SUPPORTING
STATEMENT
SURVEY
QUESTIONNAIRE
TO
DETERMINE
THE
EFFECTIVENESS,
COSTS,
AND
IMPACTS
OF
SEWAGE
AND
GRAYWATER
TREATMENT
DEVICES
FOR
LARGE
CRUISE
SHIPS
OPERATING
IN
ALASKA
U.
S.
ENVIRONMENTAL
PROTECTION
AGENCY
November
2004
i
TABLE
OF
CONTENTS
Page
PART
A
OF
THE
SUPPORTING
STATEMENT
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1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
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1
2(
a)
Need/
Authority
for
the
Collection
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1
2(
b)
Practical
Utility/
Users
of
The
Data
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2
(
i)
General
Use
of
the
Data
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2
(
ii)
Detailed
Technical
Analyses
Supported
by
Parts
A
and
B
of
the
Survey
Data
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4
(
iii)
Detailed
Economical
Analyses
Supported
by
Part
C
of
the
Survey
Data
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3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
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9
3(
a)
Non­
Duplication
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9
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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9
3(
c)
Consultations
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10
3(
d)
Effects
of
Less
Frequent
Collection
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11
3(
e)
General
Guidelines
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11
3(
f)
Confidentiality
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11
3(
g)
Sensitive
Questions
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4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
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11
4(
a)
Respondent
NAICS
Codes
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11
4(
b)
Information
Requested
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12
(
i)
Data
Items,
Including
Record
Keeping
Requirements
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12
(
ii)
Respondent
Activities
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27
5.
THE
INFORMATION
COLLECTED
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AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
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5(
a)
Agency
Activities
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28
5(
b)
Collection
Methodology
and
Management
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29
5(
c)
Small
Entity
Flexibility
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30
5(
d)
Collection
Schedule
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30
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
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30
6(
a)
Estimating
Respondent
Burden
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30
6(
b)
Estimating
Respondent
Costs
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32
(
i)
Estimating
Labor
Costs
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32
TABLE
OF
CONTENTS
(
Continued)

Page
ii
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
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(
iii)
Capital/
Start­
up
Operating
and
Maintenance
Costs
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(
iv)
Annualizing
Capital
Costs
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34
6(
c)
Estimating
Agency
Burden
and
Costs
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34
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
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36
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
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36
6(
f)
Reasons
for
Change
in
Burden
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36
6(
g)
Burden
Statement
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36
Appendix
A
SUMMARY
OF
COMMENTS
ON
THE
PUBLIC
NOTICE
FOR
THE
PROPOSED
INFORMATION
COLLECTION
FOR
LARGE
CRUISE
SHIPS
IN
ALASKA
AND
EPA'S
RESPONSE
Appendix
B
SUMMARY
OF
COMMENTS
RECEIVED
IN
CONSULTATIONS
ON
THE
DRAFT
SURVEY
FOR
LARGE
CRUISE
SHIPS
IN
ALASKA
AND
EPA'S
RESPONSE
iii
LIST
OF
TABLES
Page
6­
1
Estimated
Respondent
Burden
to
Complete
the
Survey
(
Hours)
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31
6­
2
Estimated
Respondent
Costs
to
Complete
the
Survey
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33
6­
3
Estimated
Agency
Burden
and
Labor
Cost
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35
6­
4
Estimated
Agency
Total
Cost
(
Labor
and
O&
M)
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35
1
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
SURVEY
QUESTIONNAIRE
TO
DETERMINE
THE
EFFECTIVENESS,
COSTS,
AND
IMPACTS
OF
SEWAGE
AND
GRAYWATER
TREATMENT
DEVICES
FOR
LARGE
CRUISE
SHIPS
OPERATING
IN
ALASKA
1(
b)
Short
Characterization/
Abstract
This
Information
Collection
Request
(
ICR)
package
requests
the
Office
of
Management
and
Budget
(
OMB)
to
review
and
approve
the
U.
S.
Environmental
Protection
Agency's
(
EPA),
Office
of
Water
Survey
Questionnaire
to
Determine
the
Effectiveness,
Costs,
and
Impacts
of
Sewage
and
Graywater
Treatment
Devices
for
Large
Cruise
Ships
Operating
in
Alaska
(
hereafter
referred
to
as
the
Cruise
Ship
Survey).
The
survey
information
would
be
collected
from
operators
of
cruise
lines
and
individual
cruise
vessels
authorized
to
carry
for
hire
500
or
more
passengers
that
operate
in
the
waters
of
the
Alexander
Archipelago
or
the
navigable
waters
of
the
United
States
within
the
State
of
Alaska
or
within
the
Kachemak
Bay
National
Estuarine
Research
Reserve
(
hereafter
referred
to
as
waters
in
and
near
Alaska).
EPA
would
use
the
results
of
the
survey
to
support
the
development
of
discharge
limitations
for
treated
sewage
(
human
body
waste
and
the
wastes
from
toilets
and
other
receptacles
intended
to
receive
or
retain
human
body
waste)
and
graywater
(
galley,
dishwasher,
bath,
and
laundry
waste
water)
from
cruise
vessels
operating
in
water
in
and
near
Alaska
under
the
authority
of
33
U.
S.
C.
section
1901
Note.

The
information
to
be
collected
by
the
survey
includes:
general
information
about
the
cruise
line
and
each
of
the
large
cruise
vessels
operating
in
waters
in
and
near
Alaska
(
e.
g.,
size,
capacity,
ports
of
call);
description
of
sources
of
graywater
and
sewage;
ship­
board
plumbing
systems;
data
describing
the
effectiveness
of
sewage
and
graywater
treatment
systems
operating
on
these
vessels
at
removing
pollutants
of
concern;
costs
of
these
systems;
pollution
prevention
programs
and
management
practices;
information
pertaining
to
environmental
assessment;
and
financial
information
and
data
necessary
for
economic
impact
analysis.

EPA
would
distribute
the
survey
to
12
cruise
lines
operators
responsible
for
the
30
large
cruise
vessels
operating
in
waters
in
and
near
Alaska
in
2004.
EPA
estimates
the
total
respondent
burden
and
costs
associated
with
this
ICR
are
1,270
hours
at
$
50,091.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
On
December
12,
2000,
Congress
passed
HR
4577
(
P.
L.
106­
554),
"
Department
of
Labor,
Health
and
Human
Services,
and
Education,
and
Related
Agencies
Appropriations
Act."
This
act
included
a
section
entitled
"
Title
XIV:
Certain
Alaskan
Cruise
Ship
Operations"
(
33
U.
S.
C.
section
1901
Note).
Title
XIV
set
requirements
for
the
discharge
of
sewage
and
2
graywater
from
cruise
ships
authorized
to
carry
for
hire
500
or
more
passengers
while
operating
in
waters
in
and
near
Alaska.
Title
XIV(
section
1407)
also
stated:

"
Pursuant
to
this
title
and
the
authority
of
the
Federal
Water
Pollution
Control
Act,
as
amended,
the
Administrator
[
of
the
EPA]
may
promulgate
effluent
standards
for
treated
sewage
and
graywater
from
cruise
vessels
operating
in
the
waters
of
the
Alexander
Archipelago
or
the
navigable
waters
of
the
United
States
within
the
State
of
Alaska
or
within
the
Kachemak
Bay
National
Estuarine
Research
Reserve.
Regulations
implementing
such
standards
shall
take
into
account
the
best
available
scientific
information
on
the
environmental
effects
of
the
regulated
discharges
and
the
availability
of
new
technologies
for
wastewater
treatment."

EPA's
Office
of
Water
has
begun
an
effort
to
determine
whether
to
develop
regulations
(
and,
in
doing
so,
to
determine
what
the
regulations
should
include)
for
the
appropriate
control
of
the
discharge
of
sewage
and
graywater
from
cruise
ships
covered
by
Title
XIV.
Title
XIV
(
section
1413)
provides
that
the
authority
of
sections
308(
a)
and
308(
b)
of
the
Clean
Water
Act
regarding
records,
reports,
and
inspections,
shall
be
available
to
carry
out
the
provisions
of
the
Act.

2(
b)
Practical
Utility/
Users
of
The
Data
(
i)
General
Use
of
the
Data
The
purpose
of
this
effort
is
to
determine
the
effectiveness,
costs,
and
impacts
of
sewage
and
graywater
treatment
devices
for
large
cruise
ships
operating
in
Alaska.

EPA
would
use
the
technical
data
collected
in
Parts
A
and
B
of
the
Cruise
Ship
survey
to
determine
rates
of
wastewater
generation,
and
wastewater
management,
treatment,
and
disposal
practices.
EPA
would
also
use
these
technical
data
together
with
the
cost
of
treatment
and
control
technologies
collected
in
Part
B
and
financial
data
collected
in
Part
C
of
the
survey
to
assess
economic
impacts
and
benefits
associated
with
any
new
discharge
standards
considered
by
EPA.

The
sections
in
the
Cruise
Ship
survey
are
designed
to
collect
the
following
information:


Wastewater
Sources.
EPA
would
use
this
information
to
develop
an
industry
profile
of
wastewater
generation
and
collection
which
would
contribute
to
developing
and
evaluating
possible
regulatory
and
underlying
technology
options
and
compliance
cost
estimates.


Wastewater
Treatment
System
Design
and
Operating
Parameters.
EPA
would
use
this
information
to
develop
technology
options
and
compliance
cost
estimates.


Wastewater
Generation,
Collection,
and
Treatment
Costs.
EPA
would
use
this
information
to
develop
and
validate
compliance
cost
estimates
for
underlying
technology
options.
3

Wastewater
Characterization.
The
wastewater
characterization
data
would
be
used
to
determine
current
wastewater
discharge
characteristics
for
each
cruise
vessel,
evaluate
wastewater
treatment
performance,
and
estimate
pollutant
discharge
loadings.


Pollution
Prevention
Practices.
EPA
would
use
this
information
to
identify
specific
practices
that
may
become
part
of
the
regulatory
technology
options.


Employment
Data.
EPA
would
use
the
information
in
concert
with
other
data
in
analyzing
economic
impacts
of
regulatory
options
on
employment,
communities,
and
local
economies.


Financial
Information,
Including
Income
Statements
for
Each
Cruise
Vessel,
Cruise
Line
Owner,
and
Parent
Company.
These
data
would
permit
EPA
to
calculate
a
baseline
for
an
economic
impact
analysis.
Using
this
industry
baseline,
EPA
would
assess
potential
changes
in
economic
and
financial
conditions
in
the
market
due
to
compliance
costs.

EPA
would
use
all
of
these
data
to
develop
these
discharge
limitations
in
accordance
with
the
statutory
standards.
Specifically,
the
technical
information
collected
in
Parts
A
and
B
of
the
survey
would
allow
EPA
to:


Properly
characterize,
classify,
and
if
necessary
subcategorize
the
cruise
vessels
by
pollutants,
generated
wastewater
characteristics,
wastewater
destination,
or
a
combination
of
these
or
other
factors
yet
to
be
determined;


Identify
best
management
practices
and
pollution
prevention
and
source
reduction
activities
to
decrease
pollutant
levels
before
entering
the
treatment
system;


Identify
best
available
technologies
which
are
based
on
factors
such
as
treatment
technology
efficiency
and
total
cost
to
the
industry;


Identify
cruise
vessels
with
the
most
effective
wastewater
treatment
technologies;


Determine
the
most
effective
wastewater
treatment
technologies
for
the
treatment
of
sewage
and
graywater;
and

Determine
the
cruise
vessel
treatment
system
modifications
and
associated
costs
necessary
for
individual
vessels
to
comply
with
regulatory
options
including
underlying
technology
options
and
associated
discharge
limitations.

EPA
plans
to
collect
financial
and
economic
information
in
Part
C
of
the
survey
from
cruise
lines
to
estimate
the
impact
of
costs
of
compliance
on:


The
cost
and
quantity
of
cruise
line
services;
4

The
financial
condition
of
the
cruise
line;


The
impacts
on
prices
of
additional
wastewater
treatment
controls;


The
likelihood
of
removal
of
the
cruise
vessel
from
service
in
waters
in
and
near
Alaska
and
estimates
of
associated
loss
of
employment
due
to
increased
costs
of
providing
improved
wastewater
treatment
for
effluent
from
the
vessels;
and

The
potential
change
in
regional
and/
or
local
economies
due
to
removal
of
cruise
vessels
from
service
in
waters
in
and
near
Alaska.

(
ii)
Detailed
Technical
Analyses
Supported
by
Parts
A
and
B
of
the
Survey
Data
To
develop
discharge
limitations,
EPA
would
collect
and
analyze
information
pertaining
to
wastewater
characteristics
(
e.
g.,
pollutants
discharged,
wastewater
flows),
wastewater
treatment
technologies
(
e.
g.,
pollution
prevention
techniques,
end­
of­
pipe
treatment
systems),
and
the
economic
impacts
of
these
treatment
technologies.
Specifically,
to
develop
discharge
limitations
for
the
cruise
ship
industry,
EPA
would
use
responses
to
the
Survey
Questionnaire
to
Determine
the
Effectiveness,
Costs,
and
Impacts
of
Sewage
and
Graywater
Treatment
Devices
for
Large
Cruise
Ships
Operating
in
Alaska
to
assist
in
characterizing
the
pollution
discharged
from
cruise
ships
and
to
develop
regulatory
options
to
control
these
pollutant
discharges.

The
Agency
would
use
the
data
collected
to
assist
in
establishing
current
baseline
estimates
of
industry­
wide
pollutant
concentrations,
pollutant
loadings,
and
wastewater
generation
volumes
per
passenger/
crew
capacity,
in
order
to
estimate
the
engineering
costs
of
compliance
and
analyze
the
economic
impacts
and
environmental
benefits
associated
with
each
regulatory
option.
EPA
would
select
appropriate
regulatory
options
for
the
cruise
ship
industry
based
on
the
results
of
these
analyses.

EPA
engineers,
economists,
statisticians,
and
contractors
would
perform
detailed
analyses
of
the
data
collected
through
Parts
A
and
B
of
the
survey.
The
technical
data
would
include
basic
ship
information,
wastewater
generation
information,
detailed
water
use
data,
wastewater
characterization
summaries,
detailed
wastewater
treatment
system
data,
pollution
prevention
data,
and
costing
information.
Specific
analyses
using
the
technical
data
are
described
below.

