5
Integrating Vessel and Shoreside Garbage Management

The preceding chapter addresses only part of a national Annex V implementation program—the part that applies to fleets. In addition to establishing performance standards for vessels, Annex V also mandates the provision of "adequate" garbage reception facilities at ports. Yet the crucial port side segment of the garbage management scheme conceived in Annex V is left undefined in the United States, with the result that compliance has been limited. If a comprehensive, effective Annex V implementation program is to be developed, then a systems perspective is needed that views vessels and their ports of call as part of the same system. Awareness of this need seems to be growing. Whereas the problem of marine debris once was viewed in isolation from broader waste management issues, there has been a trend over the past several years toward a more comprehensive systems-oriented perspective (Laska, 1994).

The vessel garbage management system has two elements: the vessel and the port, which is the transfer point to the landside solid waste management system. In general, vessels operate within and receive services from specific types of terminals. Just as vessels differ, so do terminals. Recreational boats use marinas, private docks, and launch ramps, while fishing vessels use fishing piers and terminals. General cargo vessels call at public ports (sometimes maintaining specified ports of call), while bulk vessels use private terminals and may operate only from selected home ports. All the materials delivered to and removed from the vessel must pass through the terminal's facilities.

As vessels become more specialized and diverse, so must terminals and the facilities they provide. Both vessels and terminals are costly to develop, build, and operate. Yet it is even more costly for a port to lose business to a competitor



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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea 5 Integrating Vessel and Shoreside Garbage Management The preceding chapter addresses only part of a national Annex V implementation program—the part that applies to fleets. In addition to establishing performance standards for vessels, Annex V also mandates the provision of "adequate" garbage reception facilities at ports. Yet the crucial port side segment of the garbage management scheme conceived in Annex V is left undefined in the United States, with the result that compliance has been limited. If a comprehensive, effective Annex V implementation program is to be developed, then a systems perspective is needed that views vessels and their ports of call as part of the same system. Awareness of this need seems to be growing. Whereas the problem of marine debris once was viewed in isolation from broader waste management issues, there has been a trend over the past several years toward a more comprehensive systems-oriented perspective (Laska, 1994). The vessel garbage management system has two elements: the vessel and the port, which is the transfer point to the landside solid waste management system. In general, vessels operate within and receive services from specific types of terminals. Just as vessels differ, so do terminals. Recreational boats use marinas, private docks, and launch ramps, while fishing vessels use fishing piers and terminals. General cargo vessels call at public ports (sometimes maintaining specified ports of call), while bulk vessels use private terminals and may operate only from selected home ports. All the materials delivered to and removed from the vessel must pass through the terminal's facilities. As vessels become more specialized and diverse, so must terminals and the facilities they provide. Both vessels and terminals are costly to develop, build, and operate. Yet it is even more costly for a port to lose business to a competitor

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea with better facilities, so port operators continually modify terminals, equipment, and services to reflect changes in vessels and shipping operations (Atkins, undated). Thus, there is a symbiotic relationship between vessels and their ports of call. Viewing the vessel and port as a system (henceforth referred to as the vessel garbage management system) significantly improves prospects for control and opens the door to solutions, fleet by fleet. This chapter examines the vessel garbage management system, exploring each element and what is needed to integrate vessel garbage into the system for handling land-generated waste. The introduction describes the principles of integrated waste management and how they apply in the maritime setting. The core of the chapter has two parts: an assessment of on-board garbage handling practices and technologies, and an assessment of port reception facilities and practices. The challenge is to maximize the garbage handling capabilities of both the vessel and port and then establish a seamless interface. If this can be achieved, then the goal of full Annex V implementation can be achieved. The final section of the chapter examines four issues that pose barriers to the internal integration of the system: quarantine requirements for vessels arriving from foreign shores, implementation of the Coast Guard's Certificate of Adequacy (COA) program and other requirements for ports, port operators' liability for handling vessel garbage, and financing—both who should pay for garbage services and how they should pay. PRINCIPLES OF INTEGRATED WASTE MANAGEMENT The Environmental Protection Agency (EPA) defines an integrated solid waste management system (ISWMS) as ''a practice of using several alternative waste management techniques to manage and dispose of specific components of the municipal solid waste stream. Waste management alternatives include source reduction, recycling, composting, energy recovery, and landfilling'' (ICF, Inc., 1989). Managers of ISWMS for land-generated waste select and employ these technical alternatives based on analysis of their needs, careful planning, and technical and economic evaluations of options. Implementation of Annex V to date has been guided—or misguided—by a perception that the effort to implement controls over vessel garbage should be separated from other initiatives to control land-generated solid waste. In fact, vessel garbage is simply a poorly controlled solid waste stream that, logic dictates, would best be managed using principles and systems similar to those developed for land-generated waste. Integration of the two systems, rather than development of redundant and parallel regimes for vessel garbage, could simplify implementation of Annex V and minimize the burdens on regulatory agencies and the regulated mariners and ports, in that all could pursue compliance with a

