Standards Enter into force
Applicable streams Applicable ships
Parameters F. Coliform (/100ml) TSS (mg/l) BOD (mg/l) COD (mg/l) pH
Chlorine (mg/l) Dis. Copper (µg/l) Dis. Nickel (µg/l) Dis. Zinc (µg/l)
Ammonia (mgN/l)
Nitrogen (mgN/l) - passenger in SA
Phosphorus (mgP/l)- Passenger in SA
20 Qi/Qe or 70% 1 Qi/Qe or 80%
do not exist. It is a successful example that demonstrates how effective sampling and monitoring drive compliant performance, and it shows industry will deliver when regulators not only make the rules, but also enforce them. Sampling and monitoring provide the only way to demonstrate that technologies are available, rules are practicable, and regulations are actually protecting the environment. Enforcement of rules is one thing, setting the rules is another.
In the past decade, regulations on black and grey water have one way to go: more stringent, more regionalised and more diversified. But how stringent is stringent enough? The success story in Alaska could have been cruising ahead
if not for a state law -AS46.03.462(b)(1) - passed in 2006. This law requested that cruise ships meet the State’s Water Quality Standards (WQS) at the point of discharge. This law is so stringent that drinking water becomes ‘toxic’ to marine water. Industry argued that these limits could not be achieved. Despite the fact that many ships continued to trade under the state’s General Permits, total berths have reduced year-on-year since 2008, which hit local businesses hard. In late 2012, the Science Advisory Panel (SAP) concluded, after a three-year study, that WQS could not be effectively achieved, and that there was little additional environmental benefit to be gained by lowering the effluent limits to WQS.
In February 2013, Alaska state rolled back
from WQS ‘as a matter of fairness’, as none of the municipal wastewater treatment works in Alaska have such a requirement.
More regulators now recognise that it is not always the case that it is ‘the more stringent the better’, when it comes to environmental rules. Such rules would first of all consume additional natural resources and incur additional carbon emissions, which must be traded with tangible environmental benefits they may bring. This requires better understanding on environmental needs and science-based impact assessments.
The debate over environmental
benefits and fairness also continued over the nutrient removal limits for passenger ships discharging in the Baltic Sea, which
www.passengership.info
was designated the first Special Area in Annex IV during MEPC62 in 2010. Passenger ships contribute less than 0.05 per cent of total nutrient load in the Baltic Sea. Ships’ limits here are more stringent than that for the local communities of equivalent population. During MEPC64 meeting, a narrow vote of 13:11 approved
the adoption of these limits (MEPC.227(64)). All indications show the skill and knowledge requirements for operating biological nutrient removal technologies, such as nitrification and denitrification, are high. The skill requirement alone would make it a challenging task to maintain compliance on board, let alone the associated increases in reactor volumes and power consumptions. Equipment type-approved ashore would have even less relevance to compliant performance on board because the nutrient concentrations in black water can be over 10 times that of the municipal sewage used for tests ashore. Simpler and more robust solutions are desirable. There are also two pre-conditions for the nutrient criteria to take effect: adequacy of port reception facilities (PRF) and availability of technologies. Local ferries in the Baltic have announced they would offload sewage to PRF. Some cruise ships may also take the advantage of PRF. This reduces the market of sophisticated nutrient removal treatment technologies on board.
The regulatory challenges do not stop here. Many ports and regions simply ban overboard discharges from ships, even though AWTs produce better effluent than that from coastal wastewater treatment works. This has forced an increasing number of ships to hold black and grey water, often in ballast water tanks, for discharging beyond 12 nautical miles (nm) from shore. However, the practice incurs an extra fuel burden and greater adverse environmental impact.
Wei Chen: The findings by the
Netherlands may be a wake-up call to the lack of monitoring regime under Annex IV
MEPC227(64) started to make the rules more effective. For example, it has introduced a Dilution Compensation Factor to restrict the so-called dilution machines that pump up to 40 times of seawater into the ‘treatment’ process.
In 2009, Wärtsilä Water Systems Ltd - a leading manufacturer of AWT systems – developed with cruise operators a simple
Passenger Ship Technology I 2nd Quarter 2013 I 57
Annex IV MEPC 2(VI)
Annex IV MEPC 159(55)
2003 2010 black all
black all
200 100 50
100 35 25
125
6-8.5 0.5
WASTEWATER STANDARDS USCG
Annex IV MEPC 227(64)
2016 black all
100
35 Qi/Qe 25 Qi/Qe 125 Qi/Qe 6-8.5 0.5
33CFR159.301 Type II MSD
1975
‘Alaska
Standards’ 33CFR159.301 Subpart E
black black and grey all
passenger
200 150
20 30 30
USEPA Vessel General Permit
grey
Alaska GP No.2009 DB0026
Stationary Discharge
2001 2013 2010-13 black
and grey
20 30 30
6-8.5 6-8.5 0.01
0.01 14
150 30
6-8.5 0.01 87 43
360 28
Alaska Water Quality
Standards (WQS)
2006 black
and grey all passenger passenger 14
150 30
6-8.5 0.01 3.1 8.2 81 1
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