Enhanced MARPOL IV Sewage and Graywater Pollution

Prevention - Holland America Line Westours Case Study

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

Abstract

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

INTRODUCTION accommodate large numbers of passengers with all the

The steady increase in the number of foreign and
domestic vessels calling on U.S. ports is generating a
closer look by regulators and the public with regard to
how they handle their waste and the effect they have on
the environment. Central to this expansion are the
coastal cruise, foreign cruise and ferry fleets that
attendant wastes generated from their care and feeding,
in addition to the normal operation of the ship. As a
result, new US sewage and graywater regulations have
been enacted, in the form of the 2001 Murkowski Act,
to govern operations in sensitive Alaskan waters.

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Industry has reacted with tighter controls with in the
trade organizations such as the International Council of
Cruise Lines (ICCL). Additional regulations in other
sensitive areas could follow. Holland America Line
Westours (HALW), operator of ten cruise vessels with
an additional four under construction, has enhanced its
sewage and graywater pollution prevention machinery,
operating procedures, record keeping, training and
survey arrangements in order to bring a new level of
confidence in its operations in sensitive areas through
ultrafiltration processes and increased managerial
oversight. Following is a review of the regulations and
the enhanced ultrafiltration process.
MARPOL CONVENTION
International pollution control regulations for ships are
set forth by the International Maritime Organization
(IMO) and found in the International Convention for
the Prevention of Pollution from Ships, 1973, as
modified by the Protocol of 1978, better known as
MARPOL 73/78 for Annex I through V with the
Protocol of 1997 covering Annex VI. See table 1.
An additional Annex was also under consideration to
enact regulations for the phase out of toxic anti-fouling
paints. This will be considered instead as a separate
Convention at the next IMO meeting in June 1999 with
the U.S. taking the lead. Conventions and Annexes
come into force 12 months after the date when not less
than 15 countries approve and the combined merchant
fleets of which constitute not less than 50% of the gross
tonnage of the world’s merchant fleet. The United
States has yet to approve Annex IV (Sewage) and
Annex VI (Air Pollution). Annex VII (Ballast Water) is
in the draft proposal stage. See table 2.

Annex I Regulations for the Prevention of Pollution by Oil

Annex II Regulations for the Prevention of Pollution by Noxious Liquid Substances in Bulk
Annex III Regulations for the Prevention of Pollution by Harmful Substances in Package Form
Annex IV Regulations for the Prevention of Pollution by Sewage from Ships
Annex V Regulations for the Prevention of Pollution by Garbage from Ships
Annex VI Regulations for the Prevention of Air Pollution from Ships
Annex VII Regulations for the Prevention of Pollution from Ballast Water (Proposed)

Table 1. IMO MARPOL Convention Annexes

Annexes Entry into Force No. of Contracting Percent World Tonnage

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

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

MARPOL IV vs. U.S. SEWAGE REGULATIONS
MARPOL Annex IV, to which the U.S. is not
signatory, allows treated sewage discharge for vessels
over 200 GRT or more than 10 persons on board when
operating between 4 and 12 nautical miles from land
with operational requirements as per IMO Resolution
ME.2(VI). See table 3. Alternately, a holding tank to
the satisfaction of the Flag Administration may be
installed. Untreated sewage discharge is permitted
outside the 12-mile limit.
USCG 33 CFR 159.3 for Marine Sanitation Devices
(MSD) governs requirements for all vessels for
discharge within 3 nautical miles off the coast in the
territorial seas with either a Type I or Type II
designation dependent upon vessel size. An additional
Type III MSD applicable for any vessel allows any
device, i.e. a holding tank, that is designed to prevent

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the overboard discharge via containment onboard for from the international MARPOL regulations as shown
the duration of the voyage. These requirements vary in table 3.

USCG USCG
Regulated Item Type I MSD Type II MSD MARPOL IV
(Vessels 65 ft. or less) (Any Vessel)
Suspended Solids No visible floating solids Less than 150 mg/l Less than 50 mg/l
Fecal Coliform Bacteria Less than 1000/100ml Less than 200/100ml Less than 250 /100ml
Biochemical Oxygen
Demand BOD5 No requirement No requirement Less than 50 mg/l
Residual Chlorine No requirement No requirement As low as practicable

Table 3. United States vs. MARPOL MSD Operational Requirements

MARPOL Annex IV Regulation 1 (3) defines sewage areas where “greater environmental protection” is
not only as drainage and wastes from toilets and urinals required are granted under Section 312 (F)(3) when
but also “WC scuppers” and all sick bay wash basins adequate pump -out facilities are provided or in the
and drains which may be interpreted to mean the floor event a drinking water intake zone is established under
drains in all the toilet areas that are normally handled as Section (F)(4)(B). These areas include fresh water lakes
graywater. This is not a problem for a vessel that has a including the majority of the Great Lakes, sensitive
combined graywater and sewage system, but could pose seawater bays and sounds. See table 4 for a full listing.
complications for those who don’t, if Annex IV of the
MARPOL Convention ever comes into force. U.S. PROPOSED MARPOL IV AMMENDMENTS
regulations do not specifically list WC scuppers, but
rather define sewage as wastes from toilets and other A draft text of the revised Annex IV of MARPOL
receptacles intended to receive or retain body waste. 73/78 was set out in annex by the Marine Environment
Protection Committee (MEPC) at the 44th session
Two types of Type II MSDs have generally been
Agenda item 12 on 20 October1999 (MEPC 44/12).
approved in the past, biological where microorganisms
The draft text was prepared based on the modified
reduce the sewage to acceptable levels and
version of Annex IV contained in annex to MEPC
physical/chemical where sewage is mechanically
37/12/10 and MEPC 38/8/6. These amendments were
macerated and strained to low levels. Both usually
developed by the previous Correspondence Group led
depend upon chlorine to bring the final fecal coliform
by Germany, and the proposed amendments to
bacteria count to USCG/IMO levels. This may be a
regulations 9, 11 and 12 of the modified version of
point of contention as chlorine itself is coming under
Annex IV contained in MEPC 43/11/2, which was
scrutiny as a pollutant. Manufacturers have had
developed by the Correspondence Group led by
difficulty in receiving approval of their equipment in
Singapore. (ref. 4)
Canada for this type of treatment, but no action has
been taken against foreign vessels that have MARPOL
The US maintains its position that it cannot support the
compliant MSDs. A third Type II has recently been
ratification of Annex IV in its current form. The US
approved using physical and biological processes
supports the continued review and discussion of the
combined with ultrafiltration and ultraviolet light to
proposed amendments to Annex IV, however, the
produce near drinking quality water.
problem remains that the amendments have not yet
addressed most of the concerns that the US has with the
The United States passed the Federal Water Pollution
requirements of Annex IV. The main reasons for the US
Control Act (FWPCA) in 1972 with reauthorization in
not accepting Annex IV are because of difficulties
1985 as the Clean Water Act. Section 312 of the Act is
related to the definition of sewage, applicability, on-
codified as 33 USC 1322 to eliminate the discharge of
board treatment, nutrient sensitive resources, effluent
untreated sewage into the waters of the United States.
standards and reception facilities. In summary, the US
Various states have petitioned and been approved under
feels that fundamental amendments to Annex IV are
40 CFR 140.3/4 for limited no discharge areas for both
needed. The US states the proposed amendments have
treated and untreated sewage (ref. 20). Zones with no
not addressed these basic problems. (ref. 3)
sewage discharge permitted, treated or non-treated, for

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 Table 4. FEDERAL CLEAN WATER ACT NO DISCHARGE ZONES