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea consistent national standard, operating within a coordinated regulatory regime. This approach would require the establishment of professional standards for waste management throughout the vessel-port system, as well as oversight and enforcement comparable to that carried out for land-based systems. It is clear that the general principles of integrated solid-waste management apply in the maritime setting. It is also clear that, with notable exceptions, these principles are not put to use consistently because there are important differences between land-based and maritime waste management. First, vessels may continue to discharge some garbage in the oceans legally, so long as they comply with Annex V. Second, waste treatment and storage capabilities are severely restricted on vessels, due to space and weight limits (this becomes an important factor in vessel design and retrofitting). Finally, vessels are mobile and may call at different ports, which has the effect of making garbage disposal demands more unpredictable and ad hoc than they are on land. As conceived by the committee, the vessel garbage management system depends on the key players to carry out the following roles: The role of vessel operators is to minimize waste through source reduction and to dispose of garbage in compliance with the law through on-board techniques and, where permissible, disposal at sea, and by delivering all other garbage to a port reception facility. The role of terminal operators and the port reception facility is to receive the remaining garbage and provide a simple process to transfer it to the well-developed disposal system for land-generated waste. The role of the existing land-based systems and their operators is to integrate the needs of vessel garbage handling into the system and to transfer technologies and methods into the vessel garbage management system. The role of boat manufacturers and shipyards is to ensure that all new vessels are designed to incorporate convenient garbage storage spaces and, where appropriate, garbage treatment technologies. The role of state governments is to help port and terminal operators establish and maintain garbage reception facilities. The role of the federal government is to provide clear legislation, criteria, and guidelines to ensure that this intermodal transfer of waste is simple, cost-effective, and in compliance with the U.S. commitment to MARPOL Annex V. The committee used this framework as a basis for identifying problems with existing procedures as well as potential solutions. The remainder of this chapter outlines how the disparate elements of the vessel-port transaction might be integrated into a process that meshes well with the prevailing national system for handling solid waste.

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea SHIPBOARD TECHNOLOGIES AND PRACTICES To apply the principles of integrated solid waste management, vessel operators first conduct a needs assessment, which includes determining how much and what sort of garbage is generated and the disposal restrictions in the waters where the vessels operate. A waste management plan then is developed. More often than not, such plans have been developed on an ad hoc basis out of necessity rather than based on engineering expertise. To assure zero discharge of plastics, plans call for waste sorting. It appears that the requisite behavioral change is occurring and that sorting can become a universal practice. Where garbage sorting procedures have been implemented, training and educational efforts (such as posters and placards) and process simplification (such as color coding and labeling of receptacles) have been cited as factors determining success (Kauffman, 1992). Many vessels have advanced and comprehensive waste management plans (National Oceanic and Atmospheric Administration Corps, 1993). In one instance, Navy personnel developed their own environmental compliance program—a "cookbook" on how to integrate garbage handling With other practices to meet environmental objectives (Gallop, undated). In addition, a number of fully integrated shipboard waste management systems have been designed. An example is the approach taken in constructing some of the newest passenger vessels, where the garbage handling and management system is designed concurrently with the vessel, to provide the best possible means of complying with Annex V. This approach elevates the mundane task of garbage handling to the same level of importance as all the other auxiliary systems considered during ship Construction (Deerberg, 1990, 1993; Vie, 1990; Florida-Caribbean Cruise Association, 1993; Laitera, 1993; Whelpton, 1993). Source Reduction An important step in integrated waste management is the effort to reduce amounts of materials brought on board that will become garbage. As indicated in Chapter 3, this type of early intervention in the hazard evolution process has been largely overlooked in the past but is an important aspect of Annex V implementation. Source reduction demands the cooperation of vendors as well as vessel operators and crews. A typical target in source reduction plans is plastic packaging. Each vessel operator tailors a source-control approach to fit the circumstances. Needs and supplies are examined, and excess packaging can be left on shore. The committee witnessed such source-control efforts at a cruise ship terminal. These procedures may create extra up-front work for the steward and staff but can reduce significantly the amount of garbage to be managed during the voyage. Another approach is to discontinue use of disposable plates, cups, and cutlery and equip the

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea vessel with durable serving pieces. Waste minimization can be encouraged or required as a condition for bids, contracts, and purchase orders. Consumables such as cleaning supplies and table condiments can be purchased in large receptacles for refilling smaller containers for daily use. Each operator devises bulk storage containers to store the necessary supplies without compromising health and safety. As some fleet operators reported to the committee, it is important that the changes do not compromise shipboard comfort and living conditions so much that the crew and/or passengers begin to resent the source reduction effort. It is always important to sustain the morale of those who are confined together on a vessel at sea. On-Board Storage A vessel operator may satisfy the mandates of Annex V by holding any restricted wastes and all plastic until the vessel returns to its home port or reaches a port reception facility that provides affordable, prompt service. Some commercial maritime operators feel that no U.S. port they visit has done an adequate job of organizing reception facilities and services, in that each garbage transaction is awkward and difficult. The committee was told of two shipping lines that prefer to hold all garbage generated while in U.S. waters rather than deal with U.S. port reception facilities as they exist now. The practice of storing wastes on board revives longstanding concerns over ensuring sanitation1 on vessels at sea. When vessels were slower, crews were larger, and there was less reliance on shoreside food preparation than is currently the case, vessel operators and builders were attentive to details that might predispose a vessel to problems with vermin or communicable diseases. Today, smaller crews must cope with not only tight itineraries but also complicated requirements for handling garbage such as food-contaminated plastics, which must be stored on board for disposal ashore. This is an issue that affects all maritime sectors. Yet the only federal guidelines on this topic, developed by the Centers for Disease Control and Prevention (CDC) Vessel Sanitation Program, apply solely to passenger vessels with international itineraries (i.e., cruise ships). Several incidents of serious contagious illness on passenger ships during the summer cruise season of 1994 (Dahl, 1994; Journal of Commerce, 1994) underscored the importance of safeguarding vessel sanitation. These incidents demonstrated that the government must retain a capability to monitor sanitation on all forms of domestic transportation and public accommodation. At present, such monitoring of vessels other than cruise ships is left to local and state health department personnel, who typically will respond to a request from a Coast 1   For purposes of this report, sanitation refers specifically to the promotion of hygiene and prevention of disease through proper handling and storage of garbage (not sewage).

