1. ASTM Committee F25 on Ships and Marine Technology Standardization for Marine Sanitation Devices Operator Perspective Randall R. Fiebrandt CDR/USCG(Ret) Director, Environmental Operations

2. NCL is member of CLIA, as is Carnival, Princess, Holland America, Costa, Royal Caribbean, Celebrity and 18 other smaller cruise lines. Worldwide fleet of 180 (+/-) ships of all sizes and shapes.

3. Typical Large (93,000 GT) Passenger Vessel in 2009 Passengers – 3000 Crew – 1000 Daily GW volume – 1000 m3 BW volume – 200 m3 Processed treated water – 1100 m3 Bio-residuals – 100 m3 Nearly double this for OASIS OF THE SEAS !

4. Most cruise ships are equipped with some brand of marine sanitation device, sewage treatment plant or Advanced Wastewater Treatment System Scanship Hamworthy Zodiac Evac Hydroxyl Zenon Rochem Navalis Triton Biopure Omnipure Orelis Red Fox

5. In 2001, NCL chose the Scanship option for all its ships (15 installations) Pre-screening Moving Bed Bio-reactor (MBBR) Chemical Precipitation & Flotation Micro-filtration UV Disinfection The latest 5 ships have incorporated the Scanship Total Solution, combining an integrated solid waste, wastewater, and bio-sludge treatment system.

6. MARPOL Annex IV is the worldwide standard for sewage treatment plants Annex IV permits discharge of untreated sewage (black water) when >12nm from the nearest land, or comminuted or disinfected black water when > 3nm from the nearest land, or anywhere when using an approved sewage treatment plant

7. By definition, an approved treatment plant is one that meets Resolution MEPC.2(VI) – 1976 Fecal coliforms < 250 /100ml TSS < 50 mg/l (shoreside testing) TSS < 100 mg/l (shipboard testing) BOD 5 <50mg/l Performance Tests Testing Considerations Periodic Surveys

8. And after 1 Jan 2010, an approved treatment plant is one that meets Resolution MEPC.159(55) – 2006 Thermotolerant coliforms < 100 / 100ml TSS <(35 + x) mg/l BOD 5 <25 mg/l COD <125 mg/l pH 6 < 8.5 Testing Considerations Surveys Training

9. Resolution MEPC.159(59) specifically states that the old resolution should be amended (so) the proliferation of differing unilateral more stringent standards that might be imposed worldwide be avoided Therein, lies the problem…. there is proliferation of differing standards !

10. US Clean Water Act (40 CFR 133.102): BOD 5 < 30 mg/l (30-day avg) w/ 85% removal rate BOD 5 < 45 mg/l (7-day avg) TSS < 30 mg/l (30-day avg) w/ 85% removal rate TSS < 45 mg/l (7-day avg) pH 6 < 9 USCG Type II (33 CFR 159): Fecal Coliforms < 200 /100 ml TSS < 150 mg/l

11. Alaska Standard (33 CFR 159.301): Enforced by the USCG 40 CFR 133.102 and Fecal Coliform: < 20 / 100 ml (geo mean) < 10% over 40 / 100 ml BOD 5 < 30 mg/l average TSS < 30 mg/l average pH 6 < 9 Total Residual Cl < 10 µg/l Continual sampling program – Scheduled and unannounced

12. Alaska Permit Standard: Fecal Coliform: < 14 /100 ml (average) < 43 / 100 ml (daily max) BOD 5 < 30 mg/l average TSS < 150 mg/l (daily maximum) pH 6.5 < 8.5 Total Residual Cl < 0.0075 mg/l InterimFinal Ammonia: <80.4 mg/l< 2.900 mg/l Cu (Dissolved): <0.066 mg/l< 0.031 mg/l Zn (Dissolved): <0.23 mg/l<0.081 mg/l Ni (Dissolved): <0.18 mg/l<0.0082 mg/l

13. Hawaii: Fecal Coliform < 40 / 100 ml TSS < 100 mg/l Canada: Fecal Coliform < 250 / 100 ml TSS < 50 mg/l BOD 5 < 50 mg/l Chlorine <0.5mg/l

14. Latest News! Baltic States are proposing a MARPOL Annex IV Baltic Sea Special Area for 2013 (existing)/2018 (new) where discharges must have Total nitrogen < 20 mg/l or at least 70% removal and Total phosphorus < 1.0 mg/l or at least 80% removal and 6.0 < pH < 8.5

15. Bottom Line Cruiselines would prefer a single worldwide standard that would allow for 24/7 discharge everywhere The cruise industry is a small segment of the worldwide marine industry and has difficulty getting support for our concerns The challenge is to determine a standard, that is acceptable to all and design affordable systems to meet that standard, consistently, on a ship platform Any standard must be performance based, to allow for future technological advances Anything ASTM can do to promote these goals is highly appreciated

16. Sidenote - Alaska Convening a 11-member science panel of experts on existing and emerging cruise ship wastewater treatment technology – January 2010 The volunteer panel will look at current and innovative wastewater technologies and evaluate installation issues. The panel will look at the quality of wastewater effluent now produced by cruise ships. It will explore treatment technologies currently used on-board ships and at on-shore facilities as well as those new applications under development.