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

State Water body CWA Type Federal Register Date

Section 312 Notice
California Mission Bay (f)(3) 41 FR 34353 8/13/76
California Oceanside Harbor (f)(3) 41 FR 34353 8/13/76
California Dana Point Harbor (f)(3) 41 FR 34353 8/13/76
California Channel Islands Harbor (f)(3) 44 FR 26963 5/8/79
California Oxnard (f)(3) 44 FR 26963 5/8/79
California Avalon Bay Harbor (f)(3) 44 FR 26963 5/8/79
California Santa Catalina Island (f)(3) 44 FR 26963 5/8/79
California Newport Bays (f)(3) 41 FR 2274 1/15/76
California Sunset Bay (f)(3) 41 FR 2274 1/15/76
California Pacific Coast Highway Bridge (f)(3) 41 FR 2274 1/15/76
California Richardson Bay (f)(3) 52 FR 33282 9/2/87
California Huntington Harbor (f)(3) 41 FR 2274 1/15/76
California/ Nevada Lake Tahoe (f)(3) 42 FR 59105 11/15/76
Florida Destin Harbor (f)(3) 53 FR 1678 1/21/88
Florida City of Key West waters (f)(3) 64 FR 46390 8/25/99
Massachusetts Westport Harbor (f)(3) 59 FR 45677 9/2/94
Massachusetts Wellfleet (f)(3) 60 FR 30539 6/9/95
Massachusetts Waquoit Bay (f)(3) 59 FR 11271 3/10/94
Massachusetts Nantucket Harbor (f)(3) 57 FR 44379 9/25/92
Massachusetts Wareham Harbor (f)(3) 57 FR 2553 1/22/92
Massachusetts Stage Harbor Complex (f)(3) 62 FR 13885 3/24/97
Massachusetts Harwich (f)(3) 63 FR 44255 8/18/98
Massachusetts Buzzards Bay (f)(3) 65 FR 46712 7/31/00
Michigan All (f)(3) 41 FR 2274 1/15/76
Minnesota Boundary Waters Canoe Area (f)(4)A 42 FR 43837 8/31/77
Minnesota Mississippi River (part) (f)(3) 42 FR 33362 6/30/77
Minnesota Minnesota River (part) (f)(3) 42 FR 33362 6/30/77
Minnesota St. Croix River (f)(3) 61 FR 30868 42 6/18/96
DENIAL FR 37844 7/25/77
Missouri All (except Miss. River, Missouri (f)(3) 40 FR 54462 11/24/ 75
River, part of Bull Shoals Lake)
New Hampshire All (except coastal waters) (f)(3) 40 FR 36797 8/22/75
New Jersey Shark River (f)(3) 63 FR 12094 3/12/98
New Jersey Manasquan River (f)(3) 63 FR 12094 3/12/98
New Jersey Shrewsbury River (f)(3) 65 FR 32091 5/22/00
New Jersey Navesink River (f)(3) 64 FR 25504 5/12/99
New Mexico All (f)(3) 41 FR 17599 4/27/76
New York Lake Champlain (f)(3) 41 FR 24624 6/17/76
New York Mamaroneck Harbor (f)(3) 62 FR 223 11/19/97
New York Lake George (f)(3) 41 FR 2668 1/19/76

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

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

State Water body CWA Federal Register Date

Section 312 Notice
Type
New York Hudson River (part) (f)(4)(B) 60 FR 63941 12/13/95
New York East Hampton (7 water bodies) (f)(3) 64 FR 7194 2/12/99
New York Greater Huntington-North Port (f)(3) 65 FR 37385 6/14/00
Rhode Island Great Salt Pond, Block Island (f)(3) 58 FR 31202 6/1/93
Rhode Island All (f)(3) 63 FR 42633 8/10/98
South Carolina Broad Creek, Lake Keowee, Lake (f)(3) 64 FR 10465 3/4/99
(North Carolina and Murray, Lake Thurmo nd, and Lake
Georgia) Wylie
South Carolina Hartwell Lake (f)(3) 60 FR 25215 5/11/95
(Georgia)
Texas 24 Freshwater bodies (f)(3) 42 FR 59776 11/21/77
Utah/Arizona Lake Powell (f)(3) 65 FR 56577 9/19/00
Vermont All (including parts of La ke (f)(3) 40 FR 42240 9/11/75
Champlain and Lake
Memphremagog)
Virginia Smith Mountain Lake (f)(3) 65 FR 61166 10/16/00
Wisconsin All (except Lake Superior, (f)(3) 41 FR 11875 3/22/76
Mississippi River, part St. Croix
River)

FEDERAL MURKOWSKI ACT
On December 21, 2000 U.S. Congress passed ``Title
XIV--Certain Alaskan Cruise Ship Operations'' of the
Miscellaneous Appropriations Bill (H.R. 5666) in the
Consolidated Appropriations Act of 2001 (P.L. 106-
554) known as the Murkowski Act for the Senator from
Alaska, to regulate sewage and graywater in Alaska for
large cruise vessels with 500 or more passengers.
Specifically excluded from this were vessels of the
United States operated by the Federal Government and
vessels owned and operated by the government of a
State, such as the entire fleet of nine Alaska State
ferries. The legislation is currently under a Notice of
Proposed Rulemaking by the USCG under 33 CFR 159
to accomplish the following:
(a) Ensure that cruise vessels operating in the waters of
the Alexander Archipelago and the navigable waters of
the United States within the State of Alaska and within
the Kachemak Bay National Estuarine Research
Reserve comply with all applicable environmental laws,
including, but not limited to, the Federal Water
Pollution Control Act, as amended (33 U.S.C. 1251 et
seq.), the Act to Prevent Pollution from Ships, as
amended (33 U.S.C. 1901 et seq.)
(b) Ensure that cruise vessels do not discharge untreated
sewage within the waters of the Alexander Archipelago,
the navigable waters of the United States in the State of
Alaska, or within the Kachemak Bay National Estuarine
Research Reserve.
(c) Prevent the unregulated discharge of treated sewage
and graywater while in ports in the State of Alaska or
traveling near the shore in the Alexander Archipelago
and the navigable waters of the United States in the
State of Alaska or within the Kachemak Bay National
Estuarine Research Reserve unless underway and
proceeding at a speed of not less than six knots and not
less than one nautical mile from the nearest shore.
(d) Ensure that discharges of sewage and graywater
from cruise vessels are monitored for compliance by
examination of environmental compliance records and
procedures; inspection of the functionality and proper

