management Act. Based on a review of XXX ship's logs and records, XXX certifies that
the provisions of the above laws were implemented as required by these laws. XXX will make
these records available to Ecology upon request. Add a description of how compliance with
these laws was achieved.
Section 9. Immediate self-reporting to Ecology of any incidences of non-compliance with any
provisions of the MOU. Describe any incidences of non-compliance and when they were
reported to Ecology and any corrective actions taken.
I hereby certify that the above information is true and can be verified through documentation. If
you have any questions or concerns, please call me at XXX-XXX-XXXX.
Sincerely,

Name
Position/Title
Company

Appendix ix

Port within 60 days of receipt of the invoice. Upon expiration of the Agreement. any claim lor payment not
already made shall be submitted within 60 days alter the expiration date or the end of the fiscal year,
whichever is earlier.

Payment will be mailed to Ecology at the following address:

Dept. of Ecology
Cashlerlng Section
PO Box 5128
Lacey, WA 98509-5128

360-407-7096 Telephone
360-649-7193
din   1

RECORDS MAINTEME

The parties to this Agreement shall each maintain books, records, documents and other evidence which
sufficiently and property reect all direct and indirect costs expended by either party in the performance of the
service(s) described herein. These records shall be swject to inspection. review or audit by personnel of
both parties, other personnel duly authorized by either party. the Cities ol the State Auditor. and lederal
olllcials so authorized by law. All books. records, documents, and other material relevant to this Agreement
will be retained for six years after expiration and the Ofce of the State Auditor. lederal auditors. and any
persons duly authorized by the parties shall have lull access and the right to exam'ne any at these materials
during this period.
Records and other documents, in any medium, lumished by one party to this agreement to the other party,
will remain the property of the furnishing party. unless otherwise agreed. The receiving party may be required
to disclose records and documents, but will not disclose or make available this material to any third parties
without first giving notice to the iumishing party and giv'ng it a reasonable opportunity to respond. Each party
will utilize reasonable security procedures and protections to assure that records and documents provided by
the other party are not erroneously disclosed to third parties.

RI HT IN DATA

Unless otherwise provided, data which originates from this Agreement shall be Morks for hire' as dened by
the US. Copyright Act ol 1976 and shall be owned by Ecology. Data shall include. but not be limited to,
reports. documents, pamphlets, advertisements, books. magazines, surveys, studies, computer programs,
lilrns, tapes. and/or sound reproductions. Ownership includes the right to copyright, patent. register. and the
ability to transfer these rights.

W

The employees or agents of each party who are engaged in the periormance oi this Agreement shall
continue to be employees or agents ol that party and shall not be considered for any purpose to be
employees or agents of the other party.

A  E  ENT ALT    N AND AMENDMENTS

This Agreement may be amended by mutual agreement ol the parties. Such amendments shall not be
binding mless they are in writing and signed by personnel authorized to bind each ot the parties.

TERMINATION

Either party may terminate this Agreement upon 30 days' prior written notillcation to the other party. If this
Agreement is so terminated, the parties shall be liable only for performance rendered or costs incurred in
accordance with the terms 01 this Agreement prior to the ellectlve date of termination.

Page 2 cl 5

TERMINATION F     E

ii for any cause. either party does not fulll in a timely and proper manner its obligations under this
Agreement. or it either party violates any oi these terms and conditions, the aggrieved party will give the other
party written notice oi such lailure or violation. The responsible party will be given the opportunity to correct
the violation or laiiure within 15 working days. if iailure or violation is not corrected, this Agreement may be
terminated immediatety by written notice of the aggrieved party to the other.

DIPQ! ES

In the event that a dispute arises under this Agreement, it shall be datemtined by a Dispute Board in the
following manner. Each party to this Agreement shall appoint one member to the Dispute Board. The
members so appointed shalt jointty appoint an additional member to the Dispute Board. The Dispute Board
shall review the facts. agreement terms and applicable statutes and rules and make a determination oi the
dispute. The determination oi the Dispute Board shall be final and binding on the parties hereto. As an
alternative to this process. either oi the parties may request intervention by the Governor. as provided by
RCW 43.17.330, in which event the Governors process will control.

W
This Agreement is entered into pursuant to and under the authority granted by the laws oi the state oi
Washington and any applicable iederal laws.  The provisions of this Agreement shall be construed to
coniorrn to those laws.

in the event oi an inconsistency in the terms oi this Agreement, or between its terms and any applicable
statute or rule. the inconsistency shall be resolved by giving precedence in the following order:

a.  Applicable state and federal statutes and rules:
b.  Statement oi work; and
c.  Any other provisions oi the agreement. including materials incorporated by relerence.
EIQNMENT
The work to be provided under this Agreement, and any claim arising thereunder. is not assignable or
deiegable by either party in whole or in part. without the express prior written consent oi the other party. which
consent shall not be unreasonably withheld.