(
a)
Subcategorization
In
developing
the
discharge
limitations,
EPA
would
consider
whether
it
is
appropriate
to
subcategorize
or
segment
the
industry
based
upon
such
factors
as
ship
size
and
age;
passenger
capacity;
water
use
practices;
wastewater
characteristics;
types
of
services
performed;
and
nonwater
quality
or
secondary
impacts.
These
factors
can
result
in
distinct
effluent
characteristics
and
would
provide
a
means
to
take
into
account
technology
achievability
and
economic
impacts
unique
to
specific
segments
of
the
industry
(
e.
g.,
older
cruise
vessels).
EPA
may
subcategorize
the
industry
based
upon
size,
age,
or
a
combination
of
these
factors,
if
necessary
and
appropriate.
Once
these
subcategories
are
established,
technically
feasible
control
options
are
developed
for
each
subcategory.
5
To
perform
the
subcategorization,
EPA
would
group
the
cruise
industry
into
separate
classes
of
similar
characteristics.
EPA
would
use
the
survey
data,
EPA
ship
visits,
and
sampling
data
to
evaluate
and
consider
each
of
the
factors
listed
above
as
they
affect
the
cruise
ship
industry.

(
b)
Wastewater
Characterization
and
Evaluation
EPA
would
use
data
collected
through
the
survey
to
analyze
cruise
ship
industry
wastewater
generation,
pollution
prevention
practices,
and
wastewater
treatment
systems.
Specifically,
EPA
would
analyze
each
wastewater
source,
including
water
use,
factors
affecting
wastewater
generation,
and
wastewater
discharge
rates;
pollution
prevention
techniques
associated
with
each
wastewater
source;
and
the
characteristics
of
wastewater
generated
from
each
source.
EPA
would
also
analyze
industry­
wide
pollution
prevention
practices
and
wastewater
treatment
systems
to
determine
the
wastewaters
that
are
being
treated,
the
treatment
technologies
that
are
applicable
to
those
wastewaters,
the
effectiveness
of
these
systems,
and
the
final
discharge
characteristics
from
cruise
ships.

Wastewater
characterization
is
used
to
determine
the
sources
of
the
wastewater
and
the
pollutants
and
pollutant
concentrations
that
are
present
in
the
wastewater.
This
information
is
ultimately
used
to
compare
the
performance
of
the
different
control
technologies
and
to
develop
a
list
of
pollutants
that
are
commonly
found
in
the
wastewater.
Wastewater
characterization
includes
the
following:


Determining
the
water
use,
wastewater
sources,
and
wastewater
generation
practices
associated
with
the
cruise
ship
industry;


Identifying
pollutants
of
concern
(
POCs);
and

Characterizing
untreated
wastewater
data
for
the
POCs.

(
c)
Technical
Feasibility
Analysis
EPA
must
select
technically
feasible
control
technologies
for
each
industry
subcategory
developed.
The
feasibility
assessment
of
these
control
technologies
would
be
based
upon
the
effectiveness
of
the
control
technologies
at
reducing
specific
pollutants
in
the
effluent
and
the
demonstration
and
availability
of
the
treatment
technologies
in
the
industry.

(
d)
Pollutant
Loadings
and
Removals
Pollutant
loadings
and
removals
are
calculated
to
evaluate
the
effectiveness
of
the
control
technologies,
to
estimate
benefits
gained
from
removing
pollutants
discharged
from
cruise
ships,
to
estimate
costs
to
achieve
such
reductions,
and
to
evaluate
the
cost­
effectiveness
of
the
regulatory
options
in
reducing
the
pollutant
loadings.
Calculating
pollutant
loadings
and
removals
includes
the
following:
6

Calculating
the
baseline
loadings
in
2004
(
i.
e.,
the
pollutant
loadings
being
discharged
prior
to
the
rulemaking);


Calculating
the
treated
loadings
(
i.
e.,
the
estimated
pollutant
loadings
after
implementation
of
the
promulgated
rule);
and

Calculating
the
pollutant
removals
(
i.
e.,
the
difference
between
the
baseline
loadings
and
the
treated
loadings).

(
e)
Assessment
of
Technology
Costs
EPA
staff
and
contractors
would
estimate
the
vessel­
specific
costs
of
various
control
technologies
being
considered
for
the
basis
of
the
discharge
limitations.
The
costs
of
the
control
technologies
would
include
the
following
items:
treatment
component
costs;
capital
costs
for
the
engineering
design,
equipment,
installation,
and
utility
connections;
annual
operating
and
maintenance
costs
for
the
equipment
and
equipment
operators;
capital
amortization,
and
compliance
monitoring.

EPA
would
use
data
collected
through
the
survey
to
estimate
the
direct
costs
of
the
wastewater
treatment
and
control
technologies
and
pollution
prevention/
management
practices
selected
as
the
technology
basis
options
for
cruise
ship
discharge
limitations.
These
data
include
wastewater
flow
rates,
wastewater
source
data,
data
related
to
treatment
technologies
already
in
place,
and
pollutant
concentrations.

EPA
would
estimate
the
incremental
investment
costs
and
incremental
operating
and
maintenance
costs
for
the
cruise
ship
industry
to
comply
with
the
technology
options
considered.
These
compliance
costs
would
be
used
to
determine
the
potential
economic
impacts
on
the
industry.
In
addition,
these
compliance
costs
would
be
weighed
against
the
effluent
reduction
benefits
resulting
from
each
technology
option.
In
order
to
estimate
ship­
level
compliance
costs,
EPA
would
need
to
consider
the
effluent
from
the
treatment
system
and
the
control
technology
for
each
cruise
ship.
This
information
would
be
used
to
determine
whether
cruise
ships
need
to
improve
their
control
technology
(
e.
g.,
by
installing
new
wastewater
treatment
units
or
entire
treatment
systems),
or
modify
their
operating
practices
to
achieve
the
discharge
limitations
for
a
particular
technology
option.

(
f)
Calculation
of
Discharge
Limitations
EPA
would
determine
discharge
limitations
for
each
alternative
technology
option
and
industry
subcategory.
These
limitations
would
be
based
upon
a
detailed
statistical
analysis
of
treated
effluent
data
from
those
cruise
vessels
with
well­
operated
treatment
systems,
using
the
recommended
control
technologies.
For
example,
EPA
may
develop
discharge
limitations
for
maximum
daily
and
average
monthly
discharge
levels.
The
data
from
the
survey
would
enable
EPA
to
identify
these
cruise
vessels
for
future
evaluation
of
their
treatment
systems.

Discharge
limitations
are
calculated
to
be
used
as
limitations
on
the
amount
of
certain
pollutants
that
are
discharged.
Calculating
discharge
limitations
may
include
calculating
long­
7
term
averages,
variability
factors,
and
limitations.
In
order
to
perform
these
calculations,
the
following
steps
are
taken:


Collecting
effluent
data;


Selecting
data
for
the
model
pollutant
control
technologies;
and

Calculating
the
limitations.

(
g)
Environmental
Assessment
and
Economic
Benefits
Analysis
EPA
would
perform
an
environmental
assessment
to
identify
potentially
affected
environmental
resources
and
assess
environmental
impacts
associated
with
cruise
ship
discharges
of
graywater
and
sewage.
To
the
extent
possible,
the
assessment
would
also
evaluate
similar
discharges
from
other
vessels
and
land­
based
services
to
Alaskan
waters.
To
perform
the
environmental
assessment,
EPA
would
use
the
pollutant
concentrations
discharged
by
the
cruise
vessels
and
the
location
of
the
discharges
to
assess
potential
impacts.

EPA
would
evaluate
potential
benefits
associated
with
reductions
in
discharges
of
sewage
and
graywater
from
cruise
vessels.
If
possible,
EPA
would
evaluate
effects
to:


Commercial
fishing;


Recreational
fishing;


Subsistence
fishing
and
hunting;


Human
health;


Tourism;
and

Non­
use
values.

(
h)
Development
of
Regulatory
Options
and
Selection
of
Final
Option
After
all
subcategories
are
identified,
technology
options
are
assessed,
discharge
limitations
are
calculated,
and
economic
analyses
are
performed,
EPA
would
develop
regulatory
options
for
consideration
by
EPA
senior
management.
Each
option
contains
detailed
information
on
the
technology
basis
for
the
option
and
associated
discharge
limitations,
amounts
of
pollutants
removed,
potential
costs
to
the
industry,
economic
impacts
of
these
costs
on
businesses
(
e.
g.,
if
cruise
lines
may
be
forced
to
remove
a
cruise
vessel
from
service
in
waters
in
and
near
Alaska
because
of
regulatory
costs),
cost­
effectiveness,
and
non­
water
quality
environmental
impacts.
Based
upon
all
of
these
analyses,
EPA
selects
the
most
appropriate
regulatory
option
for
each
subcategory
of
the
cruise
ship
industry.

(
iii)
Detailed
Economical
Analyses
Supported
by
Part
C
of
the
Survey
Data
EPA
economists
and
contractors
would
perform
detailed
analyses
of
the
data
collected
through
Part
C
of
the
Alaskan
Cruise
Ship
Survey.
The
economic
data
would
include
corporate
structure,
discount
rate,
North
American
Industrial
Classification
System
(
NAICS)
code,
income
statement
information
such
as
revenues,
costs,
interest,
depreciation,
taxes,
and
net
income,
balance
sheet
information
such
as
current
and
noncurrent
assets,
and
employment.
These
data
are
collected
for
two
levels
in
the
corporate
hierarchy
 
the
vessel
and
the
company
that
operates
the
8
vessel.
A
limited
set
of
data
is
requested
for
the
third
level
in
the
corporate
hierarchy
 
the
corporate
parent.
Specific
analyses
using
the
economic
data
are
described
below.
Employment
and
revenue
data
are
collected
at
the
company
and
corporate
parent
levels
in
order
to
identify
small
businesses
according
to
Small
Business
Administration
size
standards.

(
a)
Estimation
of
Impacts
on
Vessels
One
element
of
the
economic
analysis
would
be
a
determination
of
the
proposed
regulation's
impacts
on
individual
vessels.
The
analysis
would
combine
vessel­
specific
costs
of
compliance
with
vessel
financial
data
for
all
affected
vessels
in
the
industry.
The
results
would
be
used
to
estimate
the
total
costs
and
impacts
of
the
proposed
regulation.

A
goal
of
the
analysis
would
be
to
identify
vessels
that
might
become
unprofitable
due
to
pollution
control
requirements.
A
standard
financial
decision
model
would
predict
unprofitability
if
the
net
present
value
of
future
income
(
net
income
or
cash
flow)
from
continued
operations
is
positive
prior
to
the
incurrence
of
additional
pollution
control
costs
and
negative
after
the
incurrence
of
such
costs.
The
forecasted
income
for
the
enterprise
is
a
major
determinant
of
the
net
present
value
of
continued
operations.
The
income
projections
are
calculated
using
the
information
collected
in
the
survey,
including
the
tax
status
of
the
company
that
owns
the
vessel.

A
cruise
line
company
that
estimates
that
the
cost
of
upgrading
a
vessel
would
severely
reduce
its
profitability
has
the
option
to
transfer
that
vessel
to
another
venue
(
e.
g.,
the
Caribbean).
EPA
requests
the
costs
and
revenues
associated
with
Alaska
operations
to
better
understand
the
contribution
of
these
operations
to
the
overall
financial
health
of
the
vessel.
To
provide
an
upper
bound
analysis
of
impacts,
EPA
would
calculate
direct
losses
in
revenue
and
employment
from
the
profitability
analysis
results
and
survey
responses.
EPA
would
also
perform
sensitivity
analyses
to
estimate
the
percentage
of
costs
that
the
market
would
allow
to
pass
through
to
the
consumer
and
the
associated
effect
on
vessel
profitability.

(
b)
Estimation
of
Impacts
on
Companies
The
costs
for
all
cruise
ships
operating
in
waters
in
and
near
Alaska
that
are
owned
by
a
given
company
would
be
estimated
and
aggregated.
The
combined
cost
to
the
company
would
be
analyzed
in
the
context
of
the
company's
financial
status
to
evaluate
the
overall
impact.
The
company­
level
impact
analysis
allows
EPA
to
assess
the
effect
of
a
regulation
at
a
different
level
of
business
organization.
Where
possible,
the
analysis
would
be
performed
with
information
for
the
business
entity
because
financing
decisions
are
commonly
made
at
this
level.
In
addition,
the
economic
impacts
of
increased
pollution
control
costs
are
more
visible
at
this
level
because
of
the
smaller
asset
and
revenue
base
for
financial
ratio
analysis
compared
to
the
parent
company
level.
If
the
analysis
is
to
be
done
at
the
corporate
parent
level,
the
information
would
be
derived
from
the
financial
statements
requested
in
the
survey.
In
the
case
of
single­
vessel
firms,
this
component
of
the
analysis
is
unnecessary
because
vessel­
level
and
company­
level
impacts
would
coincide.

Whenever
possible,
EPA
would
collect
data
needed
to
assess
company­
level
impacts
from
secondary
sources.
This
reduces
the
burden
on
survey
recipients.
Secondary
sources
provide
9
data
for
publicly
reporting
companies
but
are
generally
inadequate
for
non­
publicly
reporting
companies.

(
c)
Estimation
of
Secondary
Impacts
EPA
would
assess
impacts
on
other
segments
of
the
economy.
EPA
has
included
specific
questions
concerning
(
1)
the
number
of
employees
for
whom
Alaska
is
home,
(
2)
revenues
from
onshore
recreational
activities
organized
by
the
voyage,
and
(
3)
supplies
purchased
while
in
port.

EPA
would
estimate
national
losses
in
output
and
employment
from
direct
impacts
based
on
macroeconomic
multipliers,
general
economic
data,
and
economic
data
from
secondary
sources.
EPA
also
plans
to
consider
the
secondary
impacts
felt
by
small
businesses
and
foreign
trade.
Data
from
secondary
sources
would
include
detailed
industry
trade
statistics,
labor
cost
and
commodity
price
indices,
regional
(
if
identified)
and
national
income
multipliers,
small
business
statistics,
and
other
relevant
secondary
source
information.