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operation of installed equipment for abatement and
control of any discharge; and incorporate a plan for
sampling and testing.
Additionally, inspections may include unannounced
inspections of any aspect of cruise vessel operations,
equipment or discharges and require a logbook
detailing the times, types, volumes or flow rates and
locations of any discharges of sewage or graywater.
Until such time as the formal regulations are in place,
treated sewage and graywater may be discharged inside
of one mile and at speeds less than 6 knots provided
that:
1. The discharge satisfies the minimum level of
Secondary treatment effluent quality specified
in 40 CFR 133.102:
(a) BOD<INF>5</INF> Biological Oxygen
Demand
(1) The 30-day average shall not exceed 30 mg/l.
(2) The 7-day average shall not exceed 45 mg/l.
(3) The 30-day average percent removal shall not
be less than 85 percent.
(b) SS (Total Suspended Solids)
(1) The 30-day average shall not exceed 30 mg/l.
(2) The 7-day average shall not exceed 45 mg/l.
(3) The 30-day average percent removal shall not
be less than 85 percent.
(c) pH. The effluent values for pH shall be
within the limits of 6.0 to 9.0
2. The geometric mean of the samples from the
discharge during any 30-day period does not
exceed 20 fecal coliform/100 ml and not more
than 10 percent of the samples exceed 40 fecal
coliform/100 ml;
3. Concentrations of total residual chlorine
may not exceed 10.0 mg/l; and,
4. Prior to any such discharge occurring, the owner
demonstrates test results from at least five
samples taken from the vessel representative of
the effluent to be discharged, on different days
over a 30-day period, as per 40 CFR Part 136 and
demonstrates continued compliance through
periodic sampling.
Administrative civil penalties for violations can be up to
$10,000 per day for each day during which the violation
continues, except that the maximum amount of any class
II civil penalty under this section shall not exceed
$125,000.00.
EPA ACTION
On March 17, 2000, the Bluewater Network sent a
petition (ref. 15) to the U.S. Environmental Protection
Agency (EPA) Administrator Carol Browner on behalf
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of 53 organizations, asking the EPA to take regulatory
action on measures to address pollution by cruise ships.
The petition specifically calls for an investigation of
wastewater, oil and solid waste discharges from cruise
ships, and the implementation of policy or regulatory
changes if necessary to assure that these discharges do
not threaten the marine environment. In response to the
petition, EPA agreed to study cruise ship discharges
and waste management approaches.
A Cruise Ship White Paper (ref. 6) by the EPA dated
August 20, 2000 provides preliminary information
regarding cruise ships and waste management practices.
Preliminary recommendations regarding EPA’s
response to the petition are given stating the options
presented in the paper should not be interpreted as
Agency recommendations or as a decision on the
Bluewater Network petition. The Cruise Ship White
Paper recommends the following EPA actions:
(1) Conduct an assessment of:
• the volumes and characteristics of cruise ship
waste streams and their potential impact on water
quality and the marine environment;
• the effectiveness of existing programs (regulatory
and non-regulatory) for managing those waste
streams; and
• options for better environmental management of
cruise ship waste streams including the issuance of
regulations and/or voluntary environmental
management programs such as public-private
partnerships.
(2) Solicit additional information from the
petitioners, other environmental groups, the cruise
ship industry, government agencies, and the public
for incorporation into the assessment. Hold public
information hearings in Los Angeles, California
(Sept. 6, 2000); Juneau, Alaska (Sept. 8, 2000); and
Miami, Florida (Sept. 12, 2000) where there is a large
amount of cruise ship traffic as a way to solicit this
information.
(3) Once the assessment is drafted, make it available
to the public.
(4) Establish an interagency workgroup with EPA
and the Coast Guard in primary roles to review the
assessment and take appropriate action.
(5) Continue to support Coast Guard, State and
industry efforts to improve cruise ship waste
management practices while assuring that these
efforts are consistent with national policy and
regulations.
Subsequent to this, a Cruise Ship Plume Tracking
Survey (ref. 9) was carried out August 10-13, 2001 on
Carnival Cruise Lines’ Fascination and Paradise. The
project objectives were:
 (1) Determine the effluent dilution characteristics in
the wake of the cruise ship;
(2) Track the longer-term location and mixing
dynamics of the effluent plume;
(3) Provide preliminary information on whether
discharge plumes behave as predicted by the model;
(4) Assess the utility and feasibility of monitoring
fecal coliforms (tracers of sewage) in the wake of the
cruise ship.
Results are pending, with one comment being “dilution
is the solution to pollution” which was supported by the
previous Rosenblatt & Son/ICCL “Cruise Ship Waste
Dispersion Analysis - Report on the Analysis of
Graywater Discharge ” September 14, 2000. (ref. 11)
GAO ACTION
In February 2000 the Resources, Community and
Economic Development Division of the United States
General Accounting Office released a report on cruise
ship pollution (ref. 9) at the request of House
Representatives John D. Dingell and Henry A Waxman.
87 illegal discharges in U.S. waters were noted between
1993 to 1998, all oil, garbage or plastic related.
However, concern was noted regarding the large
volume of wastewater from sinks, showers, drains and
sewage systems that cruise ships legally discharge at
sea and the possible effects of these discharges on
sensitive marine life.
IMO ISM CODE
In 1998, new amendments to IMO SOLAS Chapter IX
entered into force to make mandatory the International
Safety Management (ISM) Code, which had been
adopted by the IMO in November 1993 (Assembly
resolution A.741(18)). Chapter IX applies to passenger
ships and tankers from that date and to cargo ships and
mobile drilling units of 500 gross tons and above from
July 1, 2002. These requirements are administered by
USCG under 33 CFR 96. The ISM Code establishes
safety management objectives which:
• Provide for safe practices in ship operation and a
safe working environment;
• Establish safeguards against all identified risks; and
• Continuously improve safety management skills of
personnel, including preparing for emergencies.
The Code requires Safety Management System (SMS)
Plans to be established by owners or any person who
has assumed responsibility for operating a ship. A plan
for the above objectives, details of resources and shore-
based support must be developed in a Safety
Management Manual which is kept on board and
audited periodically, usually by the Class Society on
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behalf of the administration. The primary focus is
safety, but also included is environmental protection.
STATE REGULATIONS
Various state, county and city regulations also come
into effect within their jurisdiction. An example is
Washington State RCW 90.48.080. The criteria
developed on the international and national level
theoretically should allow for the operation of properly
maintained MSD in the navigable waters of the U.S.
This is dependent upon interpretation of the Clean
Water Act, state and local regulations as to the
definition of the harmful effects of discharges and the
sensitivity of the surrounding water such as captive
freshwater and remote saltwater bays with poor tidal
action.
States that have stricter sewage discharge regulations
such as Washington with 14 fecal coliform bacteria per
100 ml, as opposed to the Federal 200/1000 ml limits,
are precluded from enforcement without the special
sewage area designation. However, there is no
prohibition from enforcement of State pollution
standards as they apply to graywater discharge (ref. 5).
These definitions can be strict and subject to
interpretation, as an example the Revised Code of
Washington RCW 90.48.080 defines pollution as:
“such contamination, or other alteration of the
physical, chemical, or biological properties of any
waters of the state, including changes in temperature,
taste, color, turbidity or the odor of the waters, or such
discharge of any liquid, gaseous, solid, radioactive, or
other substance into any waters of the state as will or is
likely to create a nuisance or render such waters
harmful, detrimental or injurious to the public health,
safety or welfare, or to domestic, commercial,
industrial, agricultural recreational or other legitimate
beneficial uses, or to livestock, wild animals, birds, fish
or other aquatic life.”
Effective July 1, 2001 the state of Alaska enacted the
first state law in the country to regulate cruise ship
pollution. The legislation requires cruise ships to:
• Register with the state.
• Maintain records of black (sewage) and graywater
pollution.
• Sample its discharges at least twice per year.
• Allow the state access to the vessel for the purpose of
additional sampling if the state requests. Pay a fee of
$0.75 - $1.75 per passenger, depending on number of
passengers, to the state to pay for the administration
of this program.
The law also prohibits the discharge of untreated
sewage, provides standards for total suspended solids
(TSS) and fecal coliform in treated sewage and gray
water discharges, authorizes the Alaska Department of
Environmental Conservation (ADEC) to establish
standards for additional pollutants in sewage and gray
water, and generally allows discharges only at distances
greater than one mile from shore and speed more than 6
knots. It provides for civil penalties of $500 - $100,000
for an initial violation of these provisions, plus $10,000
maximum per day for each day of continuing violation.
It makes it a misdemeanor to, with criminal negligence,
violate the law or an A DEC order or regulation
enforcing it, or make false statements. Some of these
provisions already exist in federal law, but the
legislation gives the state a more active oversight and
enforcement role.
FLORIDA MOU and ICCL POLICY
On March 14, 2000 the 15 Member Lines of the
Florida-Caribbean Cruise Association (FCCA) as
representatives of the cruise industry signed a
Memorandum of Understanding (ref. 12) with the
Florida Department of Environmental Protection
(FDEP) regarding its environmental practices and
policies.
The cruise industry, through the FCCA and
International Council of Cruise Lines (ICCL),
developed cruise industry policy with regards to waste
minimization, waste recycling and waste management
based on the following underlying principles:
• Comp ly with applicable laws and regulations.
• Maintain cooperative relationships with the
regulatory community.
• Manage waste streams.
• Minimize waste generated.
• Maximize reuse and recycling.
• Educate and training cruise vessel personnel in waste
management practices.
• Embrace new technology in the management of
