NVIC 04-04: Environmental inspection checklist for passenger vessels

Commandant 2100 Second Street, S.W. United States Coast Guard Washington, DC 20593-0001 Staff Symbol: G-MOC-2 Phone: (202) 267-2978 Fax: (202) 267-0506 Email: fldr-g-moc@comdt.uscg.mil COMDTPUB P16700.4 NVIC 04-04 13 FEBRUARY 2004 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 04-04 Subj: ENVIRONMENTAL INSPECTION CHECKLIST; ADDENDUM TO FOREIGN PASSENGER VESSEL EXAMINATION BOOK, CG-840 Ref: (a) General Accounting Office (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 Effluents in certain Alaskan Waters by Cruise Vessel Operations (d) Memorandum of Understanding (MOU) dated March 14, 2000 entered between Florida Department of Environmental Protection (FDEP) and the Florida-Caribbean Cruise Association (FCCA), a representative of the cruise industry in Florida (e) International Council of Cruise Lines (ICCL) Industry Standard E-01-01, “Waste Management Practices and Procedures”

Environmental inspection checklist; addendum to Foreign Passenger Vessel Examination Book, CG-840. — 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 passenger vessels with existing Federal and state environmental standards. These discussions have resulted in the checklist contained in Enclosure 1. This checklist is an extensive list of possible inspection items related to pollution prevention equipment, operation, plans and records. It is intended as a job aid to be used by Coast Guard personnel during certificate of compliance examinations onboard foreign-flagged passenger vessels. Additionally, this document does not change or establish new Coast Guard authorities, but is intended to provide Distribution - SDL No. 141 a b c d e f g h I j k l m n o p q r s t u v w x y z A B * 1 1 1 1 1 C 1 1 1 1 D 1 1 E 1 1 F G H NON-STANDARD DISTRIBUTION: B:a G-MOC, G-MO-1, G-MSE (1) 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.

Environmental inspection checklist; addendum to Foreign Passenger Vessel Examination Book, CG-840. — 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 decision- making 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.

Environmental inspection checklist; addendum to Foreign Passenger Vessel Examination Book, CG-840. — 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.

Environmental inspection checklist; addendum to Foreign Passenger Vessel Examination Book, CG-840. — 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/cgi- bin/useftp.cgi?IPaddress=162.140.64.21&filename=rc00048.pdf&directory=/diskb/wais/data/gao.

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 Alaska1. 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.

Environmental inspection checklist; addendum to Foreign Passenger Vessel Examination Book, CG-840. — 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.

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 commonly- called “PERC”) waste, used paints and thinners that contain hazardous substances, silver- bearing 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 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)