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea Guard boarding officer to examine a ship (J.M. Farley, U.S. Coast Guard, personal communication to Marine Board staff, September 1993). One way to help ensure sanitation would be to strengthen the federal program of vessel inspections in ports, through either the CDC or the Food and Drug Administration's existing Program on Interstate Travel Sanitation. The operations manual used to check sanitation on cruise ships (Centers for Disease Control, 1989) is an example of an approach that could be integrated into vessel inspection programs. The provision of standard guidelines for maritime sectors other than cruise ships could help assure that sanitation is not compromised in the pursuit of Annex V compliance. Some fleets also may need technical assistance in developing safe and efficient on-board storage procedures. On-board garbage storage facilities can be designed to provide for quick and easy off-loading at ports while preventing unintended loss overboard. Facilities range from secured plastic bags for day trips to large dumpsters requiring mechanical off-loading (Mike Prince, marine superintendent, Moss Landing Oceanographic Laboratory, personal communication to Marine Board staff, February 4, 1994). Waste storage areas on vessels can be designed or modified to isolate certain types of wastes, minimize odors, and prevent vermin infestation. The Navy is experimenting with odor-barrier bags for storing food-contaminated plastics on board (Koss, 1994). Shoreside Recycling Assuming adequate on-board storage space is available, port waste disposal volumes can be reduced if recyclable materials are separated. Easily recycled materials include aluminum and steel cans, glass bottles, plastic bottles, newspapers, and cardboard packaging. Other materials that may be recycled include metal parts, fishing nets, ropes, and other gear.2 As noted earlier, sorting is best accomplished with standard, color-coded containers and simple, appropriate training programs (Princess Cruises, 1993). Each vessel operator tailors training to fit the circumstances. Short videotapes, followed by practice and demonstrations, greatly assist in crew training. Similar educational programs may be developed for passengers, emphasizing the need for their cooperation in improving the vessel's waste disposal practices. Obviously, recycling only makes sense if the port reception facility and the land-based ISWMS can accept the specific, separated recyclable materials. A few pilot programs have demonstrated the feasibility of recycling vessel garbage, but few permanent arrangements are in place (Middleton et al., 1991; Kauffman, 1992). 2   A recycling infrastructure has evolved for many land-generated waste materials as the popularity of recycling has grown (Grove, 1994).

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea Some of the most advanced vessel garbage handling procedures and equipment can be found on cruise ships. The top photo shows a garbage sorting area. Sorting is essential both to ensure that plastics are held on board and to separate recyclable materials from other garbage. The bottom photo shows a commercially available compactor that reduces aluminum to 1/30th of its former volume and tin to 1/10th of its former volume. These materials then are baled and brought ashore for recycling. Credit: Princess Cruises

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea Treatment/Destruction If there is room to install appropriate equipment and organize on-board storage, a range of technologies for treating or destroying garbage is available and in use on vessels. The amount of garbage generated, as well as Annex V operating restrictions, may dictate which methods and technologies are employed. Many types of commercial equipment can be purchased for shipboard use, although little testing and evaluation has been carried out to determine whether the size and ruggedness meet shipboard needs. The International Maritime Organization (IMO) Guidelines for Implementation of Annex V encourage the further development of shipboard technologies, acknowledging that the present state of the art is wanting. Vessel operators in some sectors, such as the passenger cruise industry, work with equipment vendors and engineers to meet individual needs, but the potential markets for many of the needed technologies, such as those for commercial fisheries, are too small to attract commercial developers. The cruise ship industry has invested heavily in state-of-the-art equipment, including shredders, pulpers, compactors, and incinerators. These technologies have been retro fitted on existing ships and incorporated into the design and construction of new ships. In addition, the industry works closely with naval architects, shipyards, and equipment suppliers to improve the technology. The Navy is the only federal agency that has been able to develop, test, and evaluate shipboard garbage handling technologies. The results have not been widely applicable to either the civil maritime sector or other public vessels, so there remains a need for product and systems development to support Annex V implementation. The maximum benefits could be derived from garbage treatment technologies, both existing and new, if information about them were exchanged promptly among the various maritime sectors. Compactors A compactor is a powered device used to reduce the volume of garbage, to facilitate storage during a voyage. Many such units are available commercially and most are sized to fit the needs of vessels; the committee observed successful shipboard use of compactors purchased at retail outlets. The Navy began developing compactors in 1979 but cancelled this research in 1993, deciding it was no longer necessary (U.S. General Accounting Office, 1994a, 1994b). Compactors are the backbone of the Coast Guard's Annex V compliance plans. High-volume, low-density materials, such as plastic bottles, containers, and sheeting can be compacted easily to as little as 10 percent of their former volume. Other recyclable materials, such as metal cans and even paper products, can be reduced to 25 percent of their original volume. Volume reduction of glass (e.g.,