WVER

A taiiure by either party to exercise its rights under this Agreement shall not preclude that party lrom
subsequent exercise of such rights and shall not constitute a waiver of any other rights under this Agreement
unless stated to be such in a writing signed by an authorized representative oi the party and attached to the
original Agreement.

M
ii any provision of this Agreement or any provision of any document 'ncorporated by reference shall be held
invalid. such invalidty shall not affect the other provisions of this Agreement which can be given effect without
the invalid provision, it such remainder conforms to the requirements oi applicable law and the fundamental
severabie.
purpose of this agreement, and to this end the provisions of this Agreement are declared to be



Page 3 of 5

ALL WRITIN QQNTAINED HEREIN

This Agreement contains all the terms and conditions agreed upon by the parties. No other understandings,
oral or otherwise. regarding the subject matter of this Agreement shall be deemed to exist or to bind any at
the parties hereto.

COUN'I'ERPARTS
This Agreement may be executed in counterparts, each of which may have the signature of only one Party,
but each of which shall be deemed to be an original. and all of which. when taken together. shall be deemed
to be a single Agreement.

ENTRAQ! MANAQEMENT

The program manager for each of the parties shall be responsible for and shall be the contact person for all
communications and billings regarding the pedorrnance oi this Agreement.

The Contract/Program Manager for Ecology is:        Kevin Fitzpatrick
Department of Ecology
Northwest Regional Ofce
3190 160" Avenue SE
Bellewe, WA 980086452
(425) 649-7033
E-mail: klit4610ecy.wa.gav

The Contract/Program Manager tor Port of Seattle is:    Michael McLaughlin
General Manager. Cruise and Dock SoNices
Port 0! Seattle
PO. Box 1209
Seattle. WA U.S.A. 98111
Phone:(206)728-3453
E-mail: mclaughlinmeportseatlleorg

IN WITNESS WHEREOF. the parties have executed this Agreement.


State of Washington
Department of Ecology

David C. Peeler,    ger
Water Quality Program





Page 4 of 5

Port of Seattle

~
AM 44/50
|                               Date
6'" Tay Y .
Chief Executive Officer



APPROVED AS TO FORM:

ATTORNEY GENERAL'S OFFICE

Susan Ridgley. Senior Pon Counsel
WW



Page 5 of 5

2007 Agreement

ATTACHMENT A

Department of Ecology/Port of Seattle

Cruise Ship Memorandum of Understanding Scope of Work

The Department of Ecology (Ecology), the Port of Seattle, and the NorthWest CruiseShip
Association (NWCA) are signatory to the Memorandum of Understanding, Cruise Operations in
Washington State (MOU). Originally the MOU was signed April 20, 2004 and thereafter
annually amended. The member cruise lines of the NWCA agree to comply with practices,
while operating in waters subject to the MOU. pertaining to the management of solid and
hazardous wastes and wastewaters. Ecology is charged with protecting and conserving
Washington's environmental resources in relation to the cruise industry's environmental
practices in Washington. The NWCA has agreed to fund Ecology's costs to implement the
'
MOU and to accomplish the tasks listed herein.

Task 01
Compliance Work:
Work with stakeholders on drafting necessary amendments to cruise MOU. Provide
technical assistance for cruise lines and vessel staff. Field questions from the public,
press, environmental groups. and cruise lines. Monitor compliance with the MOU.
Work with other programs within Ecology on hazardous waste, biosolids, solid waste,
spill prevention. and other MOU elements. Work with Ecology policy and scal staff on
cruise related issues. Research issues related to vessel discharges. Evaluate. draft and
update guidance on Whole Effluent Toxicity (WET) testing for cruise ships and evaluate
WET testing results. Work with Department of Health Shellsh program on shellfish and
virus related studies and issues. Manage and update Ecology's cruise ship website.

Task 02
Inspections:
Conduct annual inspections of cruise vessels to verify the operation of the treatment
systems and to evaluate compliance with the MOU. Write up inspection reports and
provide recommendations for improvement. Take samples from vessels and evaluate
results.

Task 03
Wastewater Discharge Approvals:
Verify documentation submitted for approval of discharges. Evaluate documentation and
treatment systems for requirements of MOU to discharge and based on the information
submitted and an engineering review, provide approval for discharges as appropriate.