(
d)
Regulatory
Flexibility
Analysis
EPA
requested
NAICS
code,
employment,
and
revenue
data
at
the
company
and
corporate
parent
levels
in
order
to
identify
vessels
belonging
to
companies
that
meet
the
Small
Business
Administration's
size
standards.
EPA
would
categorize
its
economic
impact
findings
for
this
subset
of
the
regulated
population.

3.
NON­
DUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Non­
Duplication
This
information
collection
would
target
large
cruise
vessels
authorized
to
carry
500
or
more
passengers
operating
in
the
waters
in
and
near
Alaska.
Because
there
is
no
database
or
a
set
of
databases
that
contains
either
most
or
all
of
the
information
requested
in
the
survey,
there
is
a
definite
need
for
this
data
collection
effort.
Some
information
on
cruise
vessels
available
from
existing
sources
would
be
pre­
populated
into
the
vessel­
specific
surveys
for
verification
by
the
cruise
line.
Available
information
may
include
general
Alaska
itinerary;
vessel
description;
discharge
status;
corporate
level
generic
pollution
prevention
and
best
management
practices;
overviews
of
wastewater
collection,
holding
and
transfer
systems;
and
wastewater
treatment
system
and
performance
and
limited
wastewater
characterization
data.
Much
of
this
information
has
been
gathered
by
the
Alaska
Department
of
Environmental
Conservation
(
ADEC)
or
the
U.
S.
Coast
Guard
(
USCG)
from
the
cruise
lines
for
vessels
operating
in
waters
in
and
near
Alaska,
and
would
be
updated
and
used
by
EPA.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
a
public
comment
period
for
this
ICR
was
made
in
the
Federal
Register
on
February
3,
2004
(
69
FR
5145).
EPA
received
five
comments
on
this
FRN
from
the
following
entities:
private
individuals,
Oceana,
Inc.,
Blue
Water
Network,
and
the
U.
S.
10
Department
of
the
Navy.
In
addition
to
publishing
the
Federal
Register
Notice,
EPA
e­
mailed
the
notice
to
the
cruise
industry,
environmental
interest
groups,
and
other
stakeholders
that
asked
to
be
included
on
EPA's
cruise
ship
mailing
list
(
approximately
335
e­
mail
addresses).

In
summary,
the
comments
received
generally
requested
that
detailed
inquiries
be
included
in
a
number
of
areas
in
the
survey
questionnaire,
covering
general,
technical,
and
financial
topics.
For
example,
commenters
requested
specific
information
regarding:
sources
of
graywater
and
blackwater;
treatment
system
operation
and
maintenance
practices;
wastewater
discharge
practices
and
locations;
and
sludge
disposal
practices.
Upon
review,
EPA
determined
that
most
of
the
requests
for
specific
inquiries
are
included
in
the
survey
questionnaire.
In
most
cases
where
specific
or
directly
related
inquiries
were
not
already
included,
questions
and/
or
data
requests
were
added
to
the
survey
questionnaire.
A
summary
of
comments
received
on
the
public
notice
and
EPA's
response
is
presented
in
Appendix
A.

3(
c)
Consultations
EPA's
Workgroup
for
the
regulation
of
Sewage
and
Graywater
from
Cruise
Ships
Operating
in
Alaska
assisted
in
the
design
of
the
survey.
In
addition,
EPA
submitted
the
draft
survey
for
review
and
comment
to
the
International
Council
of
Cruise
Lines
(
ICCL)
and
the
North
West
Cruiseship
Association
(
NWCA),
individual
cruise
lines,
the
Alaska
Department
of
Environmental
Conservation
(
ADEC),
the
U.
S.
Coast
Guard,
interested
environmental
interest
groups,
Alaska
Native
Tribes
and
Tribal
organizations,
and
other
stakeholders.
EPA
offered
to
meet
and
discuss
the
survey
with
these
stakeholders;
EPA
participated
in
a
meeting
with
ICCL
and
has
also
discussed
the
survey
with
tribal
representatives
and
ADEC.

EPA
received
survey
review
comments
from
ADEC,
the
U.
S.
Coast
Guard,
ICCL,
Royal
Carribean
Cruise
Lines,
the
Central
Council
Tlingit
Haida
Indian
Tribes
of
Alaska,
and
Oceana,
Inc.
In
summary,
the
survey
review
comments
generally
requested
that
more
detailed
inquiries
be
added
in
a
number
of
areas
in
the
survey
questionnaire,
covering
general,
technical,
and
financial
topics.
For
example,
commenters
requested
more
specific
information
regarding:
sources
of
graywater
and
blackwater
and
ship
piping
diagrams;
treatment
system
operation
and
maintenance
practices;
more
extensive
wastewater
sampling
and
analytical
data;
wastewater
discharge
practices
and
locations
(
e.
g.,
ship
speed
and
location);
sludge
disposal
practices;
and
information
on
the
net
revenue
from
local
supporting
vendors
(
e.
g.,
shore­
based).
Upon
review,
EPA
determined
that
many
of
the
requests
for
more
specific
inquiries
were
already
included
in
specific
or
related
questions
in
the
survey
questionnaire.
In
most
cases
where
specific
or
directly
related
inquiries
were
not
included,
questions
and/
or
data
requests
were
added
to
the
survey
questionnaire.

One
commenter
requested
that
the
option
for
making
claims
for
confidential
business
information
(
CBI)
not
be
provided.
EPA
has
had
in
place
for
many
years
regulations
governing
the
submittal
and
control
of
CBI.
These
regulations
are
found
at
40
CFR
part
2
and
will
continue
to
be
followed
for
this
industry.

A
comment
received
from
the
industry
asserted
that
much
of
the
financial
and
economic
data
were
aggregated
and
not
accounted
for
or
otherwise
available
for
each
of
the
company
and
11
subsidiary
company
ships
that
operate
only
in
Alaska.
EPA
worked
with
cruise
line
representatives
via
telephone
and
e­
mail
communications
to
resolve
these
issues.
Another
related
comment
from
the
industry
asserted
that
the
burden
and
time
for
responding
to
the
questionnaire
would
be
substantial
for
the
requested
financial
and
economic
data
where
they
are
not
readily
available.
EPA's
estimates
of
response
burden
have
been
adjusted
in
response
to
these
comments.
A
summary
of
comments
received
in
consultations
and
EPA's
response
is
presented
in
Appendix
B.

3(
d)
Effects
of
Less
Frequent
Collection
The
Survey
Questionnaire
to
Determine
the
Effectiveness,
Costs,
and
Impacts
of
Sewage
and
Graywater
Treatment
Devices
for
Large
Cruise
Ships
Operating
in
Alaska
is
a
one
time
only
data
collection
activity
for
the
respondents.

3(
e)
General
Guidelines
The
proposed
data
collection
activities
would
be
conducted
in
accordance
with
the
Paperwork
Reduction
Act
guidelines
in
5
CFR
1320.6
and
EPA's
Quality
Assurance
Guidance.
Information
to
be
disseminated
would
comply
with
EPA's
Information
Quality
Guidelines
which
were
developed
for
implementing
OMB's
Guidelines
for
Ensuring
and
Maximizing
the
Quality,
Objectivity,
Utility,
and
Integrity
of
the
Information
Disseminated
by
Federal
Agencies.

3(
f)
Confidentiality
The
survey
informs
respondents
of
their
right
to
claim
information
confidential
in
accordance
with
40
CFR
part
2,
subpart
B,
Section
2.203.
The
survey
provides
instructions
on
the
Confidential
Business
Information
(
CBI)
procedures
for
making
these
claims.

3(
g)
Sensitive
Questions
No
sensitive
questions
pertaining
to
private
or
personal
information,
such
as
sexual
behavior
or
religious
beliefs,
would
be
asked
in
the
survey.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondent
NAICS
Codes
The
respondents
affected
by
this
information
collection
request
are
12
cruise
lines
that
own
and
operate
the
30
large
cruise
vessels
authorized
to
carry
500
or
more
passengers
operating
in
waters
in
the
waters
of
the
Alexander
Archipelago
or
the
navigable
waters
of
the
United
States
within
the
State
of
Alaska
or
within
the
Kachemak
Bay
National
Estuarine
Research
Reserve
(
hereafter
referred
to
as
waters
in
and
near
Alaska).
The
North
American
Industry
Classification
System
identification
numbers
for
these
respondents
is:
483114:
Cruise
Lines:
Deep
Sea
Passenger
Transportation
To
and
From
Domestic
Ports.
12
4(
b)
Information
Requested
(
i)
Data
Items,
Including
Record
Keeping
Requirements
Data
Items
(
a)
General
Description
of
the
Survey
Cruise
line
owners
and
operators
would
be
requested
to
complete
one
survey
for
each
of
their
cruise
vessels
operating
in
2004
in
the
waters
in
and
near
Alaska.
The
cruise
ship
survey
consists
of
three
parts.
Part
A
requests
general
information
about
the
cruise
line.
Part
B
requests
technical
information
specific
to
each
cruise
vessel.
Financial
and
economic
information
for
both
the
cruise
line
and
cruise
vessel(
s)
are
requested
in
Part
C.
Each
of
these
three
is
divided
into
sections.
At
the
end
of
each
section,
there
is
a
question
that
provides
space
for
the
respondent
to
add
comments
that
explain
or
expand
responses
to
questions
within
that
section.
For
any
cruise
line
operating
more
than
one
vessel
in
and
near
the
waters
of
Alaska
in
2004,
EPA
would
provide
the
appropriate
number
of
copies
of
the
sections
asking
for
vessel­
specific
information.
EPA
would
pre­
populate
survey
responses
to
the
extent
possible
with
information
from
existing
sources.
A
detailed
description
of
the
survey
questions
follows.

(
b)
Part
A:
General
Cruise
Line
Information
Part
A
requests
information
about
the
cruise
line.
Questions
1
to
8
of
Part
A
collect
information
that
identifies
the
cruise
line
name
and
address,
the
primary
and
secondary
contacts
to
verify
or
clarify
the
technical
survey
information,
and
the
parent
company.
Most
of
the
information
in
Part
A
is
available
from
existing
sources
(
e.
g.,
cruise
line
websites,
ADEC
ship
registries),
and
this
information
would
be
pre­
populated.
This
information
would
be
used
to
identify
those
cruise
ships
and
the
parent
company
that
would
be
considered
in
the
economic
impact
analysis
to
determine
the
impact
to
each
company.
The
primary
and
secondary
contact
information
allows
EPA
to
contact
responsible
individuals
at
the
company
level
for
issues
related
to
this
rulemaking
effort.

Questions
9
and
10
request
the
year
the
cruise
line
first
began
operating
in
the
waters
in
and
near
Alaska
and
verifies
whether
cruise
line
vessels
operated
in
these
waters
in
calendar
year
2004.
The
months
cruise
vessels
operated
in
waters
in
and
near
Alaska
in
calendar
year
2004
are
requested
in
Question
11.
This
information
would
be
used
for
subcategorization
and
to
determine
the
universe
of
ships
that
cruised
to
Alaska
during
the
baseline
year
of
2004.

Question
12
requests
the
name,
passenger
and
crew
capacity,
and
country
of
registry
of
each
cruise
vessel
authorized
to
carry
500
or
more
passengers
and
operates
in
the
waters
in
and
near
Alaska.
Question
13
requests
the
same
information
for
cruise
vessels
the
cruise
line
plans
to
add
to
their
Alaska
operations
in
calendar
years
2005,
2006,
and
2007.
This
information
could
be
used
for
subcategorization
and
to
determine
which
vessels
would
be
covered
by
this
rulemaking.
In
addition,
the
passenger
and
crew
capacity
could
be
used
to
develop
"
passenger
normalized
flows"
that
could
be
used
in
making
data
comparisons
between
vessels
of
different
sizes.
13
The
responses
elicited
through
questions
in
this
part
are
very
important
to
verify
that
basic
information
used
throughout
subsequent
analyses
are
identified
correctly
and
used
appropriately.

Question
14
provides
an
opportunity
for
the
respondent
to
comment
on
survey
responses
in
this
section.

(
c)
Part
B:
Cruise
Vessel
Technical
Information
SECTION
1:
GENERAL
CRUISE
VESSEL
INFORMATION
Section
1
requests
general
information
about
the
cruise
vessel
pertinent
to
a
variety
of
engineering
analyses.
Some
information
requested
in
this
section,
such
as
age
or
size,
could
be
used
as
a
basis
for
developing
differing
control
and
treatment
options
and
associated
discharge
limitations.
Information
regarding
graywater
and
sewage
holding
capacity
would
characterize
current
vessel
capabilities.
The
operating
days
and
ports
of
call
would
be
necessary
to
characterize
cruise
vessel
operations
in
waters
in
and
near
Alaska.
EPA
would
also
use
general
vessel
information
in
updating
the
industry
profile,
estimating
costs
of
control
technology
options,
and
performing
the
environmental
assessment.

Question
15
requests
the
number
of
days
this
vessel
cruised
in
the
waters
in
and
near
Alaska.
Questions
16
and
17
request
the
Alaska
port
calls
and
the
sequential
order
of
the
port
calls.
Questions
18
and
19
ask
about
destinations
in
national
or
state
parks,
or
in
other
sensitive
areas.
These
questions
request
the
identity
of
these
destinations,
the
duration
of
the
visit,
and
the
number
of
times
visited
in
calendar
year
2004.
EPA
would
use
these
questions
to
assess
environmental
impacts.

Questions
20
and
21
request
the
date
of
construction
completion
and
the
date
the
vessel
began
service.
Question
22
requests
the
date
service
began
its
first
voyage
in
waters
in
and
near
Alaska.
Question
23
requests
vessel
dimensions;
maximum
speed;
weight;
holding
capacity
for
fresh
water,
sewage,
and
graywater;
the
ballast
tank
capacity;
depth
of
the
propellers
and
wastewater
discharge
port(
s);
diameter
of
the
propellers;
and
location
of
the
discharge
port(
s)
along
the
length
of
the
vessel.
Question
24
requests
the
number
of
passengers
for
each
Alaska
voyage
and
the
number
of
days
in
waters
in
and
near
Alaska.
Question
25
asks
if
the
number
of
passengers
is
typical,
higher,
or
lower
than
previous
years.
EPA
needs
this
information
in
order
to
consider
the
potential
impact
that
a
ship's
age
may
have
on
the
feasibility
of,
or
cost
associated
with,
each
candidate
control
technology.
EPA
would
use
the
information
from
questions
20
through
25
in
updating
the
industry
profile
in
considering
whether
it
is
either
necessary
or
appropriate
to
classify
cruise
vessels
for
possible
industry
subcategorization;
to
assist
in
estimating
costs
for
control
technology
options;
and
for
discharge
dilution
modeling.