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea bottles, containers, bulbs, plate glass) is best achieved with glass crushers, which shatter rather than compress the materials. A plastics processor, such as the one being developed by the Navy, is a hybrid of a shredder, a compactor, and a thermal treatment device. Plastic materials are shredded and then compressed and heated (not combusted) to form fused bricks of plastic. Developers claim the process produces sterile blocks that meet the federal quarantine standards for food-contaminated plastics. If such claims can be substantiated, then the device may be attractive to maritime operators struggling to satisfy both Annex V and Animal and Plant Health Inspection Service (APHIS) mandates. Compactors may reduce the cost of waste disposal by reducing the volume of materials to be handled. Wastes destined for quarantine may be suitable for compacting, but APHIS treatment standards are calibrated on normal-density, uncompacted wastes. Those standards fail to meet the complete needs of the Annex V regime. To support Annex V implementation and expanded use of compactors aboard ships on international voyages to the United States, APHIS could arrange a series of calibration tests to establish appropriate quarantine treatment of compacted wastes. (A range of calibrations might be needed to allow for differences in compaction among units.) Compactors are considered safe and efficient and are suitable for vessels that remain at sea for up to two or three days. These units effectively compact most shipboard garbage into paper or plastic containers, which can be sealed and stored safely on board for short periods until disposal ashore. Builders of small vessels could consider offering compactors as part of an integrated on-board garbage management system. Such technology could be incorporated readily into the design and construction of new vessels, and retrofitting may be a viable option on some existing vessels. Comminuters, Pulpers, and Shredders A comminuter is an oversized garbage disposal that reduces food scraps to a finely chopped residual, which is rinsed out of the unit with a steady stream of water. The effluent is a slurry of water and food bits. Commercial devices are made specifically for marine use. Annex V permits discharge via a comminuter, which is the single piece of shipboard equipment for which the Annex establishes a performance standard (see Appendix B, Annex V, Regulation 3). Therefore, disposal of food wastes is not a problem, because they can be ground up and discharged into the ocean3; the organic detritus can be assimilated into the envi- 3   A greater problem is disposal of food-contaminated cellulosic material, such as paper, waxed paper, paperboard, cartons, and cellophane. Cellulosic materials also can be ground up, but it is difficult to separate out plastic coatings and film to prevent their discharge.

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea ronment. Even so, food discharges are prohibited within 3 miles of the coast (12 miles in all special areas except the Wider Caribbean). A pulper is a powered device that reduces paper, cardboard, and other readily pulped materials into a mush that resembles papier-mâché. This pulp is rinsed out of the unit with a heavy, continuous stream of water, and the effluent is a slurry of pulp and water. A commercial unit has been manufactured for years. The Navy improved this device for its own shipboard use, developing both a small unit and a large unit designed for continuous heavy use. The small pulper can process up to 64 kilograms (kg) (140 pounds [lbs.]) per hour of mixed wastes, including paper, cardboard, and food wastes. The large pulper can process up to 308 kg (680 lbs.) of mixed wastes per hour. Both units capture plastics and metal and prevent their discharge. This equipment is designed to occupy the least amount of space possible and can be maintained in place; even so, the units resemble large industrial washing machines set on angled foundations. Use of pulpers can reduce the aesthetic problems caused by intact garbage and permit discharges closer to shore than otherwise would be allowed. Some Navy personnel even see pulpers as an acceptable means for discharging wastes other than food (or plastics) into special areas. They assert that the biodegradable, pulverized, cellulosic effluent poses no harm, even in highly sensitive environments. The Navy is conducting research on this issue. At present, however, Annex V and the Marine Plastics Pollution and Control Act (MPPRCA) prohibit discharge of nonfood wastes into special areas. As noted in Chapter 2, little is known about the behavior or effects of pulped garbage, paper, or cardboard in the marine environment. Larger, denser particles such as bone and seeds settle rapidly, while small particles could become widely dispersed in the surface water layers. Some fraction of pulped waste may float and eventually be found on beaches, while some accumulation of pulped waste could be expected on the sea floor of shallow special areas, such as the Persian Gulf and Baltic and North seas (Swanson et al., 1994). Another way to treat paper on board vessels is with shredders, machines with rotating blades that also can be designed to shred bones, metal, glass, and plastics. One cruise line employs four types of shredders: a bone shredder and crusher; a paper shredder used upstream of an incinerator to improve combustion; a glass shredder and crusher; and a plastics shredder used prior to storage of this material (Richard Wade, Princess Cruises, personal communication to Marine Board staff, August 29, 1994). The Navy's shredder originally was designed to process 272 kg (600 lbs.) of glass and metal per hour (Swanson et al., 1994). The pieces were to be placed in burlap bags and thrown overboard. This plan has been abandoned and the shredder technology is now part of the Navy's plastics processor. Once thrown overboard, bags of metal and glass tend to settle to the ocean floor. Swanson et al. (1994) estimated that, to ensure sinking, the ratio of metals to glass in a bag should be at least 1 to 2. Some bags may be recovered by