Task 04
Annual Reports:
Draft annual assessment of cruise ship environmental effects report. Evaluate monthly
sampling data results and summarize annually.

Task 05
Project Management:
Oversee the cruise ship MOU program and assist as needed. Provides Administrative
oversight for compliance with the MOU, represents senior program management in duties
related to protection of water quality from cruise ship discharges including negotiations.

Task 06
Additional tasks may become part of this agreement by mutual concurrence of Ecology
and the Port of Seattle. or upon extension of the agreement.

2007 Agreement

Attachment B

Department of Ecology / Port of Seattle

Cruise Vessel Wastewater Treatment Inspections
Budget, by Object

The following is a detail breakdown of the salary, benefits and other costs of the Department of
Ecology staff who will be funded under this agreement.

OBJECT                             COST

1.  Salary:
Environmental Specialist 5 (E35) $54,840 x .36 F113 =          $ 19,743
Environmental Engineer 4 (E4) $77,520 x .10 FTE =          $ 7,752
WMS Band 2 (WMSZ) $75.9M x .05 FI'E =               3 3,796
Total Salary:                                        $ 31,291

2.  Benets @ 28.2% of Salary:                                   5  8,824

3.  Indirect Costs @ 38.95% of Salary & Benefits (1):                  $ 7.812
(from 1/1/07 through 6/30/07)

Indirect Costs @ 35.78% of Salary & Benefits (l):              8 7,177
(from 7/ 1/07 through 12/31/07)

4.  Goods & Services @ $4,388 per budgeted FI'E:
ESS 54,388 x .36 FIE =                            S l, 580
E4 $4,388 x .10 ENE =                           $ 439
WMS2 $4,388 x .05 FI'E =                          S  219
Annual data summary =                            3 2,500
Annual report =                                   $ 10,000
Lab costs =                                      5 5,158
Total Goods & Services:                             $ 19,896

TOTAL      um

(I) Ecology's indirect rate, as approved by the federal cognizant agency (United States
Department of Interior) will apply. The approved FY07 rate for 7/1/06 through 6/30/07 was
38.95%. The current rate for 7/1/07 through 6/30/2008 is 35.78% of salaries and benets.

Appendix x
Bivalve Shellfish Beds 
Cruise ships that discharge treated sewage into Puget Sound under this MOU employ advanced
systems that treat sewage to a very high degree using a combination of filtration, biological
treatment, ultra-filtration, and disinfection. These systems are called Advanced Wastewater
Treatment Systems (AWTS). The ultra-filtration process effectively removes nearly all bacteria
from the treated sewage. However, viruses which tend to be smaller organisms may pass
through the ultra-filtration membranes but are typically destroyed by the disinfection unit.
The Centers for Disease Control & Prevention reported 18 norovirus outbreaks on cruise ships
in the Pacific Northwest since 2000. Cruise ships discharge into shallow waters along the
shipping lanes, near some commercial shellfish beds. Today, national standards provide little
guidance on setting shellfish closure zones based on viral risk and there is no reliable viral
indicator standard in part due to difficulties in sampling and testing for norovirus.
Because shellfish in Puget Sound and Admiralty Inlet are valuable resources for Washington
State, the Washington State Legislature commissioned the Washington State Department of
Health (DOH) Office of Shellfish and Water Protection (OSWP) to study the potential risk to
shellfish beds from virus contamination associated with cruise ship waste water discharges.
DOH contracted with the University of Washington School of Public Health and Community
Medicine to perform a risk assessment, which was completed in November 2007. The study used
a quantitative microbial risk assessment method coupled with water quality modeling in Puget
Sound. Some key findings of the study include:
When advanced wastewater treatment systems (AWTS) are functioning well, there is low
concern for viral illness. Adequate disinfection is the key to effective norovirus inactivation.
Loss of disinfection could lead to potentially unacceptable virus levels in water over shellfish
beds, even with the large dilution provided by ships under sail. However, using minimum
dilution factors for when ships are moving at least 6 knots along the current route, dilution is
estimated at 1,500,000:1 between the ship and the shore.
The UW study did not gather samples of norovirus concentrations in treated sewage from
cruise ships or in the salt water over shellfish beds. Norovirus remains non-culturable, so
there is very limited environmental data that is "norovirus specific." In response, UW
researchers used data for norovirus "surrogates" from other studies in their analysis.
Consumption data from Tribes that use shellfish beds closest to the path of cruise ships was
used in the risk analysis. These rates are higher than for the general population. Raw oyster
consumption rates were used as a conservative assumption for these areas.
The study included many conservative assumptions, but nonetheless concluded that well
functioning AWTSs would not lead to norovirus accumulation in shellfish beds such that the
median annual risk of potential illness to shellfish consumers from cruise ship discharges in
Puget Sound is less than 10,000,000:1. This compares quite favorably with the calculated
annual risk of norovirus illness from consumption of raw oysters in the general population,
which the UW researchers calculated as about 1,000:1.