waste streams.
• Design cruise vessels to be environmentally friendly.
The International Council of Cruise Lines (ICCL) has
published the “Cruise Industry Waste Management
Practices and Procedures”,(ref. 7) effective date July 1,
2001, revised December 14, 2001. Each ICCL cruise
vessel operator has agreed to utilize one or more of the
practices and procedures contained in the “Cruise
Industry Waste Management Practices and
Procedures” in the management of their shipboard
waste streams. Recognizing that technology is
progressing at a rapid rate, any new equipment or
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management practices that are equivalent to or better
than those described, and which are shown to meet or
exceed international and federal environmental
standards, will also be acceptable.
Member lines have agreed to communicate to ICCL the
use of equivalent or other acceptable practices and
procedures. As appropriate, such practices and
procedures shall be included as a revision to the
attached document. As an example, when improved
systems for treating sewage and graywater are perfected
and shown to meet the requirements for MSDs and
accepted by appropriate authorities, the new systems
and associated technology will be included in the
attachment as a revision. ICCL and its Environmental
Committee will work with the U.S. Coast Guard, the
U.S. Environmental Protection Agency and other
appropriate agencies to further implement the above
commitments.
LOCAL REGULATION
Concern for the cleanliness of water is evident past the
federal and state levels all the way down to the county
and city governments. An example of this is the
formation of Washington’s King County Interagency
Regulatory Analysis Committee (IRAC)
Boating/Sewage Compliance Task Force. This work
group was formed primarily to focus on the recreational
boating sewage problems that cross city, county and
port boundaries but includes the interface of federal
rules and commercial shipping. Agencies and their
regulations were identified in the IRAC
Boating/Sewage Compliance Matrix (ref. 8) with
a recommendation to pursue the Clean Water Act no
discharge areas for both treated and untreated sewage
under 40 CFR 140.3/4 section 312.
CLASSIFICATION SOCIETY RULES
The major Classification Societies have developed
voluntary standards for shipboard environmental
compliance. These rules are based on the principles
established under ISO 14000, similar to the
methodology employed in the International Shipboard
Management (ISM) code, which is rooted in the ISO
9000 philosophy. An example is Lloyd’s Register of
Shipping (LR), which classes the Holland America Line
Westours fleet, recently published revised Provisional
Rules for Environmental Protection. First published in
1998, these provisional rules apply to both new and
existing ships with voluntary compliance for the
environmentally conscious who want to more
effectively manage environmental and business risk.
The LR Environmental Protection (EP) notation covers
the major areas of concern with regard to operational
pollution from shipping. The rules aim to help owners:
• control operational pollution
• provide public validation of onboard
environmental performance
• demonstrate a pro-active approach to
environmental protection.
This system enables owners to highlight substantial
investment in particular aspects of pollution control,
while demonstrating a high all-round level of
environmental performance.
The core LR EP rule requirements demand a level of
environmental performance in excess of international
legislative requirements and cover:
• oxides of nitrogen (NOx) and oxides of sulphur
(SOx) emissions
• refrigerants and fire-fighting agents
• oil pollution prevention
• garbage handling and disposal
• sewage treatment
• hull anti-fouling systems
• ballast water.
Compliance leads to assignment of the LR
Environmental Protection EP letter notation.
Compliance with additional more stringent
requirements in a range of specific areas, such as
graywater treatment and protected fuel tanks, will lead
to assignment of supplementary characters, further
enhancing recognition of owners’ proactive
commitment to the environment ahead of international
requirements.
SOLID WASTE
Table 5. MARPOL/US Solid Waste Disposal Regulations
Garbage Type
Plastics, synthetic ropes, fishing nets, and plastic bags
Floating dunnage, lining and packing material
Paper, rags, glass, metal, bottles, crockery, and simila r refuse
All other garbage, paper, rags, glass comminuted or ground (1)
Food waste not comminuted or ground
Food waste comminuted or ground (1)
Mixed refuse types
1. Ground garbage must be able to pass through a screen with a mesh size no larger than 25 mm.
2. Western Caribbean Region is >3 miles for ground garbage only.
3. When garbage is mixed with other harmful substances having different disposal or discharging requirements,
the more stringent disposal requirements will apply.
9
The United States approved MARPOL Annex V
(Garbage) in December 1987. The IMO Annex was
implemented by law via the Act to Prevent Pollution
from Ships 33 USC 1901-1911. Garbage consisting of
victual, domestic and operational waste is regulated by
the USCG in 33 CFR 151.51 to 151.77, see table 5.
IMO Special Areas are areas where the discharge of all
garbage, with the exception of ground food waste at
greater than 12 miles, is prohibited and include the
Mediterranean Sea, Baltic Sea, Black Sea, Red Sea, the
Gulfs from Ras al Hadd to Ras al Fasteh, North Sea and
the Antarctic. The wider Caribbean Region, which
includes the Gulf of Mexico, has the same Special Area
status with ground garbage permitted at greater than 3
miles.
MARPOL Annex V Regulation 9 and 33 CFR
151.55/57 both require strict development of an
onboard Waste Management Plan and to report and
maintain records of refuse discharge. Willful violators
are guilty of a Class D felony and subject to fines of up
to $250,000 per individual or $500,000 per organization
as well as prison terms of up to 6 years.
Additionally, the solid waste disposal from vessels is
subject to further restrictions as per 33 CFR 151.65
with 24-hour notice required before arrival with the
following wastes from a foreign port excluding Canada:
(a) Garbage regulated by the U.S. Department of
Agriculture’s' Animal and Plant Health
Inspection Service (APHIS) 7 CFR 330.400
and 9 CFR 94.5
(b) Medical Wastes
(c) Hazardous waste as per 40 CFR 261.3
Outside Special In Special Areas
Areas
Disposal Prohibited Disposal Prohibited
> 25 miles off shore Disposal Prohibited
> 12 miles Disposal Prohibited
> 3 miles Disposal Prohibited
>12 miles Disposal Prohibited
>3 miles > 12 miles (2)
(3) (3)
HOLLAND AMERICA LINE WESTOURS CASE STUDY
CORPORATE OPERATING PHILOSOPHY
Holland America Line Westours is a cruise ship
company operating ten large passenger vessels
worldwide, and marks its 130th year in business in
2002. In 1872 the Dutch steamship Rotterdam was
launched in answer to the high demand for travel to
America. Up to this point the English and Germans
dominated the lucrative European steamship business.
With the opening of a canal linking the city of
Rotterdam with the North Sea a new era was born in
transporting travelers, immigrants and cargo from
Holland to America - the Holland America Line.
Today, Holland America’s fleet of passenger vessels
includes the 1,214-passenger ms Noordam (1984), the
1,266-passenger sister ships ms Statendam and ms
Maasdam (1993) ms Ryndam (1994) ms Veendam
(1996) ms Rotterdam (1997) ms Volendam (1998) ms
Zaandam (1999) ms Amsterdam (2000) ms Prinsendam
(2002) with four new class vessels under construction.
In addition to these larger vessels, Holland America
also operates the Windstar Cruises fleet of four motor
sailing ships, three each of approximately 150-
passenger capacity, msy Wind Star, msy Wind Song and
msy Wind Spirit and one large motor sailing vessel msy
Wind Surf.
The company is proactive instead of reactive and well
ahead of the learning curve of regulatory compliance.
This approach takes compliance of existing regulations
into account, anticipates new regulations and
incorporates pollution prevention strategies into the
process. In 1994 a corporate committee was founded to
coordinate the environmental efforts being made on the
vessels and expand that effort. The committee's
challenge was to coordinate and expand an already
impressive environmental program.
Holland America Line Westours is committed to
maintaining a clean and healthy environment for its
passengers, employees and the communities visited by
the company's ships. Holland America's concern with
the environment predates most of the legislation
governing waste disposal. Environmental issues are
regarded as integral with all of the functions of
operating the ships and are included in everything from
job descriptions to performance evaluations.
Environmental sensitivity and impact of the vessels is
regarded as a high priority of the total operations. In
10
1995 Holland America made a significant commitment
in establishing the "Seagoing Environmental
Awareness" (S*E*A) committee to coordinate and
expand the environmental program and maintain a high
level of commitment. The S*E*A program reaches
from the corporate headquarters out to all the Holland
America Line Westours fleet. The program acts as a
communications hub for the individual ship's sanitation
and environmental committees and communicates their
observations, recommendations and needs to the
company's planning and operations management. These
committees also oversee the development of
educational programs for employees and guests that
highlight environmental subjects.
PREVIOUS SEWAGE TREATMENT PLANT
The previous sewage only treatment system was
manufactured by Hamworthy, which consisted of four
separate treatment tanks of 38 tons each. The approved
MSD was designed to take only black water and
biologically treat the effluent to an acceptable quality in
three stages with chlorine injection into the final
effluent.
Effluent testing was initiated in 1998 and discovered
that the units did not meet discharge requirements.
Fortunately, the holding of wastewater in port had
already initiated. The manufacturer was contracted to
initiate an improvement program for operation, which
consisted of a complete overhaul of the system to
replace blowers, diffusers, level switches and contact
time controls for treatment. The effluent was also
treated with chlorine dioxide rather than chlorine to
help achieve the bacterial load reduction required for
compliance.
At that same time Holland America began researching
wastewater treatment technologies and discovered the
previously land-based ZENON system at Seatrade in
1999. Holland America Management have always tried
to stay ahead of the combined black and graywater
treatment curve on new regulations, a demonstration
installation was carried out for the ms Statendam. After
successful start-up and refinement of the system for
cruise ship applications, the installation onboard the ms
Zaandam and four other vessels were carried out at a
cost of approximately $2,000,000 per vessel.
 ms ZAANDAM
PRINCIPAL CHARACTERISTICS