Question
26
provides
an
opportunity
for
the
respondent
to
comment
on
survey
responses
in
this
section.
14
SECTION
2:
WASTEWATER
SOURCES
Section
2
is
designed
to
obtain
information
about
graywater
and
sewage
sources,
flows,
and
destinations.
It
also
requests
information
to
further
characterize
wastewater
generation
on
each
cruise
vessel,
including
information
on
types
and
volumes
of
graywater
sources
and
for
chemical
additions
for
cleaning,
maintenance,
and
odor
control.
Finally
this
section
requests
graywater
and
sewage
schematic
flow
diagrams
and
design
and
operating
information
for
untreated
wastewater
collection,
holding,
and
transfer
(
CHT)
tanks.
Generic
overview
information
on
CHT
tanks
is
available
from
existing
sources,
and
this
information
would
be
prepopulated
in
responses
to
applicable
questions
in
cruise
vessel­
specific
survey
questionnaires.
Responses
to
Section
2
would
provide
EPA
with
information
needed
to
develop
an
industry
profile
of
wastewater
generation
and
collection
and
to
develop
and
evaluate
possible
regulatory
technology
options
and
compliance
cost
estimates.

Question
27
requests
a
schematic
flow
diagram
for
the
untreated
sewage
and
graywater.
The
schematic
flow
diagram
is
required
to
illustrate
the
sources
and
distribution
of
untreated
wastewater
through
vessel
sewage
and
graywater
CHT
systems.
This
would
provide
a
clear
understanding
of
the
components
and
the
destination
of
the
untreated
sewage
and
graywater
wastewater
streams.
A
checklist
is
presented
following
question
instructions,
to
ensure
that
the
schematic
flow
diagram
is
complete
and
submitted
as
intended.
This
information
would
be
used
for
determining
wastewater
characteristics;
specifically,
it
would
be
used
for
determining
the
water
use,
wastewater
sources,
and
wastewater
generation
practices.

Question
28
requests
the
destination
of
graywater
and
sewage
sources.
Question
29
requests
nominal
flow
rate
data
for
sewage
and
graywater
sources
such
as
galley,
dishwasher,
bath,
laundry,
and
sewage.
Responses
to
Question
29
would
assist
in
the
determination
of
the
overall
graywater
and
sewage
hydraulic
and
pollutant
load
generation
rates
for
each
vessel,
and
to
identify
trends
among
ships
based
on
operations
and/
or
per
passenger
generation
rates.
These
questions
would
aid
in
developing
an
industry
profile
for
wastewater
generation
and
in
evaluating
differences
in
vessel
wastewater
generation
and
characteristics.
The
information
provided
in
responses
to
Questions
27
and
29
also
would
contribute
to
developing
compliance
cost
estimates.
In
addition,
this
information
could
be
used
for
industry
subcategorization.

Question
30
requests
a
list
of
any
sewage
or
graywater
streams
that
are
routed
to
destinations
other
than
graywater/
sewage
CHT
tanks.
Responses
to
this
question
would
also
provide
information
regarding
possible
ship
alterations
that
may
be
necessary
to
reroute
these
sewage
and
graywater
sources
to
the
collection
or
holding
tank.
Responses
to
this
question
would
be
used
to
determine
if
rerouting
of
waste
streams,
if
needed,
is
feasible
on
most
ships
as
a
means
for
renovating
current
wastewater
discharge/
treatment
practices.
This
information
also
would
contribute
to
developing
compliance
cost
estimates,
so
that
modifications
in
system
can
be
assessed.

Question
31
requests
information
regarding
the
use
of
vacuum
versus
gravity
or
sea
water
versus
fresh
water
in
sewage
and
graywater
systems.
Responses
to
this
question
would
identify
pollution
preventing
practices
used
to
reduce
freshwater
consumption
and
could
provide
a
contributing
basis
for
best
management
practices
(
BMPs).
In
addition,
it
could
be
used
for
15
calculating
compliance
cost
estimates,
if
modifications
are
needed
in
the
use
of
vacuum
or
sea
water
usage.

Questions
32
through
35
ask
for
an
estimate
of
the
number
of
meals
served
per
day,
the
amount
of
dishes
washed,
the
amount
of
laundry
washed,
and
the
water
usage
per
toilet
flush.
These
questions
would
provide
information
for
determining
potential
graywater
and
sewage
generation
rates
per
day
from
these
various
activities.
Responses
would
be
used
to
create
an
industry
profile
for
wastewater
generation
and
a
basis
for
comparison
between
vessels.
This
information
also
would
contribute
to
checking
and
validating
compliance
cost
estimates
and
calculating
pollutant
loadings
and
removals.

Questions
36
and
37
are
designed
to
provide
information
about
typical
BOD
5
and
COD
concentrations
in
the
untreated
sewage
and
graywater
streams.
Responses
to
these
questions
would
help
to
characterize
wastestream
strengths
and
to
estimate
raw
waste
pollutant
loads.
This
information
would
contribute
substantially
to
designing
technology
options
and
developing
compliance
cost
estimates.
In
addition,
it
would
be
used
to
identify
the
pollutants
of
concern
(
POCs)
and
characterizing
untreated
wastewater
data
for
the
POCs.

Question
38
asks
for
a
list
of
the
top
10
chemicals
by
volume
used
in
various
activities
such
as
cleaning,
maintenance,
odor
control,
calcification
prevention,
biocides,
and
chlorination
that
end
up
in
the
untreated
sewage
and/
or
graywater
drainage
and
CHT
systems.
This
question
is
intended
to
provide
information
on
chemical
components
and
concentrations
in
the
untreated
sewage
and/
or
graywater
drainage
and
collection
system,
to
characterize
the
wastewater
generated
onboard
cruise
vessels.
Responses
to
this
question
would
also
be
evaluated
to
identify
and
select
among
those
pollutants
which
may
be
of
concern,
and
to
identify
opportunities
for
pollution
prevention
through
chemical
substitution
and
best
management
practices.

Questions
39
and
40
ask
for
a
list
of
the
five
most
commonly
used
disinfectants
and
pesticides
by
volume.
The
question
also
requests
the
potential
for
each
of
these
chemicals
to
enter
the
graywater
or
sewage
systems.
This
information
would
provide
knowledge
of
the
chemicals
used
onboard
cruise
vessels
and
their
likelihood
to
receive
treatment
via
the
graywater
or
sewage
treatment
operations.
This
question
is
intended
to
provide
information
regarding
the
potential
chemical
pesticide
and
disinfectant
components
in
the
sewage
and
graywater
systems,
which
would
be
used
to
further
characterize
the
wastewater
generated
onboard
cruise
vessels.
Responses
to
this
question
would
also
be
evaluated
to
identify
and
select
among
those
pollutants
which
may
be
of
concern,
and
to
identify
opportunities
for
pollution
prevention
through
chemical
substitution
and
best
management
practices.

Question
41
requests
the
vessel's
total
untreated
sewage
and
graywater
CHT
capacities
in
hours
and
is
designed
to
provide
information
regarding
the
retention
capacity
for
untreated
waste.
Responses
to
this
question
would
contribute
to
developing
compliance
cost
estimates
for
control
technology
options,
and
also
would
serve
as
an
indicator
of
the
need
for
and
frequency
of
disposal
of
wastewaters
whether
via
treatment,
holding
for
onshore
disposal,
or
direct
discharge.
Specifically,
this
information
would
be
used
to
determine
if
additional
storage
capacity
is
needed
to
comply
with
the
regulation.
16
Question
42
has
multiple
parts
and
asks
for
key
information
regarding
the
sources
and
flow
rates
to
each
untreated
graywater
and/
or
sewage
CHT
tank.
This
data
is
vital
for
the
characterization
of
the
untreated
sewage
and
graywater
waste,
such
as
the
inflow
of
potential
hazardous
chemicals
that
are
contained
in
photo
lab
or
salon
wastewaters.
Other
subparts
to
this
question
include
information
regarding
the
capacity,
usage
time,
and
any
sludge
collection/
disposal
from
CHT
tanks.
Responses
to
this
question
are
intended
to
aid
in
creating
an
industry
profile
for
the
generation
and
collection
of
wastewater,
as
well
as
developing
and
evaluating
possible
control
technology
designs
and
regulatory
options
and
compliance
cost
estimates.

Questions
43
and
44
request
information
regarding
shore
side
disposal
of
untreated
sewage
or
graywater
including
the
volume
transferred
to
shore
side
facilities
in
Alaska
in
2004.
Questions
45
and
46
ask
for
information
regarding
discharge
of
untreated
wastewater
at
sea,
including
specific
volumes
and
location
of
disposal
(
in
port,
within
1nm
of
shore,
etc.).
It
is
important
to
track
the
amount
of
disposed
of
either
on
shore
or
at
sea,
in
order
to
formulate
an
industry
profile
for
disposal
methods
for
wastewater
as
well
as
developing
and
evaluating
possible
technology
and
regulatory
options
and
compliance
cost
estimates.

Question
47
provides
an
opportunity
for
the
respondent
to
comment
on
survey
responses
in
this
section.

SECTION
3:
WASTEWATER
TREATMENT
SYSTEM
DESIGN
AND
OPERATING
PARAMETERS
Section
3
requests
information
on
graywater
and
sewage
treatment
technologies
operated
onboard
each
cruise
vessel
in
2004.
This
section
applies
only
to
wastewater
treatment
systems
that
treat
graywater
and/
or
sewage.
The
information
in
this
section
includes
wastewater
treatment
diagrams;
design
and
operating
specifications;
sources
of
influent;
chemical
additions;
operating
and
maintenance
procedures;
and
discharge
practices.
Information
obtained
by
EPA
from
ADEC
and
USCG
identifies
wastewater
treatment
systems
used
on
vessels
operating
in
waters
in
and
near
Alaska.
EPA
would
pre­
populate
this
information
in
preliminary
responses
to
applicable
questions
in
the
vessel­
specific
survey
questionnaires,
requesting
any
necessary
changes
and
updates
to
make
them
correct
and
accurate.
EPA
would
need
responses
to
inquiries
in
this
section
as
critical
input
for
developing
control
technology
options,
regulatory
options
and
compliance
cost
estimates.
Information
gathered
from
these
questions,
coupled
with
analytical
data
requested
in
Section
5,
would
be
used
to
assess
operation,
maintenance,
control,
and
performance
of
treatment
technologies.
For
all
questions
in
this
section,
respondents
are
asked
to
fill
out
the
survey
for
each
individual
wastewater
treatment
system,
since
some
ships
have
more
than
one
wastewater
treatment
system,
and
not
all
systems
are
either
the
same
or
even
similar.

Question
48
requests
a
list
of
the
wastewater
treatment
unit
operations
used
to
treat
graywater
and/
or
sewage.
This
question
also
indicates
the
corresponding
table
to
be
completed
for
the
detailed
wastewater
treatment
operation
information
requested
in
Question
68
of
Section
3.

Question
49
requests
a
schematic/
diagram
for
each
wastewater
treatment
system
used
to
treat
graywater
and/
or
sewage.
These
diagrams
would
identify
all
sources
entering
the
treatment
17
system;
wastewater
destinations;
any
chemical
additions
and
recycle
streams;
the
locations
of
sludges,
oils,
and
wastes
leaving
the
system;
and
the
location
of
any
wastewater
sample
points.
In
addition,
the
diagram
being
requested
would
specify
flow
rates
for
all
streams.
This
information
would
be
necessary
to
understand
the
individual
sewage
and
graywater
treatment
processes
in
order
to
contribute
to
developing
technology
options
and
associated
designs,
regulatory
options,
and
compliance
cost
estimates.
A
checklist
is
provided
following
the
question
instructions
to
ensure
that
each
wastewater
treatment
system
schematic/
diagram
is
complete.

Questions
50
and
51
request
the
name
and
a
brief
description
of
each
wastewater
treatment
system.

Questions
52
through
54
request
information
regarding
each
treatment
system's
operation
as
a
batch
or
continuous
process.
If
the
system
is
batch,
questions
53
and
54
ask
for
the
number
of
batches
per
day
and
typical
volume
of
wastewater
that
is
treated
in
2004.
The
information
requested
here
would
be
necessary
to
contribute
to
developing
control
technology
options,
regulatory
options,
and
compliance
cost
estimates,
and
aid
in
understanding
the
individual
cruise
vessels
wastewater
treatment
processes.

Questions
55
through
59
request
information
regarding
the
vessel
location
and
frequency
of
operation
for
each
wastewater
treatment
system
in
2004.
Specifically,
Questions
55
and
56
ask
the
design
capacity
of
the
system
and
the
average
volume
treated
per
day.
Questions
57
and
58
ask
how
many
hours
per
day
and
days
per
year
was
the
wastewater
treatment
system
operated
in
2004,
respectively.
Question
59
asks
where
the
vessel
operates
the
wastewater
treatment
system,
(
i.
e.,
at
all
times,
only
in
waters
in
and
near
Alaska,
within
1
nautical
mile
(
nm),
etc.).
This
information
would
be
necessary
for
estimating
wastewater
treatment
system
operation
and
maintenance
costs.
The
responses
also
would
be
important
for
profiling
the
extent
of
wastewater
treatment
that
is
occurring
in
the
cruise
ship
industry,
where
the
treatment
occurs,
and
also
to
calculate
pollutant
loadings
and
conduct
the
environmental
assessment.

Question
60
requests
information
pertaining
to
incidences
of
partial
treatment,
where
not
all
of
the
treatment
units
were
employed
in
the
wastewater
treatment
process.
The
question
asks
when
and
why
this
would
occur
and
which
treatment
units
were
not
used.
This
question
would
provide
the
reasons
for
and
frequency
of
partial
wastewater
treatment,
and
thus
provide
part
of
the
basis
for
treatment
system
upgrades,
and
also
for
the
environmental
assessment.