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea fishermen using trawls or scallop or clam dredges. Other bags will deteriorate eventually and the contents will become part of the sedimentary record. Incinerators Incineration devices range from primitive "bum barrels" to complex dual-chamber systems with sophisticated emission controls. True incineration uses controlled combustion to achieve near-total destruction of waste with minimal emissions, so the more rudimentary bum barrels and older "fireboxes" seen on some ships are not representative of the technologies now available (Chang, 1990). The latest models have multiple chambers in order to maximize combustion of the waste and consume the resulting gases, and some of the exhaust heat can be reclaimed for other uses (Whitten and Wade, 1994). The IMO recently adopted standards for shipboard incinerators in order to document the technologies acceptable under Annex V and establish combustion performance standards in line with modem capabilities (the standards may be found at the end of Appendix B). The government of Bermuda also has established standards and licensed two ships to use incinerators (T. Sleeter, senior surveyor, Bermuda Ministry of the Environment, personal communication to Marine Board staff, June 2, 1994; Bermuda Ministry of the Environment, undated). Properly designed and operated incinerators can bum successfully most types of garbage, including paper, cardboard, and, under certain conditions, plastics (metal and glass cannot be burned). A number of acceptable, purpose-built marine designs are manufactured and sold for commercial use. Several units with tailor-made sorting and ash-handling systems are now in service (see Figure 5-1). These integrated systems have enabled passenger vessels to comply with Annex V in situations where compliance would have been unmanageable otherwise. Many recently constructed cruise ships have one or two high-capacity incinerators (Whitten and Wade, 1994), and some government vessels are equipped with incinerators as well. The National Oceanic and Atmospheric Administration, despite some poor experiences with units installed on its fleet, has been advised to equip its vessels with either trash compactors or appropriately designed incinerators (Art Anderson Associates, 1993). The Coast Guard has purchased and installed a prototype unit meeting IMO standards on one of its cutters (Sara Ju, Coast Guard, personal communication to Marine Board staff, August 18, 1994). It is important that the equipment selected be appropriate, that seafarers learn to use it proficiently, and that the units not be misused. Controlled combustion must be sustained in order to get good waste destruction; an incinerator is not appropriate for a vessel that generates very little or erratic amounts of waste. If fed too little waste, or surges of waste, an incinerator can perform poorly; either destruction may be inadequate or operating problems may arise within the unit. Thus, there are many instances where a vessel operator would do well to avoid relying on an incinerator. On the other hand, incinerators may be appropriate for

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea Managers of APHIS programs also have attempted to respond to the sudden increase in the need for their services resulting from Annex V and the COA program. Before Annex V, APHIS waste haulers typically were not allowed to transport quarantined wastes through rural areas. This policy was changed in 1988 to allow certified waste haulers to transport containers of garbage through rural areas and for long distances. Also in 1988, following passage of the MPPRCA, the Coast Guard was directed by law to require ports to prove they could provide reception facilities for quarantined garbage; without such a capability, a port was unlikely to receive a COA verifying its compliance with Annex V. In 1987, only 32 ports had facilities that were approved to handle garbage under USDA regulation; by 1992, most U.S. ports had USDA-approved garbage handling procedures and appropriate equipment (Caffey, 1993).14 Access to proper equipment may be limited in certain cases, however. Some hospitals and international airports have the technology, for example, but their operators, fearing damage to the equipment, generally decline to make it regularly available for vessel garbage (Carangelo and Buch, 1993). The same compliance agreements and supervision provisions are used to handle both vessels and passenger aircraft, and the airport side of the quarantine program seems to function well.15 However, there is at least one major difference between APHIS operations at airports and those at seaports: Quarantined garbage is removed from aircraft at the end of each flight due to the lack of on-board storage space, while ships do not necessarily off-load any waste in port. Furthermore, compliance agreements at airports are with caterers, who personally board aircraft and remove regulated garbage, whereas compliance agreements at seaports are with waste haulers, who do not board vessels and therefore have no control over what is off-loaded. All of this means that waste haulers at ports, because their APHIS services are in less demand than are those of airline caterers, have less market incentive to comply with regulations and thereby maintain and attract business. The airport practices may have the effect of increasing control over garbage management, in addition to freeing up on-board space for storage of additional garbage. Both of these effects are desirable. In summary, the committee identified four basic problems related to the 14   Because APHIS allows waste haulers to transport waste for long distances, numerous ports deemed capable of providing APHIS waste reception facilities actually have no such facilities. Instead, the garbage is transported to facilities elsewhere. That extra shipment certainly increases the disposal cost to ship operators using those ports. 15   Airports enter into agreements that make compliance easy and routine. The quarantine practices do not cause delays in flight operations. The garbage removal is performed largely by airline caterers in well-monitored kitchens on the airport premises (Carol Hearer, Ogden Aviation Services, personal communication to Marine Board staff, October 17, 1991). In addition, APHIS prepares training materials in multiple languages for new catering employees, to reinforce the need to adhere to quarantine practices (Caffey, 1991).