Length Overall..............................................................................................................780.6 feet, 238.00 m.

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

SYSTEM DESIGN SUMMARY PROCESS SUMMARY

Holland America Line Westours has installed a
ZENON Environmental Inc. immersed membrane
bioreactor wastewater treatment system on the ms
Zaandam. This system is designed to process a
maximum of 187,562 gallons per day (710 m3 /day) of
all blackwater and graywater (i.e. accommodation,
laundry, galley and Somat pulper effluent) generated
aboard the ship. The system is designed to produce
effluent (permeate) with Biological Oxygen Demand
BOD5 < 15 mg/l, TSS < 2 mg/l and fecal coliform <
10/100 ml. Commissioned in May 2001, the system’s
performance has been fully validated and was certified
as a Type II MSD by the United States Coast Guard in
October 2001. The actual performance has exceeded
the design specifications; effluent BOD typically ranges
between 2 and 5 mg/l, and both TSS and fecal coliform
count are below detectable limits. In practice, the actual
combined gray and black wastewater generation rate is
approximately 15 per cent less than the design capacity,
or approximately 158,503 gallons per day (600 m3 /day).
Holland America has installed the same system on other
vessels engaged in the Alaskan passenger trade and
governed by the Murkowski Act (i.e. ms Statendam,
Volendam, Veendam and Ryndam)
The ZENON system is a typical application of the
company’s proprietary ZeeWeed/ZenoGem
technologies, which combine bio-oxidation and
membrane ultrafiltration into a single process such that
system operation is simplified and space requirements
are minimized. The Zaandam system features the same
processes that have been applied in hundreds of
ZENON’s land-based municipal wastewater treatment
plants. Four basic processes are used in the system:
Equalization - The graywater streams are combined and
temporarily placed in a holding tank to equalize the
biological and solids loading, and provide a reservoir
from which the bioreactor can be fed at a constant rate.
Bio-oxidation - The organic content of the mixed liquor
is processed biologically in an aerated bioreactor.
Membrane Ultrafiltration - The bioreactor mixed liquor
is filtered through a hollow-fiber ultrafiltration
membrane system. The membranes are immersed
directly in the bioreactor and operate under vacuum,
causing the purified water to permeate though the
membrane surfaces into the hollow cores of the fibers.

11
UV Disinfection - Prior to overboard discharge or
reuse, the permeate is exposed to ultraviolet light to kill
any residual bacteria which may have penetrated the
membranes.
ZeeWeed - ZenoGem Process
The ZENON ZeeWeed ZenoGem process combines
the best features of biological processing and
membrane filtration. Used individually, neither method
provides a satisfactory solution given the space
constraints aboard a cruise ship. Stand-alone biological
treatment for gray and black water is limited by
available tank volume, which is typically inadequate to
achieve the required SRT and HRT levels necessary to
satisfy the effluent quality requirements. Membrane
filtration alone is not suitable for processing blackwater
or graywater, either individually or combined, as
conventional membrane systems foul rapidly when
processing either type of waste in their raw form. The
ZENON system utilizes a proprietary process, whereby
the combined blackwater and graywater streams are
biologically treated and concentrated in a tank
containing ZeeWeed® membrane modules. ZeeWeed®
utilizes hollow-fiber ultrafiltration membranes, figure 1,
that are tolerant of high concentrations of suspended
solids. This feature allows high solids levels to be
achieved in the bioreactor, thereby minimizing the
working volume required. In addition, the ZeeWeed®
membranes produce extremely high quality effluent that
does not require chlorination to achieve USCG and
IMO discharge criteria.
The ZenoGem process is a proprietary membrane
bioreactor (MBR) process that has been applied for the
treatment of industrial and commercial wastewaters for
over ten years. In the process, ultrafiltration
membranes separate the treated water from the mixed
liquor. In effect, the membranes perform the functions
of the secondary settler and tertiary filter of the
activated sludge process in a conventional wastewater
treatment plant. Historically, energy costs associated
with pumping the mixed liquor under high pressure
through tubular or reverse osmosis membranes
precluded widespread application of the process for the
treatment of municipal wastewater. However,
development of immersed hollow fiber ZeeWeed
membrane technology has eliminated the need for high-
pressure pumping and greatly reduced energy
requirements.
12
ZeeWeed are proprietary hollow-fiber ultrafiltration
membranes that are immersed within the bioreactor, in
direct contact with the mixed liquor. The ZeeWeed 
hollow fiber membranes are contained in bundles called
modules, which are assembled into cassettes of 8-12
modules. The membrane modules are directly
immersed in the aeration tank, in direct contact with the
mixed liquor. Through the use of a centrifugal or
positive displacement pump, a vacuum varying between
2 and 9 psi is applied to a header connecting the
membrane modules. The vacuum draws the treated
water through the hollow fiber membranes. The treated
water passes through the hollow fibers and is pumped
out by the permeate pump. All particulate matter and
the mixed liquor solids are rejected at the surface of the
membrane. The ZeeWeed membranes are
automatically back pulsed on a regular basis using
collected permeate. A coarse bubble air diffuser is
located at the base of each membrane module. The
airflow provided by the diffuser scours the external
surface of the membrane transferring the rejected solids
away from the membrane surface. This airflow also
provides a portion of the biological oxygen
requirements. Supplemental coarse or fine bubble
diffuser grids may be used to supply the remainder of
the biological oxygen requirements. Sludge is wasted
directly from the aeration tank at the operating MLSS
concentration between 10,000 – 15,000 mg/l. Figure 2
shows a simplified process flow diagra m, illustrating
the major process stages.
Figure 1. ZeeWeed® Membranes
 ZeeWeed ® ZenoGem®
Ventilation Bioreactor UV
Disinfection
Permeate
Discharge
Overboard