As described above, the potential risk of viral contamination of shellfish beds from cruise ship is
extremely low when AWTS systems are functioning well. Additionally the geography of Puget
Sound and the configuration of shipping lanes provide most shellfish beds some protection from
potential contamination from passing ships. However, the signatories to the MOU understand
the importance of shellfish resources to Washington State and have agreed to take the actions
outlined on page ___ of the MOU to protect shellfish beds and human health while operating in
Washington MOU waters.

Appendix x
continued
Bivalve Shellfish Beds 
2008 Season
2008 Cruise Season Boundary Points
Id  Tract Name      LATITUDE      LONGITUDE         Id  Tract Name    LATITUDE      LONGITUDE
- -
1  Apple Tree Cove   47.81274089040  122.48047265700     47  Tyee Shoal    47.61916098460  122.48420272400
-                                                              -
2  Apple Tree Cove   47.81255672180  122.47941651600     48  Tyee Shoal    47.61865190330  122.48324910700
-                                                              -
3  Apple Tree Cove   47.81197112760  122.47872458000     49  Tyee Shoal    47.61814655430  122.48229042500
-                                                              -
4  Apple Tree Cove   47.81129443870  122.47812835500     50  Tyee Shoal    47.61761807860  122.48135871800
-                                                              -
5  Apple Tree Cove   47.81056937740  122.47758747000     51  Tyee Shoal    47.61718007830  122.48033341700
-                                                              -
6  Apple Tree Cove   47.80992145700  122.47684781100     52  Tyee Shoal    47.61670845870  122.47935532600
-                                                              -
7  Apple Tree Cove   47.80931916930  122.47604614700     53  Tyee Shoal    47.61609072620  122.47855854300
-                                                              -
8  Apple Tree Cove   47.80895286530  122.47498673900     54  Tyee Shoal    47.61543441750  122.47782569300
-                                                              -
9  Apple Tree Cove   47.80852971000  122.47419683400     55  Tyee Shoal    47.61469777070  122.47729421200
-                                                              -
10  Apple Tree Cove   47.80812779070  122.47315426700     56  Tyee Shoal    47.61394668260  122.47679893700
-                                                              -
11  Apple Tree Cove   47.80748647770  122.47257436300     57  Tyee Shoal    47.61317098590  122.47657100600
-                                                              -
12  Apple Tree Cove   47.80668065230  122.47239303200     58  Tyee Shoal    47.61237442300  122.47686659800
-                                                              -
13  Apple Tree Cove   47.80586169470  122.47237830900     59  Tyee Shoal    47.61162109430  122.47735159900
-                                                              -
14  Apple Tree Cove   47.80507505630  122.47246917900     60  Tyee Shoal    47.61083929010  122.47772883400
-                                                              -
15  Apple Tree Cove   47.80443177020  122.47321819700     61  Tyee Shoal    47.61005751060  122.47810617700
-                                                              -
16  Apple Tree Cove   47.80389497510  122.47389983000     62  Tyee Shoal    47.60927581650  122.47848390200
-                                                              -
17  Apple Tree Cove   47.80348525790  122.47492954200     63  Tyee Shoal    47.60847990770  122.47877353100
-                                                              -
18  Apple Tree Cove   47.80310261180  122.47598949400     64  Tyee Shoal    47.60766507680  122.47893589300
-                                                              -
19  Apple Tree Cove   47.80237402570  122.47638256900     65  Tyee Shoal    47.60687831460  122.47927979300
-                                                              -
20  Apple Tree Cove   47.80219450150  122.47688158400     66  Tyee Shoal    47.60609769090  122.47964967100
-
67  Tyee Shoal    47.60531536900  122.48000498600
-
68  Tyee Shoal    47.60457213290  122.48052049900
-
69  Tyee Shoal    47.60398226870  122.48118881300
-
70  Tyee Shoal    47.60407102430  122.48180079600