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea APHIS regime. One, high disposal costs, is outside the committee's scope. The second problem, the confusion over what types of garbage are subject to quarantine, is relevant to the committee's task, in that Annex V compliance depends in part on widespread understanding of proper garbage handling practices. The third problem, the lack of full integration of the APHIS and Annex V regimes, is directly relevant to the present study because it is further evidence of the need for a systems approach to vessel garbage management. The overlay of Annex V on APHIS regulations may compound confusion and compliance problems among vessel operators. The fourth problem, the lack of a requirement for off-loading of APHIS waste at U.S. port calls, is related to the need for integration of the APHIS and Annex V regimes. As noted earlier, vessels are not required to off-load Annex V garbage either, although other nations have adopted such mandates and there may be good arguments for doing so. If vessel operators were required to off-load Annex V garbage, then the adoption of parallel requirements for APHIS waste would have the multiple benefits of fostering integration of the two regimes, freeing up much-needed space on board, and bringing the seaport side of the quarantine program into line with the airport side. This concept is applicable primarily to cargo and passenger cruise ships, which may generate large amounts of garbage, including APHIS waste, and routinely call at commercial ports. Port Accountability Also of concern are the significant gaps in port controls. The COA program and the related requirements covering smaller terminals are meant to assure the existence of a complete garbage management plan that covers, among other things, the handling of APHIS waste. But the certification process only shows that the structure for compliance exists within a port serving large tankers or fishing vessels16; there is little verification that the structure actually functions as described. Similarly, while reception facilities also are required at small fishing piers, recreational marinas serving 10 or more boats, and terminals serving offshore oil and gas operations, the Coast Guard neither inspects the facilities nor requires that COAs be obtained. Still another problem is that regulations do not identify clearly the parties responsible for implementing APHIS requirements in a terminal or port. Because the current regulations are not comprehensive (the many small, unattended piers and launch ramps are not covered), do not assign responsibility for port improvements, and do not require record keeping or inspections, the system of controls is primarily an exercise in paperwork. 16   As noted in Chapter 1, the COA program applies to ports and terminals serving vessels of 400 gross tons or more carrying oil or noxious liquid substances, or those that serve fishing vessels that cumulatively off-load more than 500,000 pounds of commercial fishery products during a calendar year.

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea Nonetheless, if the overall garbage management system is to be strengthened, then the COA program is a logical starting point. Several MPPRCA amendments have been proposed that would require inspections of COA facilities when the owner or operator changes, make COAs valid for a five-year time period, require inspections before issuance of new certificates, and mandate examinations of all non-COA holding facilities. If adopted, these provisions may be helpful. Even so, designing and administering the COA program is a heavy burden on the Coast Guard, which has no expertise in waste management and might be overwhelmed by the attempt to ensure that the more than 10,000 U.S. ports provide garbage reception facilities that are truly adequate. The more logical authorities for overseeing the landside of the vessel garbage management system are the EPA, which has extensive expertise in handling waste of all types, and the states, which develop solid waste management plans authorized by the Resource Conservation and Recovery Act (RCRA) (P.L. 94-580), as amended.17 (States must submit these plans, which detail regulations and strategies, in order to avoid having EPA take over their programs.) Unlike the Coast Guard, the EPA and the states employ waste professionals who are engaged full-time in managing regimes for solid and industrial waste. At present, the Coast Guard is the primary government authority with official responsibility for overseeing port reception facilities. But the committee has obtained a legal opinion stating that RCRA and the regulations are sufficiently broad that they arguably could allow a state's solid waste management plan to cover a vessel docked at a port in the state (Dana J. Schaefer, Parkowski, Noble and Guerke [Dover, Delaware], personal communication to a member of the Committee on Shipborne Wastes, March 23, 1994). The EPA could establish technical standards for determining whether port reception facilities are ''adequate,'' and states could assure that the standards were met as part of their waste management planning process. The EPA has supported similar technical assistance when other waste streams have been brought under federal control (U.S. Environmental Protection Agency, 1990a and 1990b; Council of State Governments, 1992). Certainly in Texas and New Jersey, where reducing waterborne and beach debris is a top public priority, full integration of port reception facilities into the state ISWMS would be a logical approach. Either legislation or a regulatory directive might be required to bring the EPA into this process.18 To supplement the COA program, other government agencies that regulate ports could help assure the adequacy of port reception facilities. State govern- 17   These provisions are codified at United States Code, Title 42, Sections 6941-6949. 18   The EPA interprets current requirements as addressing permanent disposal structures (40 C.F.R. §258 establishes minimum criteria for landfills, which are considered permanent structures with lasting impact on the environment). Dumpsters and other temporary facilities are considered disposal practices, which the EPA has chosen not to regulate.

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea ments issue permits related to matters such as waterfront construction and environmental regulations and could review or require port reception facilities as a condition of granting permits to ports. In addition, the U.S. Army Corps of Engineers routinely surveys and approves new docks and other port structures and could review the adequacy of port reception facilities as a part of this process. Review of port reception facilities as part of existing regulatory processes could help foster Annex V compliance without overburdening government agencies. Liability Since the late 1970s, the U.S. Congress has enacted several laws (e.g., RCRA and the Comprehensive Environmental Response, Compensation, and Liability Act [CERCLA] [P.L. 96-510], known as the "Superfund" law) that changed the legal responsibilities of those who create wastes and those who handle, transport, or treat wastes. The intent has been to remedy problems caused by old practices and to halt the use of ineffective practices. In fact, many practices have been abandoned under the new laws, and the government has supported substantial technical research to help develop new, more reliable techniques for handling wastes of all kinds. The RCRA and CERCLA regimes also have gained public recognition because of their emphasis on punishing offenders and allocating liability for damages resulting from poor waste disposal practices. Legal precedents have been established in this arena that expand the range of entities that can be held accountable for a polluting event, well beyond the obvious candidates. In particular, the "cradle-to-grave" model that forms the basis of these regimes establishes legal liability for everyone who comes into contact with a waste material. Many businesses, concerned that they might become entangled unwittingly in the legal consequences of poor waste handling, have imposed strict audits and controls on their own waste generation and on the haulers who service their facilities. It should be no great surprise, then, that fear of being saddled with liability for vessel waste handling is impeding implementation of Annex V (Pisani, 1989). Both public and private port operators are concerned that a more active role by public authorities in developing and overseeing a vessel garbage management system would expose ports to liability, particularly with regard to APHIS and hazardous wastes. As a result, vessel owners have been on their own in identifying and implementing waste disposal alternatives, at least in the United States. Those who drafted Annex V did not anticipate placing ports in legal jeopardy; nevertheless, this issue requires attention if ports are to become active players in the development of an effective vessel garbage management system. In the judgment of the committee, concerns over port liability are not well justified at this stage. If port reception facilities were integrated into the national ISWMS, then much of the uncertainty over liability would be eliminated. Management systems for other forms of waste seem to work well and address liability