Screening Permeate
Backpulse
Tank Reuse
Collection
Tank
Bioreactor
Waste Tank
Overboard
Black Water Discharge
(Sewage) > 12 Miles

Macerator/
Recirculate

Aerated Shoreside Discharge

Solids Tank

Figure 2. ZenoGem Shipboard Process Flow Diagram

The membrane module is the building block of the and Oocysts, resulting in a clear effluent independent to
system. An individual membrane module is the settling characteristics of the sludge. ZeeWeed®
smallest replaceable unit within any ZeeWeed  membranes exclude any particles larger than 0.035 µm
filtration system. ZeeWeed hollow fiber membranes in size. Figure 3 illustrates the relative particle sizes
are strong polymeric membranes cast on the outside that are separated or rejected by typical filtration
surfaces of porous support lumens. ZeeWeed  processes; ZeeWeed falls within the ultrafiltration
membranes create an absolute barrier to biomass, solids range.

ST Microscope Scanning Electron Microscope Optical Microscope Visible to Naked Eye

Micrometers
(Log Scale) Macro Molecular
Ionic Range Molecular Range Micro Particles Range Macro Particle Range
Range
0.001 0.01 0.1 1.0 10 100 1000
Angstroms Units
1 2 3 4 5 6 7
(Log Scale) 10 10 10 10 10 10 10

Approximate
100 200 1000 10,000 20,000 100,000 500,000
Molecular Weight
Crypto
sporidium
Aqueous Salt Carbon Black Paint Pigment Giardia Human Hair
Cyst
Endotoxin/Pyrogen Yeast Cell Beach Sand

Metallon Synth. Virus Bacteria Mist

Dye
Tobacco Smoke Coal Dust
Relative
Size of Common Gelatin Pin
Red Point
Materials Blood
Blue Indigo Dye Cell Pollen
Sugar Colloidal Silica
Granular
Atomic Albumin Protein A.C. Fine Test Dust Activated
Radius Carbon
Latex/Emulsion
Asbestos Milled Flour