2008 Cruise Season Boundary Points
Id  Tract Name      LATITUDE      LONGITUDE
-
21  President Point    47.76301811440  122.46531995900
-
22  President Point    47.76227795780  122.46478860500
-
23  President Point    47.76153965240  122.46425163200
-
24  President Point    47.76079984240  122.46372318400
-
25  President Point    47.76012732540  122.46302154800
-
26  President Point    47.75945808780  122.46231363200
-
27  President Point    47.75877611500  122.46163224400
-
28  President Point    47.75821701680  122.46249970800
-
29  President Point    47.75769964180  122.46344179800
-
30  President Point    47.75709757920  122.46424411400
-
31  President Point    47.75642784290  122.46495166300
-
32  President Point    47.75568013190  122.46545052600
-
33  President Point    47.75491428200  122.46589325600
-
34  President Point    47.75413762450  122.46629389900
-
35  President Point    47.75340374390  122.46683607100
-
36  President Point    47.75266140050  122.46720422800
-
37  President Point    47.75189295980  122.46684018600
-
38  President Point    47.75123556490  122.46610769300
-
39  President Point    47.75058390610  122.46579489800
-
40  President Point    47.74994707310  122.46656628000
-
41  President Point    47.74921684450  122.46711888700
-
42  President Point    47.74848682750  122.46768011900
-
43  President Point    47.74775279740  122.46822961800
-
44  President Point    47.74701858040  122.46877863300
-
45  President Point    47.74627675290  122.46930377000
-
46  President Point    47.74561278720  122.46984543000
DATUM = HARN
83

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Appendix xi
MEMORANDUM OF UNDERSTANDING 
CRUISE OPERATIONS IN 
WASHINGTON STATE 
SUMMARY OF AMENDMENTS 
AMENDMENT NO. 1
Signed July 8, 2005
1.  Changing references to the Seattle being the only port berthed to all ports in Washington.
While the ships typically call only to Seattle, there is potential for port calls to
other ports.
2.  Adding a requirement for all vessels within the NWCA to submit an annual report of
compliance with MOU.
This requirement is being added due to the need to know if ships complied with
the MOU whether or not they go through the process of authorization to
discharge. For ships that choose to hold their discharge while in Washington
waters, it is important to know if they complied.
3.  Adding regulation language referenced in Appendix vi to show all effluent limits required
for discharge.
Ships that discharge must meet the higher standards as set in Alaska which is
referenced in the MOU and in appendix vi.
AMENDMENT NO. 2
Signed April 28, 2006
1.  Adding a requirement to prohibit the discharge of oily bilge water and a definition was
also added. The purpose of this addition is to include specific prohibition language on all
major sources of potential pollutants from the vessels.
2.  Adding a definition for residual solids. Residual Solids has gone undefined although we
have had the requirement to prohibit the discharges. This has been added to clarify
exactly what types of residual solids are being managed per this MOU.
3.  Adding specific language about what limits must be met for monitoring results. The
purpose of this addition is to make it clear to the cruise lines and to the public what limits
need to be met.
4.  Changing the requirement on WET testing from once per 2 years to once per 40 port calls
or turnarounds for vessels that are not homeported due to the fact that vessels come and
go from this route from year to year.
5.  Other minor changes for organization of the document.

Appendix xi
continued 
AMENDMENT NO. 3
Signed May 25, 2007
1.  Changing all references and the appendix from the International Council of Cruise Lines
(ICCL) to the Cruise Line International Association (CLIA) as the association changed.
2.  Adding language about the interagency agreement for cost recovery and referencing the
appendix.
3.  Changing where residual solids (sludge) can be discharged to disallow any residual solids
discharges in the entire Olympic Coast National Marine Sanctuary.
4.  Clarifying the language to allow for inspections of all vessels, whether approved for
discharge or not for compliance with the MOU. The language currently only allows for
inspections of vessels discharging.
5.  Clarifying the language to say that all vessels approved for discharge, not just those
actually discharging agree to the sampling requirements set out in the MOU. The current
language has been confusing for some vessels approved for discharge, but mostly holding
discharges anyways.
AMENDMENT NO. 4
1.  Incorporating recommendations from the Washington State Department of Health virus
report:
a)  Not allow discharges within a half mile of shellfish beds. Include an appendix
identifying the areas where bivalve shellfish beds that are recreationally harvested
or commercially approved within half a mile of the shipping lanes and update
annually. And include an appendix with background information on the virus
related elements.
b)  Define a "disinfection system upset" condition as a disinfection below levels of
four log (99.99%) inactivation of norovirus.
c)  Require immediate shutdown capability from an upset condition of disinfection
below levels of four log (99.99%) inactivation of norovirus for all vessels that
have submitted documentation to discharge.
d)  Require immediate notification to the Department of Health for an upset
condition.
2.  Require whole effluent toxicity testing for only those vessels that are have submitted
documentation for continuous discharge.
3.  Other minor changes for organization of the document.