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea concerns. For example, in the medical and hazardous waste programs, records are kept that can link the generator to the disposal process. The chain of custody is established, and liability is shared by all those involved; if problems arise, then the waste can be tracked and the culprit identified. Who Should Pay? There is considerable debate over who should pay for vessel garbage services. On one level, the question is whether these services are a public responsibility, to be funded by government regardless of the amount of garbage or level of service use, or a private responsibility, to be paid for only by those who use it. On another level, the question is, what funding mechanism should be used? These questions need to be answered if the vessel garbage management system is to be effective and efficient. Fundamentally, there are three options. One is for each vessel or agent to arrange for garbage services individually, with no port involvement beyond the provision of adequate reception facilities. This is the current approach. While in keeping with the government's free-market policy, this method has allowed for wide variations in disposal fees and, in some cases, inadequate facilities. The inconsistency among disposal fees and the perception that costs are too high have discouraged some vessel operators from off-loading garbage,19 which then may end up in the ocean or at ports with less-expensive fees but inferior disposal practices. With respect to the adequacy of facilities, the U.S. debate on this issue has not addressed the true costs (including debt service) of providing additional garbage services. It may be that these costs deter port operators from upgrading facilities. This situation needs to be examined in detail, to determine whether the free market can provide for adequate facilities.20 In other pollution-control arenas, the federal government has offered a variety of incentives and financing 19   A Coast Guard survey revealed that vessel operators may avoid using U.S. port reception facilities for several reasons, including a perception that disposal costs are exorbitant, confusion over the distinction between Annex V garbage and APHIS waste, cost differences among states, and variations in the types of containers used (North, 1993; U.S. Coast Guard, 1993). The Coast Guard has suggested that one way to improve Annex V compliance would be to reduce the cost of garbage disposal options (Eastern Research Group, 1992). 20   The experience in Corpus Christi suggests that a port making a large investment in garbage services is unlikely to see corresponding returns. The Port of Corpus Christi Authority constructed a modest steam boiler, which beginning in mid-1989 was operated full-time by a port employee as an APHIS-certified facility. Costs were high: In addition to the initial $100,000 capital investment, the port had to assume liability for waste treatment (Carangelo and Buch, 1993). The facility was shut down in early 1994 because, ironically, the waste hauler found it cheaper to track quarantined materials to Houston.

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea vehicles to make funding available to compensate for market hesitation. Such an approach might be warranted as part of Annex V implementation. The second option is for garbage services to be covered by the tariff that, in some ports, is paid by all vessel operators, regardless of whether garbage is deposited. This approach is the simplest option to administer but distributes the costs among parties who do not benefit directly. Moreover, ports are moving away from tariffs. The third option is to impose a standard fee for garbage services actually used. This approach conforms to the pattern for other services, which vessel operators pay for on a fee-for-service basis. It has been suggested that ports should participate in setting or capping garbage-disposal rates. Both the second and third options would require that a port arrange for garbage services for all vessels calling there and assure that the costs of those services were covered in some manner by tariffs, fees, or some other revenue source. Then the question becomes whether private terminals should be subject to the same rules as public terminals. In the absence of a cohesive national port system, the federal government may need to initiate discussions of these issues as part of its effort to assure that adequate port reception facilities are provided. Regardless of which option is pursued, it may be prudent and indeed necessary for port authorities to work cooperatively on a wide scale (either regional or national) to establish a common fee for garbage hauling, independent of the port receiving the ship. Because the crucial parameter is the prevailing cost in the land-based disposal system, there is little basis for neighboring ports to diverge much from those fees. Long-term arrangements might offer an economic benefit; a ship operator who purchased waste-hauling services only occasionally would pay a higher fee than would a customer who negotiated a long-term contract. SUMMARY The preceding analysis of vessel garbage management as a system identifies numerous opportunities for improving the system and thereby the implementation of Annex V. On the vessel side of the system, the government could provide three general types of assistance designed to foster Annex V compliance: Technology Assistance. A range of on-board garbage handling and treatment technologies is available. In some cases, commercial equipment can be purchased, but available technology may be inappropriate, due to its size or operating features. Some vessel operators may require assistance in locating available equipment or adapting or developing improved or more appropriate units. The federal government could facilitate technology transfer, so that all maritime sectors could make maximum use of information about Navy and cruise industry R&D, as well as equipment designed for land use. The government also could establish a program to develop, test, and evaluate shipboard technologies