Question
61
provides
a
short
list
of
treatment
system
operating
parameters
and
requests
the
respondent
to
state
whether
and
how
often
that
particular
parameter
was
measured
or
monitored
during
the
year
2004.
Operating
parameters
listed
include
equipment
checks,
influent
and
effluent
flow
rates,
sludge
return
levels,
and
chemical
levels.
This
question
also
gives
the
respondent
the
opportunity
to
write
in
any
additional
operating
parameters
that
were
measured
or
monitored
during
the
year.
This
list
of
operating
parameters
would
be
necessary
to
provide
information
regarding
operational
control
practices
for
wastewater
treatment
operations
and
likely
relationships
to
system
performance,
and
may
be
used
to
develop
appropriate
best
management
practices.
In
addition,
it
may
be
used
to
estimate
operating
and
maintenance
costs.
EPA
can
use
this
information
to
determine
whether
the
ship
is
performing
all
the
necessary
operating
and
maintenance
procedures
and
to
estimate
costs
for
improved
operation
and
maintenance.
18
Questions
62
and
63
request
information
regarding
preventative
maintenance
activities
and
frequencies
in
2004.
Question
62
provides
a
short
list
of
pre­
specified
preventative
maintenance
activities
and
requests
a
yes
or
no
answer,
as
well
as
the
frequency
and
treatment
unit
on
which
the
maintenance
was
performed
and
whether
maintenance
is
completed
and
scheduled
by
a
programmed
system.
The
question
provides
respondents
with
the
opportunity
to
also
enter
any
other
preventative
maintenance
activities
that
took
place
during
the
year.
Question
63
asks
how
wastewater
is
handled
during
maintenance
activities.
The
list
would
provide
information
regarding
wastewater
treatment
system
operation
and
maintenance
practices
as
they
relate
to
system
performance,
and
may
be
used
to
develop
appropriate
best
management
practices.
In
addition,
it
may
be
used
to
estimate
operating
and
maintenance
costs.
Based
on
this
information,
EPA
can
determine
if
the
ship
is
performing
all
the
necessary
operating
and
maintenance
procedures.

Question
64
asks
for
the
occurrence
of
overall
system
and/
or
component
failures
in
operation
of
the
wastewater
treatment
system
in
2004.
If
the
respondent
answers
yes,
they
are
further
asked
to
explain
the
nature
and
cause
of
the
failures.
This
question
may
uncover
common
wastewater
treatment
failures
and
causes
among
vessels.
Equipment
or
operational
failures
in
the
wastewater
treatment
system
also
affect
system
performance,
and
are
important
considerations
in
developing
best
management
practices,
regulatory
compliance
cost
estimates
and
technology
options
based
on
the
relationship
of
operation
and
maintenance
practices
to
system
performance.
In
addition,
this
information
may
be
used
as
a
basis
to
select
(
or
reject)
effluent
data
in
developing
the
discharge
limitations.
For
example,
data
collected
during
system
failures
may
be
rejected
for
use
in
developing
discharge
limitations.

Questions
65
and
66
ask
if
someone
is
designated
to
operate
the
wastewater
treatment
system
and
requests
a
description
of
the
training
provided
to
the
operator.
This
information
may
be
used
to
estimate
operating
costs.

Question
67
requests
a
copy
of
the
wastewater
treatment
system
operating
and
maintenance
log
for
2004.
The
information
in
this
log
would
contribute
to
developing
the
technology
options
and
regulatory
compliance
cost
estimates,
and
to
the
details
of
appropriate
best
management
practices.
In
addition,
EPA
would
use
this
information
to
estimate
operating
and
maintenance
costs.
Based
on
this
information,
EPA
could
determine
if
the
ship
is
performing
all
the
necessary
operating
and
maintenance
procedures
and
if
certain
procedures
could
be
implemented
to
improve
the
treatment
of
the
system.

Question
68
requests
information
on
wastewater
treatment
units
used
to
treat
sewage
and/
or
graywater
on
the
cruise
vessel
in
2004.
This
question,
which
takes
up
about
half
of
the
pages
of
the
survey,
is
divided
into
16
subsections
describing
different
wastewater
treatment
unit
processes
and
operations.
Only
one
or
a
few
of
these
subsections
would
be
applicable
to
any
single
vessel.
For
example,
a
vessel
with
a
Type
III
Marine
Sanitation
Device
(
MSD)
holding
tank
and
no
other
treatment
would
only
need
to
complete
Subsection
H.
A
vessel
with
a
traditional
Type
II
MSD
would
only
need
to
complete
the
subsections
for
maceration
and
chlorination
(
J
and
B).
A
vessel
using
an
advanced
treatment
system
with
aerobic
biological
treatment
and
ultrafiltration
would
only
complete
Subsections
A
and
F.
Information
requested
under
each
subsection
includes
unit
specifications,
frequency
and
type
of
monitoring,
system
19
maintenance,
information
regarding
all
influent
and
effluent
flows
(
solids
and
liquids),
and
chemical
additions
if
required.
This
information
would
be
used
to
develop
the
designs
of
individual
unit
operations
of
technology
options
and
regulatory
compliance
and
cost
estimates,
and
to
develop
appropriate
best
management
practices.

Question
69
requests
the
identification
of
all
discharges
from
the
treatment
system
including
treated
wastewater,
sludge,
and
other
residuals.
The
question
also
asks
for
actual
or
estimated
flow
or
discharge
rates
and
the
destination
for
each
discharge.
This
question
would
provide
further
important
information
regarding
the
destination
of
all
wastes
following
treatment
and
would
substantially
contribute
to
developing
technology
options
and
their
non­
water
quality
environmental
impacts,
regulatory
compliance
cost
estimates,
and
to
developing
appropriate
best
management
practices.
In
addition,
this
information
may
be
used
for
the
pollutant
loadings
analysis
to
determine
which
discharge
is
the
final
effluent.

Question
70
requests
information
regarding
cruise
vessel
speed
during
discharge
overboard.
The
question
requires
a
check
for
greater
than
or
less
than
6
knots.
Vessel
speed
during
discharge
greatly
influences
dilution
of
the
discharged
waste
stream.
This
information
would
be
used
in
conducting
the
environmental
assessment.

Question
71
asks
whether
the
wastewater
treatment
system
is
certified
by
the
U.
S.
Coast
Guard
for
continuous
discharge
in
waters
in
and
near
Alaska
in
2004
and
2005.
The
question
requires
respondents
simply
to
check
yes
or
no.
In
order
to
be
certified
for
continuous
discharge,
the
wastewater
treatment
system
effluent
must
meet
more
stringent
effluent
discharge
standards
established
by
the
U.
S.
Coast
Guard
(
USCG)
pursuant
to
Title
XIV.
This
question
would
provide
information
regarding
which
ships
have
advanced
wastewater
treatment
systems
with
performance
that
may
reflect
the
pollutant
control
technology
ultimately
selected
by
EPA
as
the
basis
for
proposed
regulations.

Questions
72
and
73
request
information
regarding
discharge
practices
for
each
wastewater
treatment
system
while
in
waters
in
and
near
Alaska.
Specifically,
Question
72
asks
where
discharge
occurs
in
waters
in
and
near
Alaska,
and
Question
73
asks
what
conditions
would
cause
the
cruise
vessel
to
change
wastewater
discharge
practices.
This
information
would
be
used
for
the
environmental
assessment
and
the
pollutant
loadings
analysis.

Question
74
asks
if
the
treated
wastewater
is
reused.
EPA
would
use
this
information
to
develop
technology
options
and
associated
designs.

Questions
75
and
76
asks
whether
the
vessel
would
use
shore­
side
treatment
vessels
in
lieu
of
onboard
treatment
if
available.
Question
76
also
asks
for
the
cost
at
which
the
use
of
these
facilities
would
be
prohibitive.
This
information
would
be
used
to
determine
the
demand
for
shore­
side
treatment
as
an
alternative
to
onboard
wastewater
treatment.

Question
77
asks
the
respondent
if
the
cruise
vessel
is
meeting
the
requirements
in
MARPOL
Annex
IV,
meaning
the
vessel
meets
international
discharge
requirements
for
sewage.
The
response
to
this
question
would
aid
in
developing
technology
options
and
regulatory
compliance
cost
estimates,
and
appropriate
best
management
practices.
20
Question
78
requests
a
copy
of
the
vessel's
Sewage
and
Graywater
Discharge
Record
Book
for
2004.
If
the
vessel
also
operated
in
waters
in
and
near
Alaska
in
2000,
sewage
and
graywater
discharge
logs
are
also
requested
for
2000
if
available.
This
information
would
contribute
to
developing
wastewater
technology
options,
and
regulatory
compliance
cost
estimates
(
investment,
and
operation
and
maintenance
costs).
The
information
regarding
discharge
location
and
flow
would
also
be
used
for
the
environmental
assessment.
The
2004
records
are
required
for
compliance
with
Federal
Regulations
at
33
CFR
part
159,
subpart
E,
and
are
reviewed
periodically
by
the
Coast
Guard.
Based
upon
early
information­
gathering
visits
to
cruise
ships
by
EPA
and
supporting
engineering
contractor
staffs,
the
information
provided
in
the
2004
logs
is
readily
available
for
the
purposes
of
this
survey.
The
discharge
logs
for
2000
would
be
used
to
assess
changes
in
discharge
resulting
from
the
requirements
of
Title
IV.

Responses
to
Questions
69
through
78
would
provide
very
important
information
which
would
contribute
to
a
broad
range
of
critical
analyses
supporting
this
project,
including
developing
design
and
costs
of
technology
options,
compliance
costs,
best
management
practices,
an
environmental
assessment,
and
other
supporting
analyses.

Question
79
provides
an
opportunity
for
the
respondent
to
comment
on
survey
responses
in
this
section.

SECTION
4:
WASTEWATER
TREATMENT
SYSTEM
COST
Section
4
requests
information
on
the
costs
for
each
graywater
and/
or
sewage
treatment
system
(
including
holding
tanks)
on
each
cruise
vessel.
Specifically,
the
information
requested
in
this
section
includes
capital
costs
and
operating
costs
for
the
existing
wastewater
treatment
system,
space
availability
on
the
cruise
vessel,
and
power
generation.
This
information
would
be
used
to
develop
"
net"
compliance
cost
estimates
for
retrofitting/
upgrading
or
replacing
existing
systems
as
necessary.

Question
80
requests
costs
associated
with
each
graywater
and/
or
sewage
treatment
system.
Information
is
required
for
two
types
of
costs,
direct
and
indirect.
Direct
costs
include
purchased
equipment
and
installation,
instrumentation
and
control,
and
piping.
Indirect
costs
include
engineering
costs,
construction
expenses,
contractor's
fees,
and
contingency
funds
actually
expended.

Question
81
asks
for
an
itemized
list
of
purchased
equipment
and
purchased
equipment
installation
costs
provided
in
Question
80
for
each
major
piece
of
equipment.
This
information
would
provide
cost
estimates
for
wastewater
treatment
equipment
associated
with
holding
tanks,
Type
II
MSD's,
and
varying
types
of
advanced
treatment
systems
and
unit
operations
used
by
the
industry.
Data
from
questions
80
and
81
would
provide
the
best
available
information
on
actual
installed
capital
costs
for
existing
wastewater
treatment
systems.
This
information
would
be
used
to
estimate
incremental
investment
costs
for
each
cruise
ship
to
comply
with
each
technology
option.
21
Question
82
requests
the
installation
date
and
the
date
the
wastewater
treatment
system
began
operation.
This
information
would
provide
the
time
frames
required
from
purchase
to
installation
to
operation
for
the
various
types
of
treatment
systems.

Question
83
requests
actual
operating
and
maintenance
costs
paid
and
rates
for
each
wastewater
treatment
system
during
the
calendar
year
2004.
Costs
include
operating
labor,
maintenance
equipment
and
contracted
services,
sampling/
monitoring
costs,
chemical
costs,
and
sludge,
oil,
or
other
residual
disposal
fees.
Data
from
this
question
would
provide
the
best
available
information
on
operation
and
maintenance
costs
associated
with
existing
wastewater
treatment
systems
and
would
be
used
to
develop
compliance
cost
estimates.
This
information
would
be
used
to
estimate
incremental
operating
and
maintenance
costs
for
each
cruise
ship
to
comply
with
each
technology
option.

Questions
84
and
85
request
information
and
costs
of
recent
(
since
2000)
and
planned
(
2005
to
2010)
modifications
and/
or
shutdowns
to
the
wastewater
treatment
system.
Modifications
include
replacement,
upgrade,
or
addition
of
wastewater
treatment
units.
These
questions
also
ask
for
explanations
regarding
the
shutdown,
replacement,
upgrade,
or
addition
to
the
wastewater
treatment
units.
Information
from
these
questions
would
provide
a
profile
for
the
wastewater
treatment
modifications
and
upgrades
that
are
taking
place
industry­
wide
as
well
as
the
reason
for
the
modification,
especially
if
it
is
related
to
compliance
with
wastewater
discharge
standards.
In
addition,
this
information
would
be
used
for
the
pollutant
loadings
analysis.
Specifically,
it
would
be
used
to
ensure
that
the
data
received
represents
the
treatment
system
configuration
for
the
baseline
year
of
2004.
Costs
of
these
modifications
would
also
provide
information
that
would
be
used
to
develop
wastewater
treatment
system
compliance
cost
estimates.

Questions
86
and
87
request
information
and
costs
of
any
recent
(
since
2000)
or
planned
(
2005
to
2010)
modifications
to
the
sewage
or
graywater
collection
system,
including
piping,
or
collection/
holding
systems
(
other
than
treatment).
Modifications
may
include
upgrade,
rerouting,
or
addition
of
systems.
These
questions
also
ask
for
explanations
regarding
replacement,
upgrade,
reroute,
or
addition.
Responses
to
these
questions
would
provide
data
on
industry­
wide
modifications
to
the
wastewater
collection
systems
and
would
be
used
to
develop
compliance
cost
estimates
for
retrofitting/
upgrading
or
replacing
existing
systems
as
necessary.