Process Reverse Osmosis Ultrafiltration Particle Filtration

for
Separation Microfiltration
Nanofiltration

Nominal Pore Size of ZeeWeed® Membrane

Figure 3. – Process Comparison Filtration Spectrum

13
The membrane fibers are assembled in individual
modules, with the ends of each fiber potted in
polyurethane resin in top and bottom headers. The
modules in turn are configured in cassettes, which are
immersed in the bioreactor mixed liquor.
Figure 4. ZeeWeed 500c Cassette
PROCESS EQUIPMENT - MAJOR
COMPONENTS
All of the process equipment is installed immediately
adjacent to the bioreactors. The system is configured in
two process trains to provide a measure of redundancy,
and to facilitate cleaning. Although the membranes
feature a continuous self-cleaning back pulse function
and air scouring, the modules will require periodic
chemical soaking (i.e. once every six to twelve months)
to remove biological foulants. The major components
of the system include:
• One (1) graywater equalization tank (existing
double-bottom tank N.3.C.);
• Two (2) graywater feed pumps;
• Two (2) mechanical screening units to remove hair,
string and other solids which are potentially
hazardous to the hollow-fiber membranes;
• One (1) break tank to collect screened water from
the units;
• One (1) aerated solids collection tank (36 m3 ) to
receive screened solids from the screening units.
• Two (2) solids recirculation/macerator pumps to
keep the solids mixed and in suspension in the
aerated solids collection tank;
14
• One (1) offload pump for discharge of solids
ashore;
• Two (2) bioreactor feed pumps which transfer
water from the break tank to the bioreactors;
• Two (2) bioreactor tanks, converted from a single
existing potable water tank, each equipped with
fine-bubble diffuser aeration systems;
• (24) ZeeWeed® membrane cassettes, twelve
immersed in each bioreactor (6 per train), with
aeration supplied to each train by a blower;
• One (1) bioreactor waste water tank port double
bottom tank no. 3;
• Two (2) permeate pumps;
• Two (2) mixed liquor recirculation pumps, used to
keep the bioreactor tank contents mixed and to
periodically pump waste from the bioreactors to the
bioreactor waste water tank;
• One (1) UV disinfection unit.
PROCESS DESCRIPTION
Graywater Equalization
Graywater from the laundry, accommodation sources,
the galley and the Somat system are transferred, either
automatically via continuous feed pumps or under
manual control by an engineer from the Engine Control
Room, from existing collection tanks to the equalization
tank, double-bottom tank N.3.C. Prior to entering the
equalization tank, the galley and Somat streams pass
through an existing grease trap to remove free oils and
grease. The blended graywater is pumped from the
equalization tank to the mechanical screens. The
transfer pumps are controlled by the ZENON system
PLC, which receives level signals from transmitters in
the equalization tank and the screened water tank.
Screening
Black water is transferred from four vacuum collection
system tanks. Each collection system is equipped with
a discharge pump that empties the collection tank based
on timer and level control operation. The flow of
blackwater to the ZENON system is usually
continuous; there can be periods of intermittent and
varying flow due to the manner the discharge pumps
operate. The black and graywater streams are blended
immediately before entering the twin (parallel)
mechanical screening units. Screened filtrate flows by
gravity into a collection tank; the screened solids are
discharged into a separate solids holding tank. Screened
solids rejected by the mechanical screens are collected
in the (36 m3 ) aerated solids collection tank and re-
hydrated using by the wasted sewage sludge;
approximately 700 kg/day are filtered from the
combined raw blackwater/graywater influent stream.
The holding tank is aerated to inhibit the development
of anaerobic conditions, which would cause odor
problems and generate potentially dangerous explosive
gases. A macerator pump recirculates the contents of
the solids holding tank to chop large size solids and
keep the solids in suspension. All waste solids are
pumped off the ship directly from the solids collection
tank to shore approximately every four weeks. Contents
of this mixture can include plastics and other prohibited
compounds from such items as condoms.
Bioreactor Feed System
The screened filtrate is pumped directly from the
collection tank to the two bioreactor tanks. The pumps
operate when water in the collection tank is above the
low-level set point and liquid in each bioreactor is
below the high-level set point. The pumps shut off
when the low-low level in the collection tanks or high-
high levels in both bioreactors are reached.
Bioreactors
The bioreactors are converted potable water tanks. The
ZeeWeed® membrane modules are contained in open-
topped ‘tubs’ installed in the main bioreactor tanks,
isolated from the main bioreactor volume by a vertical
partition and horizontal floor which span the width of
each bioreactor tank (Note: the tank modifications
included the construction of a cofferdam to separate the
bioreactor tank from the adjacent potable water tank).
Organics (BOD5 /COD) in the screened wastewater are
bio-oxidized and converted to CO2 , H2 O and bio-cells
in the bioreactors. Dissolved oxygen required for bio-
oxidation is supplied by two aeration systems that
consist of two air blowers and a fine bubble diffuser
array installed in the bottom of each bioreactor.
Recirculation pumps transfer the mixed liquor in the
bioreactor to the two ZeeWeed membrane ‘tubs’ for
solid-liquid separation; the mixed liquor then flows
over the edge of the tub partition back into the main
bioreactor volume. A portion of the mixed liquor
volume (bioreactor waste) is periodically pumped to
double bottom tank 3 port to limit the mixed liquor
suspended solids concentration to approximately 10,000
to 15,000 mg/l. Liquid levels in the bioreactors are
monitored and maintained at a constant liquid level by
controlling the permeate (effluent) production rate. The
permeate flow rate increases or decreases in proportion
to corresponding changes in the mixed liquor level until
the capped (pre-set) maximum or minimum permeate
flow is reached. Alternatively, limiting the differential
pressure measured through the membranes can be used
to regulate production.
15
ZeeWeed® Membrane Ultrafiltration
The cassettes are immersed in the tub assemblies
contained within the bioreactor tanks, in direct contact
with the mixed liquor. Through the use of a positive
displacement pump, a vacuum is applied to the top
headers of the membrane modules, which draws clean
water (permeate) through the hollow fiber membranes
while the solids rejected by the ZeeWeed  membranes
overflow back to the bioreactors. To minimize
membrane fouling, air is introduced to the bottom of the
membrane modules to scour the external surface of the
hollow fibers and move the rejected solids away from
the membrane surface. This airflow also provides a
portion of the oxygen that is required for biological
process.
Bioreactor Waste
Typically 10 to 15 m3 /day solids concentrated and
generated in the bioreactor mixed liquor are
periodically pumped to double bottom tank 3 port by
discharging a portion of the bioreactor contents. This
concentrated effluent is than pumped overboard
whenever the vessel is outside the 12-mile limit as
established in compliance with MARPOL regulations
and federal laws.
UV Disinfection
The permeate is subjected to a final polishing stage and
is discharged through a UV disinfection unit to assure
residual bacteria that may have penetrated the
membrane system is killed. A high level of ‘kill’
efficiency is achieved given the extremely low turbidity
of the permeate produced by the ZeeWeed 
membranes.
System Operation Control
The system is controlled via a PLC in either fully
automatic mode or manual modes, which are accessed
and manipulated via a Human Machine Interface
(HMI). The HMI enables the operator to start and stop
the system and make adjustments to the default settings
that govern the system in various operation modes.
EFFLUENT QUALITY
The treated water is almost potable and would meet
Environmental Protection Agency (EPA) drinking-
water standards with the exception of a few parameters,
most notably the total dissolved solids (TDS) and
nitrate limits. The performance criteria for the ms
Zaandam system did not require either parameter to be
controlled, however, the process could be modified to
reduce both to comply with EPA requirements if
specified by a client.
Holland America installed an onboard laboratory to
monitor system performance via means of simple
analytical methods. In addition, Holland America uses
independent shore-based laboratories to periodically
test preserved permeate samples to verify system
operation and validate their own monitoring methods.
The analyses routinely indicate the permeate has no
detectable fecal coliform per 100 milliliters and no
detectable suspended solids, surpassing the effluent
requirements of a Type II MSD defined by Code of
Federal Regulations 33 CFR 159. The Zaandam
installation was issued U.S. Coast Guard certification as
a Type II MSD (Certification No. 159.015/6500/0)
although the system’s actual performance far exceeds
Type II requirements. In the absence of any regulations
governing the operation and performance of MSDs
designed to process graywater, or combined gray and
blackwater, Type II certification was considered to be
Figure 5. – ZENON Immersed Membrane Bioreactor General Arrangement
The membranes are installed and accessed for
maintenance through watertight doors installed on the
bioreactor aft bulkhead. A fine bubble diffuser grid
was installed in the bottom of each bioreactor; the
grid provides the air required to support the
16
the best existing match for the ZENON system’s
capabilities.
Machinery Arrangement
The installation centers on the existing potable water
tank, which was converted to the combination
bioreactor/ZeeWeed process tank. Fresh Water Tank
N.51 Port, with an original capacity of 119,142 gallons
(451 cubic meters), was divided longitudinally in two
equal portions to accommodate the individual process
trains. A steel partition divided the two sections; a
cofferdam was also installed along the inboard side of
the converted tank to isolate the new bioreactor from
the adjacent fresh water tank N.51 Center. A steel tub
was fabricated in the aft end of each bioreactor volume
to contain the ZeeWeed membranes; this isolation was
required to facilitate chemical soak cleaning of the
membranes without resorting to draining the entire
bioreactor volume.
biological processes. The cassettes are supported by
upper and lower steel rails; the cassettes are installed by
positioning them by the watertight doors, hoisting them
up to the level of the rails, pushed into location and
secured with bolts; Figure 6 illustrates the diffuser grid
and membrane module installations. Although the
ZeeWeed tub volume constitutes a portion of the total
bioreactor volume, there was no need to install a
diffuser grid as the membrane modules feature coarse
bubble diffusers, which provide air to facilitate
ZeeWeed operation. Operating in two separate
trains, mixed liquor is recirculated between the tubs and
the main bioreactor volumes by pumps to assure the
solids stay in suspension and are well mixed; the liquor is
pumped from the bioreactors to the tubs, then overflows
from the tubs back to the bioreactors.

Figure 6. – Bioreactor Fine Bubble Diffuser Grid Membrane Modules Installations

All process equipment, with the exception of the four port side, primarily to accommodate their large size, but
blowers, was installed in the machinery space also to provide a measure of noise isolation (sound
immediately aft of the bioreactor. The blowers were attenuating enclosures will be installed on all future
installed in the space outboard of the bioreactor on the installations).

Figure 7. – Process Equipment and Membrane Module Access Watertight Doors

All system functions are controlled by the operator by a
Human Machine Interface (HMI) located on the main
electrical and motor control center panel. The operator
may regulate permeate production of each train
separately by setting the production flow rate or
limiting the differential transmembrane pressure (TMP)
applied to the membranes. The HMI displays all
critical system parameters, including instantaneous
flow, TMP, pH, mixed liquor temperature and total
dissolved solids (TDS) concentration, and permeate
turbidity. The system will also record total daily
permeate production.