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea for wide application. The Maritime Administration could lead the effort, or the Navy R&D program could be expanded to develop on-board garbage handling and treatment technologies for commercial use. Guidance on Key Issues. Federal agencies could take steps to resolve issues that may be impeding safe garbage storage and expanded use of garbage treatment equipment. Guidelines on shipboard sanitation could be developed and technical assistance provided for all fleets to ensure that on-board storage procedures were safe. To support expanded use of trash compactors, APHIS could develop standards based on compacted waste. And, to foster proper use of incinerators, the EPA could adopt the IMO standards for shipboard incinerators. Financial Assistance. Some fleets, notably the fisheries sector, may require financial assistance in order to achieve compliance. The NMFS could offer financial assistance for research on and installation of garbage handling and treatment technology to fisheries fleets. To expand access to this assistance, the NMFS could consider waiving the $100,000 minimum expenditure requirement for the Capital Construction Fund Program. Turning to the port side of the system, there is little evidence of strategic planning to support the provision and use of adequate garbage reception facilities. Steps could be taken in five areas to improve the vessel-port interface: Require Cargo and Cruise Ships to Off-Load Garbage at U.S. Port Calls. Such a requirement would help ensure that large commercial ships use port reception facilities and thereby increase government control over the vessel garbage management system. Strengthen the Recycling Infrastructure. The vessel garbage management system could benefit from an improved infrastructure for recycling, to take advantage of this now-standard mechanism for reducing waste streams. Transfer Oversight of Port Reception Facilities to EPA and the States. Responsibility for port reception facilities could be assumed by waste management experts within EPA and state governments; EPA could set technical standards, and states could assure that the standards were met as part of the waste management planning process under RCRA. State governments also could review or require port reception facilities as a condition of granting permits to ports. Improve Integration of the Annex V and APHIS Regimes. The federal government could make it easier for vessel operators to comply with all applicable Annex V and APHIS regulations. Such an effort would involve educating mariners about both Annex V and quarantine requirements, ensuring that any off-loading requirements were parallel, and working toward a system that would require vessel operators to make Only one arrangement for handling of both types of garbage in a port. Address Payment Issues. Attention to the question of who should pay for

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Clean Ships Clean Ports Clean Oceans: Controlling Garbage and Plastic Wastes at Sea garbage services, and how, could help ensure that port reception facilities are adequate and that vessels use them, instead of the oceans, for disposal of garbage. As part of this process, ports may need to cooperate in setting fees. The federal government may need to initiate discussions of these issues. REFERENCES Art Anderson Associates. 1993. NOAA Fleetwide Shipboard Waste Management. Report prepared for the National Oceanic and Atmospheric Administration by Art Anderson Associates, Bremerton, Wash. Jan. 29. Atkins, W.H. Undated. Modern Marine Terminal Operations and Management. Oakland, Calif.: Port of Oakland. Bayliss, R. and C.D. Cowles. 1989. Final Report on the Impact of MARPOL Annex V Upon Solid Waste Disposal Facilities of Coastal Alaskan Communities. NWAFC Processed Report 89-20, prepared for the Southwest Alaska Municipal Conference. Available from the Marine Entanglement Research Program of the National Marine Fisheries Service (National Oceanic and Atmospheric Administration), Seattle, Wash. October. Bermuda Ministry of the Environment. Undated. Standard Operating Conditions for Cruise Ship Incinerators. Available from the Ministry of the Environment, Government Administration Building, 30 Parliament Street, Hamilton HM 12, Bermuda. Burby, R. and R.G. Patterson. 1993. Improving Compliance with state environmental regulations. Journal of Policy Analysis and Management 12(4):753-772. Caffey, R.B. 1991. Presentation by Ronald B. Caffey, Animal and Plant Health Inspection Service, to the Advisory Panel for the Shipping Industry Marine Debris Education Project of the Marine Entanglement Research Program (National Oceanic and Atmospheric Administration), at the Kearney/Centaur office, Alexandria, Va., Feb. 11, 1991. Caffey, R.B. 1993. Testimony of Dr. Ronald B. Caffey, assistant to the deputy administrator, Veterinary Medical Office, Plant Protection and Quarantine, Animal and Plant Health Inspection Service, before the Subcommittee on Superfund, Ocean, and Water Protection of the Committee on Environment and Public Works, U.S. Senate, 102nd Congress, Second Session, Washington, D.C., Sept. 17, 1992. Pp. 28-30 in Implementation of the Marine Plastic Pollution Research and Control Act. S. Hrg. 102-984. Washington, D.C.: U.S. Government Printing Office. Carangelo, P. and T. Buch. 1993. Presentation by Paul Carangelo and Tex Buch, Port of Corpus Christi Authority, to the Committee on Shipborne Wastes of the National Research Council, at the Port of Corpus Christi Authority, Corpus Christi, Tex., February 17, 1993. Centers for Disease Control. 1989. Vessel Sanitation Program Operations Manual. Available from the U.S. Public Health Service, Vessel Sanitation Program, 1015 N. America Way, Miami, Fla. 33132. Chang, T. 1990. Low technology (burn barrel) disposal of shipboard-generated (MARPOL V) wastes. Pp. 915-920 in Proceedings of the Second International Conference on Marine Debris, 2-7 April, 1989, Honolulu, Hawaii (Vol. II), R.S. Shomura and M.L. Godfrey, eds. NOAA-TM-NMFS-SWFSC-154. Available from the Marine Entanglement Research Program of the National Marine Fisheries Service (National Oceanic and Atmospheric Administration), Seattle, Wash. December. Coe, J. 1992. Presentation by James Coe, National Marine Fisheries Service, to the Committee on Shipborne Wastes of the National Research Council, at the Governor Calvert House of the Historic Inns of Maryland, Annapolis, Md., May 7-8, 1992. Council of State Governments. 1992. Model Guidelines for State Medical Waste Management. Lexington, Ky.: Center for Environment of the Council of State Governments.

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