MOU
Major components
– Defines “Waters Subject to this MOU”
– Black water / Gray water / residual solids
– Limits, monitoring, stop discharge for upset or
disinfection problems, no discharges ½ mile from
shellfish beds
– Hazardous waste, solid waste, oily bilge water…
Amendments
Clarification changes, covers other ports in WA, Added annual
compliance report, Expands residual solids discharge ban to
entire OCNMS, DOH virus report recommendations
incorporated (2009)
MOU
Approvals to Discharge:
– 2009: two (2) vessels approved to discharge – both
continuously
– 2008 four (4) vessels approved to discharge – all
continuously
– 2007: five (5) approved continuously, one (1) at >1nm
– 2006: four (4) approved continuously, seven (7) at
>1nm
– 2005: four (4) approved continuously, four (4) at >1nm
– 2004: two (2) approved continuously, two (2) at >1nm
MOU Compliance
Compliance Evaluation
Discharge Approval Process
Inspections
Sampling Data
Annual Report/Records Review
Whole Effluent Toxicity Testing
Purpose – to evaluate whether there are potential
toxicity issues from vessel discharges
Required for vessels approved for discharge
continuously - once every 2 years for homeported
vessels or 1/40 port calls.
Results – toxicity from ammonia and possibly from
surfactants and detergents
MOU – Compliance History
2004 – Discharges of both untreated graywater and AWTS
effluent without approval
2005 – Missed Sampling
2006 – Missed Sampling; discharges of untreated
gray/treated black water discovered during inspection.
False report submitted. $100,000 fine issued/paid.
2007- Discharges of AWTS effluent without approval
2008 – Missed WET testing
The MOU Overall
Benefits
– Without state regulation specific to cruise ships, at least
have agreement in place to protect water quality
– Learning more about the vessels and equipment and
getting data
– Procedure for notification of noncompliance
– Still have enforcement capabilities for WQ violations and
press coverage if violate MOU
Issues
– Inability to enforce on the agreement itself
– Lack of coverage of MOU for other vessels
– Air quality issues not currently covered by the MOU
Broader Issues
State Legislative Action
History of bills being introduced to codify MOU
EPA Permit
Issued February 2009
Covers most commercial vessels >79 feet
26 discharge types covered (not black water)
Annual MOU meeting – agreed to continue with MOU, MOU more
stringent for certain requirements
Virus Protection
DOH virus study completed end of 2007, recommendations
incorporated into MOU
MOU Funding
THE END!
QUESTIONS?