Question
88
requests
the
location
and
dimensions
of
the
spaces
housing
the
wastewater
treatment
systems,
excluding
holding
tanks.
Question
89
asks
for
dimensions
of
the
portion
of
the
spaces
currently
housing
the
wastewater
treatment
system
that
are
available
for
the
installation
of
additional
wastewater
treatment
units.
Question
90
asks
for
the
location
and
dimensions
of
spaces
available
elsewhere
on
the
cruise
vessel
where
wastewater
treatment
units
may
be
installed.
Space
for
support
of
wastewater
treatment
systems,
such
as
on­
board
laboratory
and/
or
chemical
equipment
storage
space
are
also
requested.
Responses
to
these
questions
would
provide
an
estimate
for
the
space
required
by
certain
wastewater
treatment
unit
operations
as
well
as
space
available
for
additional
unit
operations.
All
of
this
information
would
be
taken
into
consideration
when
developing
unit
operation
and
system
designs
and
estimating
compliance
costs,
particularly
for
retrofitting
wastewater
treatment
system
upgrades
within
existing
systems.
22
Question
91
asks
if
cost
estimates
to
install
advanced
wastewater
treatment
have
been
obtained.
Responses
to
this
question
would
be
used
to
augment
the
costs
data
set
provided
by
the
responses
to
Questions
80
and
81.

Question
92
asks
whether
the
cruise
vessel
would
require
additional
power
generator
capacity
to
operate
additional
wastewater
treatment
units.
This
information
would
be
used
to
assess
whether
the
ship
has
the
power
generation
capabilities
to
support
upgraded
or
additional
wastewater
treatment
systems.
This
information
may
also
be
used
to
assess
the
energy
impacts
of
the
regulatory
options.

Question
93
provides
an
opportunity
for
the
respondent
to
comment
on
survey
responses
in
this
section.

SECTION
5:
SAMPLING
DATA
Section
5
requests
information
concerning
the
availability
of
sewage
and
graywater
stream
characterization
data
and/
or
data
characterizing
the
effectiveness
of
sewage
and
graywater
treatment.
This
information
would
be
used
to
determine
current
wastewater
discharge
characteristics
for
each
cruise
vessel,
to
evaluate
wastewater
treatment
performance,
and
to
estimate
pollutant
discharge
loadings.
Information
collected
from
these
questions,
coupled
with
wastewater
treatment
system
design
and
operating
data
collected
from
Section
3,
would
be
used
to
assess
the
performance
of
wastewater
treatment
technologies.

Questions
94
through
97
require
a
yes/
no
answer
and
ask
if
wastewater
samples
were
collected
and
analyzed
to
characterize
any
untreated,
treated,
partially
treated,
treatment
residuals,
and
paired
influent
and
effluent
sewage
or
graywater
generated
by
each
vessel.
Responses
to
these
questions
would
indicate
whether
sampling
data
are
available
for
use
by
EPA.

Question
98
requests
all
corresponding
sampling
data,
including
sampling
points
and
analytes.
A
checklist
is
presented,
following
question
instructions,
to
ensure
that
the
sampling
data
is
complete
and
submitted
as
intended.
To
reduce
the
burden
to
the
respondent,
only
sampling
data
that
were
not
otherwise
provided
to
EPA
(
e.
g.,
via
ADEC,
USCG)
need
to
be
submitted
in
response
to
this
survey.
Upon
careful
review,
it
is
likely
that
most
or
all
of
these
historical
data
would
be
usable,
as
an
important
supplement
to
data
that
would
be
generated
from
sampling
by
EPA
of
cruise
ships
operating
in
waters
in
and
near
Alaska
during
the
summer
of
2004,
to
determine
current
wastewater
discharge
characteristics,
evaluate
wastewater
treatment
performance,
and
to
estimate
pollutant
discharge
loadings.

Question
99
provides
an
opportunity
for
the
respondent
to
comment
on
survey
responses
in
this
section.

SECTION
6:
POLLUTION
PREVENTION
PRACTICES
Section
6
requests
information
to
evaluate
the
status
of
pollution
prevention
practices
for
each
cruise
vessel,
to
identify
pollution
prevention
technologies,
and
to
quantify
the
performance
of
any
such
practices.
Some
generic
overview
information
on
these
practices
is
available
from
23
existing
sources
and
would
be
pre­
populated
in
cruise
vessel­
specific
surveys.
EPA
would
use
this
information
to
identify
appropriate
practices
that
may
become
part
of
regulatory
options
yet
to
be
developed
and
to
prepare
an
industry
profile
of
pollution
prevention
practices,
and
also
potentially
allow
EPA
to
assess
their
impact
on
sewage
and
graywater
generation
rates.

Question
100
provides
a
list
of
environmental
management,
pollution
prevention,
or
waste
reduction
practices
with
check
boxes
for
the
respondent
to
indicate
those
used
on
each
cruise
vessel.
Following
the
list,
Question
100
requests
a
description
of
the
practice;
affected
cruise
vessel
processes
and
wastewater
streams;
targeted
pollutants
of
the
practice;
costs
and/
or
savings
of
implementing
the
practice;
and
the
resulting
reduction
in
quantity
of
the
wastewater
generated
and
freshwater
requirements.
The
respondent
is
asked
to
photocopy
the
pages
containing
Question
100
for
each
practice
checked.

Question
101
provides
a
list
of
environmental
management
practices
with
check
boxes
for
the
respondent
to
indicate
those
used
on
each
cruise
vessel.
These
practices
include
passenger
education,
employee
training
or
incentives,
and
implementation
of
an
Environmental
Management
System.
Copies
of
the
environmental
policy
statement
and
any
stated
targets
related
to
sewage
and
graywater
discharges
are
also
requested.

Question
102
asks
if
future
pollution
prevention
practices,
pollution
management,
or
waste
reduction
practices
are
planned
and
asks
the
respondent
to
list
the
practice(
s)
and
the
scheduled
implementation
date.

EPA
would
use
responses
to
Questions
100
through
102,
supplemented
by
responses
to
preceding
questions,
to
develop
any
necessary
and
appropriate
best
management
practices.

Question
103
provides
an
opportunity
for
the
respondent
to
comment
on
survey
responses
in
this
section.

(
d)
Part
C:
Financial
and
Economic
Information
Part
C
of
the
detailed
survey
would
gather
information
necessary
to
complete
an
economic
impact
analysis
of
the
proposed
discharge
limitations
for
the
Alaska
Cruise
Ship
industry.
The
questions
are
separated
into
three
sections.
Section
1
collects
financial
information
about
the
vessel
and
the
respondent
completes
a
separate
Part
C:
Section
1
for
each
cruise
vessel
operating
in
waters
in
and
near
Alaska
that
it
owns.
Section
2
requests
detailed
information
about
the
company,
such
as
ownership
structure,
NAICS
code,
discount
rate,
fiscal
year
start
month,
income
statement,
and
balance
sheet
information.
Section
3
requests
information
at
the
corporate
parent
level.
Asking
questions
at
different
levels
assures
that
EPA
would
have
sufficient
information
to
evaluate
regulatory
impacts
at
all
levels
of
economic
activity.

To
minimize
the
burden
of
responding
to
the
survey,
the
respondent
must
complete
only
applicable
sections.
The
questions
are
phrased
with
commonly
used
terminology.
Tables
are
organized
with
formats
familiar
to
financial
officers
in
the
respondent
industry.
Questions
requesting
similar
types
of
information
are
arranged
together
to
facilitate
review
of
the
pertinent
records
and
completion
of
the
survey.
24
For
some
questions,
three
years
of
data
are
needed
to
provide
information
to
identify
industry
trends,
to
resolve
data
anomalies,
and
to
identify
potential
irregularities
caused
by
events
outside
of
the
Alaska
Cruise
Ship
industry's
control.
EPA
requests
financial
and
economic
information
for
the
fiscal
years
ending
2002,
2003,
and
2004
 
the
most
recent
years
for
which
data
are
available.

SECTION
1:
CRUISE
VESSEL
FINANCIAL
INFORMATION
EPA
introduces
the
economic
and
financial
portion
of
the
questionnaire
by
providing
an
explanation
of
why
the
data
being
requested
are
needed.
EPA
believes
when
the
respondent
understands
the
role
of
economic
and
financial
analysis
in
establishing
discharge
limitations,
the
respondent
would
also
see
that
it
is
to
his/
her
benefit
that
EPA
be
able
to
evaluate
economic
impacts
using
real­
world
data
that
reflect
actual
operating
conditions.

The
respondent
would
complete
a
Section
1
for
each
vessel
it
owns
that
operated
in
waters
in
and
near
Alaska
in
2004.
The
section
begins
by
requesting
the
average
number
of
employees
on
this
vessel
for
Alaska
voyages
and
voyages
to
other
regions
(
Questions
1a
and
1b).
These
data
inform
us
whether
staffing
levels
for
the
vessel
differ
by
regions
and
the
potential
range
in
jobs
lost
should
the
vessel
become
unprofitable
to
operate.
Questions
2a
and
2b
ask
for
the
number
of
employees
listed
in
Questions
1a
and
1b,
respectively,
that
are
based
in
Alaska.
These
data
would
be
used
for
estimating
regional
impacts.
Question
3a
requests
the
total
number
of
hours
worked
by
all
staff
during
2004
and,
of
those,
how
many
are
associated
with
Alaska
voyages.
The
combination
of
responses
from
Questions
1
and
3
provide
EPA
with
the
estimated
number
of
hours
worked
per
employee.

With
Question
4,
Section
1
focuses
on
financial
data
for
the
vessel.
Throughout
the
questionnaire,
the
respondent
is
asked
to
provide
answers
in
terms
of
U.
S.
dollars.
Question
4
asks
whether
financial
records
are
kept
on
a
basis
of
U.
S.
dollars
and,
if
not,
the
respondent
is
asked
to
identify
the
conversion
factor
used.

Question
5
solicits
income
statement
data
for
2004
for
all
vessel
operations
and
for
Alaska
voyages
only.
The
information
requested
includes
total
revenue,
costs,
depreciation,
and
expenses
from
which
to
calculate
earnings
before
interest
and
taxes
(
EBIT).
EPA
anticipates
that
this
information
is
available
for
all
vessels.
Question
5
also
requests
the
remainder
of
income
statement
information
(
i.
e.,
interest
expenses,
taxes,
and
net
income)
should
these
items
be
recorded
on
a
vessel's
income
statement.
The
survey
requests
the
respondent
to
identify
costs
and
revenues
associated
with
Alaska
voyages
to
the
extent
possible
because
of
the
focus
on
wastewater
controls
in
this
region.
Questions
6
and
7
request
the
same
information
but
for
fiscal
years
2003
and
2002.

EPA
is
requesting
three
years
of
cost
and
income
data
for
several
reasons.
First,
some
vessels
have
installed
upgraded
wastewater
treatment
systems
and/
or
practices
during
this
period
and,
for
these
vessels,
the
Agency
would
be
able
to
examine
the
changes
in
financial
health
due
to
these
modifications.
Second,
three
consecutive
years
of
data
would
provide
a
much
more
accurate
picture
of
the
financial
condition
of
the
vessel.
Third,
three
years
of
data
provides
EPA
with
an
estimate
of
the
year­
to­
year
variation
in
income
and
costs.
The
vessel­
level
analysis
25
would
not
hinge
on
a
single,
possibly
atypical,
year.
Fourth,
EPA
can
identify
possible
outliers
or
trends
in
the
data.
A
vessel
might
be
projected
to
fail
prior
to
any
incurrence
of
regulatory
costs
if
all
three
years
show
declining
to
negative
income.

The
information
collected
in
Questions
5
through
7
serves
as
the
basis
for
developing
forecasted
earnings.
The
time
frame
for
the
projection
would
correspond
to
the
time
frame
for
the
cost
annualization
which,
in
turn,
depends
on
the
equipment
lifetime
of
the
pollution
control
options
under
consideration.
EPA
would
calculate
the
present
value
of
earnings
and
the
present
value
of
incremental
pollution
control
costs
for
each
vessel
using
the
discount
rate
information
collected
in
Section
2.

Question
8
asks
the
cruise
line
to
report
expenditures
for
supplies
and
recreational
services
at
various
ports
of
call
in
Alaska
(
both
intra­
company
transfers
and
expenditures).
These
data
track
the
economic
contribution
of
these
ships
to
the
local
economies.
(
EPA
would
rely
on
public
data
to
estimate
the
amount
of
onshore
expenditures
by
vacationers,
another
major
source
of
income
to
these
communities.)

Questions
9
and
10
ask
for
information
on
capital
replacement
costs
at
the
vessel
level.
These
costs
are
considered
a
part
of
what
the
vessel
needs
to
recoup
over
time
in
order
to
continue
as
a
viable
operation.
This
information
will
help
EPA
make
a
determination
of
vessel
financial
health
over
the
time
frame
of
the
analysis.

SECTION
2:
CRUISE
LINE
FINANCIAL
INFORMATION
Question
11
asks
whether
the
company
is
domestic
or
foreign.
This
question
helps
interpret
the
information
requested
in
Question
12.
Questions
12
and
13
request
the
company
to
identify
its
corporation
type
and
ask
whether
the
company
is
publicly
or
privately
owned.
This
information
is
necessary
to
determine
a
company's
tax
status
and
the
availability
of
additional
public
data
for
the
economic
analysis.

Question
14
requests
the
company's
North
American
Industrial
Classification
System
(
NAICS)
code.
This
information
is
needed
to
evaluate
the
range
of
industries
potentially
affected
by
the
rulemaking
and
the
Small
Business
Administration's
(
SBA's)
small
business
standards
that
could
apply
to
regulated
community.
The
latter
are
needed
for
the
regulatory
flexibility
analysis.

Question
15
asks
for
the
average
number
of
employees
at
the
company,
all
Alaska
operations,
and
Alaska
voyages.
That
is,
the
cruise
line
might
have
substantial
onshore
operations
that
supply
the
vessel
while
in
port
or
provide
recreational
activities
to
the
vacationers.
These
employees
would
also
be
affected
by
a
change
in
Alaska
operations
and,
so,
are
of
interest
to
EPA.
SBA
size
standards
are
given
in
terms
of
the
number
of
employees
or
annual
revenues.
This
information
is
needed
to
evaluate
whether
the
vessel
is
owned
by
a
small
business.