17
 Figure 8. – Human Machine Interface Control Panel
ONBOARD LABORATORY AND SYSTEM
STARTUP
In addition to monitoring system performance and
parameters through the HMI, the system operator
performs daily manual measurements. The data is sent
to ZENON daily for the first six to eight weeks of
operation, the biological seeding and start-up period,
then weekly thereafter, allowing ZENON to provide on-
going support to operators as they rotate through their
postings to the ship. Monitoring through the start-up
period is critical to assure the bacteria grow at a desired
rate and become acclimatized to the influent
characteristics of the blackwater and graywater streams.
The bacteria may be added either as commercially
available seed or return activated sludge (RAS)
collected from a shore based municipal wastewater
treatment plant. Manual testing and monitoring is
performed only where on-line methods either don’t
exist or are considered unreliable. The tests performed
include:
• Dissolved Oxygen (DO) measurements in the
bioreactor mixed liquor, to assure sufficient oxygen
is delivered to the bacteria via the fine bubble
diffuser grids;
• Chemical Oxygen Demand (COD) in both the
mixed liquor and the permeate, to assure the
18
effluent quality is within acceptable limits by
inferring the Biological Oxygen Demand (BOD)
based on the COD measurement (BOD
measurements must be performed by professional
laboratories; samples are periodically collected and
preserved for later analysis;
• Total Solids (TS), Total Dissolved Solids (TDS)
and Total Suspended Solids (TSS) measurements to
determine the concentration of bacteria and
biological solids in the mixed liquor, and;
• Ammonia measurement to determine the quality
of the nutrients supplied to the bacteria from the
influent streams.
In addition, a simple 30-minute settling test is
performed on samples of mixed liquor collected from
each bioreactor to provide a quick qualitative means of
estimating TSS. Over time, a correlation between the
settling tests and direct TSS measurements can be
established such that the TSS tests need only be
performed on a weekly basis. The TSS test requires
several hours to complete as the mixed liquor samples
must be baked to dehydrate the solids prior to weighing
them. Weighing the samples using a laboratory balance
can also be difficult due to the rolling and pitching
motion of the ship in rough seas.
 Figure 9. – Onboard Test Laboratory
CONCLUSIONS
The Holland America Line Westours sewage and
graywater waste management system onboard the ms
Zaandam was found to far exceed the International and
U.S. Regulations and industry standard marine practice.
Additional ZENON bioreactor ultrafiltration systems
retrofitted to the fleet operating in Alaska ensure
compliance with the recently enacted Murkowski
legislation. Four newbuildings currently under
construction will be outfitted with similar systems.
A commitment has been made by Holland America
Management to raise the traditional bar of operation,
maintenance and performance of the MSD that has been
traditionally installed on vessels. This radically new
and different waste treatment system approach requires
minimal maintenance and attention and has proved very
reliable. This leadership role is enhanced with the
addition of a new environmental engineer position to
aid in enhancing operation of all pollution prevention
equipment onboard each vessel.
Holland America has taken the extra step to review all
chemicals used onboard and standardize to compatible
cleaning agents, environmentally compatible solvents
and eliminated all products that could create foaming or
disrupt the biological ecosystem necessary for the
bacteria to survive and flourish. Operation procedures
for each waste stream such as galley cooking oil have
been developed to ensure correct handling and disposal.
Further recognition was recently given by the USCG in
awarding Holland America Line Westours QUALSHIP
21 designation for on-board safety, environmental and
health regulation compliance. Holland America Line
Westours is to be commended for this high level of
compliance and the waste management equipment,
procedures and internal reporting in excess of the
regulations. Of particular note is the investment in
19
additional onboard Environmental Engineers and the
next generation of combined sewage/graywater
treatment plants that help promote clean water
operations.
Holland America is now exploring additional steps in
improving operations including reuse onboard of the
ZENON permeate as non-potable technical water for
service in the laundry and engine room. Another
possible area of conservation is the technology to dry
the sludge for incineration.
As the question of detrimental invasive species in
ballast water comes to the environmental forefront,
feasibility of using the 600 tons per day of clean
permeate for ballast looks promising. This may be the
ultimate clean and environmentally sound solution to
the often dangerous regulations to exchange ballast
water 200 miles out at sea, which is also impractical
due to routing. Due to the double duty served, systems
such as ZENON could be an effective alternative to the
added space, weight and cost of ballast water treatment
plants. This commitment by Holland America to
follow each and every waste stream to finality is an
example that would go a long way to protect the marine
environment, if everyone in the marine industry would
follow their lead.
REFERENCES

1. Dixon, Doug “Enhanced MARPOL Oil Pollution
Prevention - Holland America Line Case Study”
SNAME Pacific Northwest Section Meeting,
March 17, 2000
2. Dixon, Doug and Hughes, Greg “Coastal Cruise
Ship Waste Management” SNAME Joint
California Sections Meeting, May 13, 1999
3. Bonomo, Frank “Questionnaire on Annex IV of
MARPOL 73/78” USCG Position Statement
4. USCG email on MARPOL IV Signing, Frank
Bonomo to Doug Dixon, 9 January 2002
5. EPA Memorandum from Carol Ann Siciliano,
Attorney, Water Division (LE-132W) to Ann
Prezyna EPA Office of Regional Counsel Region X
re: State’s (Washington State Department of
Ecology) Authority to Prohibit the Discharge of
Sewage and Graywater from Vessels, September 4,
1992
6. EPA “Cruise Ship White Paper” United States
Environmental Protection Agency, August 22,
2000
7. ICCL “Cruise Industry Waste Management
Practices and Procedures” International Council of
Cruise Lines, May 14, 2001, Revised December
14, 2001
8. IRAC “Boating/Sewage Compliance Matrix”
Interagency Regulatory Analysis Committee
9. GAO “Marine Pollution - Progress Made to
Reduce Marine Pollution by Cruise Ships, but
Important Issues Remain” United States General
Accounting Office Report GAO/RCED-00-48,
February 2000
10. EPA Oceans and Coastal Protection Division
“Cruise Ship Plume Tracking Survey” July 30,
2001
11. Kim, Don K., P.E., M. Rosenblatt & Son “ICCL
Cruise Ship Waste Dispersion Analysis - Report on
the Analysis of Graywater Discharge ” September
14, 2000
12. Florida Department of Environmental Protection
(FDEP) “MEMORANDUM OF
UNDERSTANDING Florida-Caribbean Cruise
Association (FCCA)” March 14, 2000.
13. IMO “International Convention for the Prevention
of Pollution from Ships, 1973, as modified by the
Protocol of 1978 (MARPOL 73/78)” International
Maritime Organization, consolidated edition 2002.
14. Peterson, Randall; Monti, Sandro; Kopser,
Christopher “Application of Membrane Bioreactor
Technologies to Ship Gray and Black Water
Treatment” Maritime Environment International
Conference, Genoa, Italy, March 17, 2000
15. Bluewater Network “Petition to EPA to Address
Cruise Ship Pollution”, March 17, 2000
16. International Maritime Organization (IMO) Web
Site www.imo.org
17. International Council of Cruise Lines (ICCL) Web
Site www.iccl.org
18. Alaska Department of Environmental Conservation
(ADEC) Web Site
www.state.ak.us/local/akpages/ENV.CONSERV/pr
ess/cruise/cruise.htm
19. North West CruiseShip Association (NWCA) Web
Site www.alaskacruises.org
20. Environmental Protection Agency (EPA) Web Site
Cruise Ship Discharges
www.epa.gov/owow/oceans/cruise_ships
21. Holland America Line Environmental Policy Site
www.hollandamerica.com/aboutus/policies/environ
mental.htm
22. U.S. Navy Shipboard Environmental Information
Clearinghouse Web Site
http://navyseic.dt.navy.mil/
23. EPA Web Site
www.epa.gov/owow/oceans/vessel_sewage/vsdnoz
one.html No-Discharge Zone for Vessel Sewage

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