Questions
16
and
17
request
the
estimated
interest
rate
and
the
estimated
equity
rate
the
company
pays
to
finance
capital
improvements,
respectively.
Question
18
asks
about
the
appropriate
mix
of
debt
(
Question
16)
and
equity
(
Question
17)
used
to
finance
capital
26
improvements.
The
economic
analysis
would
use
these
data
to
annualize
the
cost
of
future
wastewater
treatment
investments.

Question
19
asks
for
the
starting
month
of
the
company's
fiscal
year
in
case
it
becomes
necessary
to
adjust
for
technical
information
provided
on
a
calendar
basis
and
financial
information
provided
on
a
fiscal
year
basis.
Question
20
is
the
same
as
Question
4
but
for
the
cruise
line
rather
than
the
vessel
in
case
one
set
of
financial
records
are
kept
in
U.
S.
dollars
and
the
other
is
not.

Similarly,
Questions
21
through
23
parallel
Questions
5
through
7.
Both
set
of
questions
request
income
statement
information
in
formats
familiar
to
financial
officials
for
Alaska
operations
and
for
all
operations.
While
Questions
5
though
7
pertain
to
individual
vessels,
Questions
21
through
23
request
data
on
revenues,
costs,
interest,
and
taxes
for
the
entire
company.
The
difference
between
the
sum
of
all
Alaska
cruises
for
all
vessels
owned
by
the
cruise
line
and
the
value
of
all
Alaska
operations
allows
EPA
to
infer
the
value
of
onshore
Alaska
operations
that
would
not
be
captured
by
Section
1
data
but
which
are
important
for
evaluating
community
impacts.
Dividing
the
Alaska
financials
into
land­
based
and
vessel­
based
provides
for
additional
information
necessary
for
estimating
the
contribution
the
firm
makes
to
the
local
economies,
since
vessels
contribute
to
the
local
economy
in
a
different
way
than
land­
based
operations.
For
privately
held
firms
or
wholly
owned
subsidiaries,
such
data
are
not
available
by
any
means
other
than
this
survey.
These
data
are
key
to
the
projection
of
company
revenues
and
how
they
might
be
affected
by
the
aggregate
costs
of
upgrading
all
of
their
Alaska
cruise
vessels.

Question
24
requests
balance
sheet
information
at
the
company
level
for
2002,
2003,
and
2004.
The
request
is
made
in
familiar
format
for
current
assets
excluding
inventories,
non­
current
assets
(
land,
buildings,
vessels,
and
equipment)
as
well
as
associated
cumulative
depreciation.
Requested
liability
data
include
current
liabilities,
long­
term
debt,
retained
earnings,
and
other
owner
equity.
The
balance
sheet
data
can
be
used
to
calculate
a
series
or
weighted
average
of
financial
ratios
that
indicate
financial
health
(
e.
g.,
current
ratio,
working
capital­
to­
debt,
and
debtto
assets).
Three
years
of
data
are
requested
in
order
to
study
the
changes
in
financial
health
for
cruise
lines
that
upgraded
waste
water
pollution
controls
during
this
period.

Question
25
asks
respondents
to
provide
copies
of
accounting
reports,
annual
reports,
and/
or
10­
K
forms
for
fiscal
year
2004
for
the
company.
These
data
can
be
provided
with
little
additional
effort
on
the
part
of
the
respondent.
EPA
uses
the
additional
information
to
understand
the
industry,
the
role
of
each
company
within
the
industry,
and
details
that
might
explain
what
otherwise
might
be
considered
outliers
in
the
survey
data.
EPA
also
uses
the
data
to
resolve
inconsistencies
with
the
survey
responses
prior
to
contacting
the
respondent
for
follow­
up
information
or
clarification.

SECTION
3:
CORPORATE
PARENT
FINANCIAL
INFORMATION
Only
those
companies
that
are
owned
or
operated
by
another
business
or
joint
entity
would
answer
questions
in
Section
3.
If
the
cruise
line
is
not
owned
by
another
company,
the
respondent
checks
the
"
No"
box
in
Question
26
and
skips
to
Question
31.
27
The
respondent
who
checks
the
"
Yes"
box
in
Question
26
needs
to
answer
only
four
additional
questions.
The
respondent
needs
to
provide
the
corporate
parent's
name
and
mailing
address
(
Question
27),
its
NAICS
code
(
Question
28),
the
total
number
of
employees
for
the
corporate
parent
in
fiscal
year
2004
(
Question
29),
and
copies
of
the
2004
financial
statements
(
Question
30).
SBA
makes
its
determination
of
a
small
business
at
the
highest
level
in
the
corporate
hierarchy
and
the
size
standard
differs
according
to
the
NAICS
code.
Through
these
four
questions,
EPA
has
the
NAICS
code,
the
number
of
employees
and
the
2004
revenues
from
the
financial
reports
in
order
to
identify
corporate
parents
that
might
be
small
businesses.

Question
31
asks
the
respondent
to
identify
an
individual
for
EPA
to
contact
concerning
information
submitted
in
Part
C
of
the
survey,
as
well
as
the
days
and
times
when
he
or
she
can
be
reached.
This
question
is
not
duplicative
of
Part
A
Questions
5
and
6
because
the
contacts
for
engineering
and
financial
data
are
frequently
different
individuals.
This
information
is
needed
in
the
event
that
clarification
is
needed
for
a
response
or
set
of
responses.

Question
32
provides
an
opportunity
for
the
respondent
to
comment
on
survey
responses
in
Part
C.

Record
Keeping
This
is
a
one
time
information
collection
effort.
There
would
be
no
need
for
the
respondents
to
maintain
additional
records.

(
ii)
Respondent
Activities
Each
respondent
would
receive
Parts
A
(
General
Cruise
Line
Information),
B
(
Cruise
Vessel
Technical
Information,
and
C
(
Financial
and
Economic
Information)
of
the
survey.
The
respondents
must
read
the
transmittal
letter
with
attachments
citing
authority
of
section
308
of
the
Clean
Water
Act
and
confidentiality
and
handling
of
any
responses
for
which
assertions
of
confidential
business
information
(
CBI)
may
be
made.
In
addition,
respondents
must
read
the
Introduction,
General
Instructions,
Definition
of
Key
Terms,
Abbreviations/
Symbols,
and
Certification
Statement
sections
in
the
beginning
of
Part
A
of
the
survey.
The
Introduction
section
provides
the
purpose
and
use
of
the
survey,
survey
outline,
e­
mail
and
website
information,
how
to
return
the
survey,
and
provisions
regarding
data
confidentiality.
The
General
Instructions
section
gives
the
respondent
guidance
on
completing
the
responses
and
including
attachments,
if
needed.
The
Definition
of
Key
Terms
provides
respondents
with
all
pertinent
definitions
and
acronyms
to
understand
and
complete
the
survey.
The
Abbreviations/
Symbols
section
lists
abbreviations
and
symbols
to
assist
respondents
in
understanding
frequently
used
survey
acronyms,
abbreviations,
and
numerical
units.

The
survey
respondent
would
have
to
read
and
understand
the
survey,
plan
response
activities,
gather
information,
compile
and
review
information,
and
complete
the
survey
form.
The
respondent
would
also
have
to
verify
and
update
"
draft"
responses,
provided
by
EPA
from
existing
sources,
to
a
portion
of
the
questions.
The
respondent
would
also
be
required
to
photocopy
and
retain
the
completed
survey
form
for
up
to
one
year,
in
the
event
that
EPA
has
to
contact
the
ship
for
clarification
of
any
response.
28
Section
3
in
Part
B
of
the
survey
requires
the
respondents
to
consult
records
on
wastewater
treatment
and
discharge
information.

To
complete
Part
C
of
the
survey,
respondents
would
have
to
access
and
compile
data
from
vessel­
specific
and
cruise
line
revenue,
costs,
employment,
asset,
and
liability
files.
For
vessels
that
have
a
corporate
parent
company
in
their
business
structure,
only
financial
statements
would
have
to
be
provided
by
the
ship.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
5(
a)
Agency
Activities
The
Agency
has
conducted,
is
conducting,
or
would
conduct
the
following
activities
to
administer
the
Survey
Questionnaire
to
Determine
the
Effectiveness,
Costs,
and
Impacts
of
Sewage
and
Graywater
Treatment
Devices
for
Large
Cruise
Ships
Operating
in
Alaska:


Development
of
the
survey
questionnaire;


Review
of
survey
by
trade
associations,
industry
representatives,
EPA
workgroup,
OMB,
and
other
stakeholders;


Development
of
the
ICR;


Revisions
of
the
survey
based
on
comments
from
trade
associations,
individual
cruise
lines,
Alaska
State
regulating
agency,
EPA
workgroup
members,
OMB,
and
other
stakeholders;


Development
of
a
mailing
list
database
and
mailing
labels;


Development
of
a
tracking
system
for
survey
mail­
out,
receipt,
and
return
activities;


Mailing
of
surveys;


Development
and
maintenance
of
e­
mail
addresses
and
a
website
for
respondents
who
require
assistance
in
completing
their
survey;


Development
of
a
database
for
survey
responses;


Receipt
and
review
(
coding)
of
survey
responses;


Data
entry
and
verification;


Summarization
and
analysis
of
survey
responses
(
industry
profile);
and
29

Performance
of
statistical
summaries
and
technical
analyses.

EPA
would
use
the
survey
results
as
a
part
of
its
effort
to
develop
sewage
and
graywater
discharge
regulations
for
large
cruise
ships
that
operate
in
waters
in
and
near
Alaska.
These
data
received
would
be
transferred
from
the
questionnaire
form
to
a
master
database
for
future
use.

5(
b)
Collection
Methodology
and
Management
Each
selected
cruise
line
would
receive
their
own
survey
with
an
assigned
cruise
line
identification
number.
The
survey
would
include
a
copy
of
the
vessel­
specific
sections
in
Parts
B
and
C
for
each
cruise
vessel,
plus
a
blank
copy
of
these
sections.
The
sections
for
each
cruise
vessel
would
have
the
vessel
name
and
a
vessel
identification
number.
Each
cruise
line
respondent
can
complete
the
survey
by
legibly
handwriting
or
typing
the
responses
in
the
spaces
provided.
Electronic
versions
would
also
be
available
to
the
respondents
at
their
request.
The
survey
would
be
sent
via
Federal
Express
or
comparable
carrier
to
ensure
a
point
of
contact
(
the
cruise
line
contact
person)
signs
for
and
receives
the
survey
package.
Each
cruise
line
would
be
allowed
60
calendar
days
to
return
the
completed
survey.

Two
e­
mail
addresses,
one
for
Parts
A:
General
Cruise
Line
Information
and
B:
Cruise
Vessel
Technical
Information,
and
one
for
Part
C:
Financial
and
Economic
Information,
would
be
available
to
provide
assistance
in
completing
the
survey
to
international
respondents
as
well
as
respondents
in
different
time
zones.
The
e­
mail
addresses
would
reduce
the
burden
to
the
survey
respondents
by
providing
a
timely
response
to
any
inquiries
that
the
respondents
may
have.
The
e­
mail
addresses
would
also
reduce
any
misinterpretations
of
the
survey
and
thus
decrease
the
burden
of
follow­
up
phone
calls
and
letters
to
the
respondents.
E­
mail
is
the
preferred
means
of
communication
because
cruise
line
personnel
have
ready
access
to
this
resource.
Telephone
communication
is
much
less
accessible
and
would
be
a
significant
expense.

A
website
would
also
be
available
to
provide
assistance
in
completing
the
survey.
The
website
information
may
include
responses
to
frequently
asked
questions,
a
copy
of
the
survey,
general
instructions,
a
checklist
to
ensure
the
survey
is
complete
before
its
return,
the
survey
schedule,
and
other
information
to
assist
the
respondents.

Each
page
of
a
cruise
line's
survey
would
have
a
unique
cruise
line
and
a
unique
vessel
identification
number
for
ease
of
tracking.
The
cruise
line
identification
number
would
be
used
to
track
the
mailing
date
of
the
survey,
cruise
line
survey
receipt
date,
follow­
up
letters
and
telephone
calls
to
respondents,
and
EPA's
receipt
of
the
completed
survey.
The
identification
number
would
also
be
used
as
an
identification
code
for
data
entry
in
the
survey
database.
Follow­
up
calls
would
be
performed
as
needed
to
clarify
inconsistencies
in
cruise
line
responses,
and
to
remind
non­
respondents
of
their
requirement
to
complete
and
return
the
survey.

Upon
receipt
of
completed
surveys,
EPA
and
EPA
contractors
would
review
the
surveys
for
completeness
and
accuracy
and
enter
data
codes
to
prepare
the
survey
for
data
entry.
The
coded
survey
responses
would
be
entered
into
a
database.
This
database
would
then
be
used
to
perform
data
analysis.
30
5(
c)
Small
Entity
Flexibility
No
small
business
standard
is
expected
to
apply
to
the
cruise
lines
to
be
regulated.
EPA
would
verify
that
the
small
business
status
does
not
exist
for
these
cruise
lines
or
vessels.

5(
d)
Collection
Schedule
Based
on
a
maximum
of
90
days
for
OMB
review,
the
schedule
for
the
survey
distribution,
response
receipt,
and
data
collection
activities
is
as
follows:

Action
Approximate
Number
of
Calendar
Days
After
OMB
Approval
Survey
mailed
30
Receive
survey
responses
90
Complete
survey
follow­
up
125
Data
entry
of
survey
responses
145
Analysis
of
survey
responses
205
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
The
survey
was
submitted
to
the
North
West
Cruiseship
Association,
International
Council
of
Cruise
Lines
(
ICCL),
and
individual
cruise
lines,
the
Alaskan
Department
of
Environmental
Conservation,
the
United
States
Coast
Guard,
environmental
interest
groups,
Native
American
tribes,
and
other
stakeholders
for
review
and
comment
and
to
estimate
the
total
number
of
burden
hours
to
complete
the
survey.
The
burden
to
respondents
includes
the
time
necessary
to
read
and
understand
the
survey
and
instructions,
plan
response
activities,
gather
information,
compile
and
review
information,
and
complete
the
survey
form.

As
described
in
Sections
3(
b)
and
3(
c)
of
this
Information
Collection
Request,
EPA
provided
many
opportunities
for
comment
on
the
burden
to
respond
to
the
survey.
EPA
received
several
general
comments
indicating
that
EPA
had
underestimated
the
burden;
EPA
received
only
one
comment
containing
a
quantitative
burden
estimate.
This
source
estimated
that
it
would
take
20
hours
per
ship
to
complete
the
technical
portions
of
the
survey
and
200
hours
for
a
cruise
line
with
six
applicable
ships
(
33
hours
per
ship)
to
complete
the
economic
portion
of
the
survey.
In
response
to
these
comments,
EPA
has
increased
its
burden
estimates
(
as
described
below)
from
those
provided
in
the
Federal
Register
Notice
on
February
3,
2004.

For
the
purpose
of
estimating
burden,
there
are
two
types
of
vessels:
(
1)
vessels
with
advanced
wastewater
treatment
systems
certified
to
discharge
continuously
in
waters
in
and
near
Alaska
under
33
CFR
159.309;
and
(
2)
vessels
that
do
not
have
wastewater
treatment
systems
authorized
to
discharge
continuously.
31
Vessels
authorized
to
discharge
continuously
would
need
to
complete
additional
questions
regarding
their
wastewater
treatment
system
and
wastewater
discharge
resulting
in
an
increased
respondent
burden.
EPA
estimates
it
would
take
the
respondent
an
average
of
approximately
54
hours
to
complete
and
review
their
responses
to
the
survey
and
associated
data
submissions
for
each
cruise
vessel
that
is
certified
to
continuously
discharge.

For
the
vessels
that
do
not
have
wastewater
treatment
systems
authorized
to
discharge
continuously
in
Alaska,
EPA
estimates
it
would
take
an
average
of
approximately
29
hours
to
complete
and
review
responses
to
the
survey.

EPA
would
distribute
the
survey
to
the
entire
population
(
census)
of
12
cruise
lines
operating
large
vessels
(
total
of
30)
in
the
waters
in
and
near
Alaska
in
2004.
Because
the
cruise
lines
are
legally
obligated
to
complete
the
survey
under
the
authority
of
Clean
Water
Act
Section
308
(
see
Title
XIV,
Section
1413),
EPA
expects
a
100
percent
response
rate.
EPA
estimates
that
the
total
burden
for
cruise
lines
operating
the
16
vessels
certified
to
discharge
continuously
under
33
CFR
159.309
would
be
approximately
864
hours.
EPA
estimates
that
the
total
burden
for
the
14
vessels
that
are
not
certified
to
discharge
continuously
would
be
approximately
406
hours.
Therefore,
the
total
burden
estimate
for
all
12
cruise
lines
to
complete
surveys
for
the
30
vessels
would
be
1,270
hours.
Table
6­
1
presents
the
average
hourly
and
total
burden
by
labor
category
associated
with
all
respondent
activities
necessary
to
complete
the
survey.

Table
6­
1
Estimated
Respondent
Burden
to
Complete
the
Survey
(
Hours)

Respondent
Activity
Environmental
Engineer
Accountant
Clerical
Support
Engineering
Manager
Financial
Manager
Lawyer
Total
Burden
per
Activity
(
Hours)

Cruise
Vessels
Certified
for
Continuous
Discharge
(
16
Vessels)

Read
Instructions
3
0.5
1.5
1
1
7
Gather
Information/
Data
16
6
2.5
24.5
Complete
Survey
Form
7.5
3.5
2.5
13.5
Review
Survey
Responses
5
2.5
1.5
9
Estimated
Burden
for
Continuous
Discharge
Vessel
54
Subtotal
of
Survey
Burden
(
Average
Respondent
Hours
×
16
Vessels)
864
Cruise
Vessels
Not
Certified
for
Continuous
Discharge
(
14
Vessels)

Read
Instructions
1
0.5
1.5
1
1
5
Gather
Information/
Data
2.5
6
1.5
10
Complete
Survey
Form
2
3.5
2
7.5
Review
Survey
Responses
2.5
2.5
1.5
6.5
Estimated
Burden
for
Non­
Continuous
Discharge
Vessel
29
Subtotal
of
Survey
Burden
(
Average
Respondent
Hours
×
14
Vessels)
406
Total
Respondent
Burden
(
Estimated
Hours
for
30
vessels)
1,270
Table
6­
1
(
Continued)

32
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
The
direct
cost
to
respondents
to
complete
the
survey
equals
the
time
required
to
read
and
understand
the
survey,
gather
the
information,
compile
and
review
the
information,
and
complete
the
survey
form.
Two
e­
mail
addresses
would
be
operated
by
EPA
contractors
to
assist
vessels
in
responding
to
the
survey.
Material
costs
to
each
respondent
would
include
photocopying
and
postage.
Labor
costs
would
comprise
the
majority
of
the
financial
burden
imposed
on
the
industry.

The
Agency
estimates
an
average
cost
of
$
2,186
(
averaged
between
managerial,
professional,
and
clerical
staff)
for
each
cruise
vessel
authorized
to
discharge
continuously.
EPA
estimates
the
total
cost
for
the
16
vessels
certified
to
discharge
continuously
would
be
approximately
$
35,000.
For
each
cruise
vessel
not
authorized
to
discharge
continuously,
EPA
estimates
an
average
cost
of
$
1,080.
The
Agency
estimates
the
total
cost
for
the
14
vessels
that
do
not
discharge
continuously
would
be
approximately
$
15,000.
Table
6­
2
presents
the
average
and
total
respondent
cost
to
complete
the
survey
using
earnings
data
from
the
Bureau
of
Labor
Statistics,
National
Compensation
Survey
(
July
2003).
EPA
increased
the
median
hourly
earnings
by
31.25
percent
to
account
for
benefits.
The
total
respondent
labor
cost
to
complete
the
survey
for
the
30
cruise
vessels
is
$
50,091.
33
Table
6­
2
Estimated
Respondent
Costs
to
Complete
the
Survey
Respondent
Position
Bureau
of
Labor
Statistics
Occupation
Median
Hourly
Earnings
Median
Hourly
Earnings
Plus
Benefits
Average
Hours
O&
M
(
Dollars)
Total
Cost*

Cruise
Vessels
Certified
for
Continuous
Discharge
(
16
Vessels)

Environmental
Engineer
Engineer,
n.
e.
c.
$
35.33
$
46.37
26.5
$
1,229
Accountant
Accountant
$
23.30
$
30.58
10
$
306
Clerical
Support
Typist
$
13.51
$
17.73
5
$
89
Engineering
Manager
Engineering
Manager
$
32.38
$
42.50
6.5
$
276
Financial
Manager
Financial
Manager
$
29.57
$
38.81
3.5
$
136
Lawyer
Lawyer
$
45.95
$
60.31
2.5
$
151
Estimated
Average
Cost
for
Continuous
Discharge
Vessel
$
2,186
Subtotal
of
Survey
Costs
(
Average
Respondent
Costs
×
16
Vessels)
$
34,978
Cruise
Vessels
Not
Certified
for
Continuous
Discharge
(
14
Vessels)

Environmental
Engineer
Engineer,
n.
e.
c.
$
35.33
$
46.37
5.5
$
255
Accountant
Accountant
$
23.30
$
30.58
10
$
306
Clerical
Support
Typist
$
13.51
$
17.73
3.5
$
62
Engineering
Manager
Engineering
Manager
$
32.38
$
42.50
4
$
170
Financial
Manager
Financial
Manager
$
29.57
$
38.81
3.5
$
136
Lawyer
Lawyer
$
45.95
$
60.31
2.5
$
151
Estimated
Average
Cost
for
Non­
Continuous
Discharge
Vessel
$
1,080
Subtotal
of
Survey
Costs
(
Average
Respondent
Costs
×
14
Vessels)
$
15,113
Total
Respondent
Labor
Costs
(
Estimated
Cost
for
30
Vessels)
$
50,091
Total
Respondent
Labor
and
O&
M
Costs
(
Estimated
Cost
for
30
Vessels)
$
890
$
50,981
Notes:
Wage
rates
are
increased
by
31.25%
to
account
for
benefits.
*
Rounding
errors
involved.
Source:
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics.
National
Compensation
Survey,
July
2003.
Supplementary
Table
2­
2.
Private
Industry:
Mean
Hourly
Earnings
and
Percentiles,
Full­
Time
Workers.
http://
www.
bls.
gov/
ncs/
ocs/
sp/
ncbl05040.
pdf,
downloaded
17
September
2004.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
Because
EPA
would
not
require
survey
respondents
to
purchase
any
goods,
including
equipment
or
machinery,
to
respond
to
the
survey,
the
Agency
does
not
expect
capital
costs
to
result
from
the
administration
of
this
data
collection
survey.
Operation
and
maintenance
costs
include
only
photocopying
and
postage
for
the
completed
survey.
34
(
iii)
Capital/
Start­
up
Operating
and
Maintenance
Costs
EPA
estimates
there
would
be
no
capital
or
start
up
costs
associated
with
responding
to
the
survey.
Operating
and
maintenance
costs
include
only
photocopying
and
postage.
EPA
assumed
a
photocopying
rate
of
$
0.10
per
page
for
200
survey
pages
per
vessel
for
a
total
photocopying
cost
of
$
600.
EPA
assumes
the
respondents
will
return
the
completed
survey
via
Federal
Express
or
a
comparable
delivery
carrier
that
requires
a
signature
to
acknowledge
receipt.
EPA
estimates
the
Federal
Express
Saver
rate
at
$
9.65
for
a
1­
lb
package
per
vessel
for
a
total
mailing
cost
of
$
290.
Total
O&
M
cost
for
30
vessels,
computed
across
all,
is
estimated
at
$
890.

(
iv)
Annualizing
Capital
Costs
EPA
estimates
that
there
would
be
no
capital
costs
associated
with
responding
to
the
survey.

6(
c)
Estimating
Agency
Burden
and
Costs
Table
6­
3
presents
an
estimate
of
the
burden
and
labor
cost
that
EPA
would
incur
to
administer
the
Cruise
Ship
Survey.
The
table
identifies
the
collection
administration
tasks
to
be
performed
by
Agency
employees
and
contractors,
with
the
associated
hours
required
for
each
grouping
of
related
tasks.
EPA
determined
Agency
labor
costs
by
multiplying
Agency
burden
figures
by
the
hourly
Agency
labor
rate
of
$
54.84.
EPA
determined
this
rate
by
dividing
the
2004
base
GS­
13,
Step
5
rate
of
$
71,293
by
a
person­
year
of
2,080
hours,
and
then
multiplying
the
result
by
a
benefits
multiplication
factor
of
1.6.
EPA
determined
contractor
labor
costs
by
multiplying
contractor
burden
figures
by
an
average
contract
labor
rate
of
$
74.27.
This
rate
is
consistent
with
current
Agency
contracts.
Table
6­
4
presents
an
estimate
of
the
total
Agency
cost
including
estimates
of
the
one­
time
operating
and
maintenance
costs
associated
with
photocopying
and
postage.
EPA
estimated
O&
M
costs
based
on
experience
with
similar
collections.
Total
Agency
costs
(
including
contractor
and
O&
M
costs)
are
estimated
at
$
183,188.
Labor
costs
for
responding
to
comments,
revising
the
survey,
and
analyzing
survey
responses
contribute
to
the
majority
of
total
costs.
35
Table
6­
3
Estimated
Agency
Burden
and
Labor
Cost
Activities
Burden
(
hours)
Labor
Cost*

Agenc
y
Contractor
Total
Hours
Agency
($
54.84/
hr)
Contractor
($
74.27/
hr)
Total
Cost
Develop
the
survey
instrument;
Provide
the
draft
survey
instrument
to
industry
trade
associations
for
review;
Meet
with
trade
association
representatives;
Publish
notice
of
anticipated
ICR
in
Federal
Register;
Respond
to
all
comments
received;
Revise
survey
instrument
based
on
reviewers'
comments.
150
1000
1,150
$
8,226
$
74,270
$
82,496
Develop
a
mailing
list
database;
Develop
a
system
to
track
mailing
and
receipt
activities;
Mail
survey
instruments.
10
33
43
$
548
$
2,451
$
2,999
Develop
and
maintain
e­
mail
address
and
website
10
446
456
$
548
$
33,124
$
33,673
Maintain
response
tracking
system;
Implement
appropriate
procedures
for
handling
CBI
responses;
Review
and
code
responses;
Collect
missing
information.
10
395
405
$
548
$
29,337
$
29,885
Enter
and
verify
data
5
192
197
$
274
$
14,260
$
14,534
Engineering
and
economic
followup
to
clarify
responses
to
survey
questionnaire
10
100
110
$
548
$
7,427
$
7,975
TOTAL
195
2,166
2,361
$
10,694
$
160,869
$
171,563
*
Note:
Rounding
errors
involved.

Table
6­
4
Estimated
Agency
Total
Cost
(
Labor
and
O&
M)

Agency
Contractor
Total
Agency
and
Contractor
Cost
Labor
Costs
$
10,694
$
160,869
$
171,563
O&
M
Costs
$
3,625
$
8,000
$
11,625
Total
Labor
and
O&
M
Costs
$
14,319
$
168,869
$
183,188
36
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
Costs
EPA
expects
completed
surveys
from
12
cruise
lines
operating
30
cruise
vessels.
EPA
estimates
a
total
burden
of
1,270
hours
and
a
total
labor
and
O&
M
cost
of
$
51,000
for
all
respondents.
See
Tables
6­
1
and
6­
2.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
The
upper
bound
estimate
with
30
detailed
surveys
and
20
survey
follow­
up
information
requests
to
clarify
survey
responses
is
1,270
hours
and
$
51,000
for
the
respondent
community
and
2,361
hours
and
$
183,000
for
the
Agency.
See
Tables
6­
1
through
6­
4.

6(
f)
Reasons
for
Change
in
Burden
Not
applicable
because
this
request
does
not
renew
or
modify
an
existing
ICR.

6(
g)
Burden
Statement
EPA
estimates
it
would
take
the
respondents
an
average
of
42.3
hours
to
complete
and
review
their
responses
to
the
survey
and
associated
data
submissions.
This
estimate
includes
the
burden
for
verifying
and
updating
"
draft"
responses
provided
by
EPA
to
a
portion
of
the
questions.
EPA
estimates
that
the
total
burden
for
cruise
lines
operating
the
16
vessels
certified
to
discharge
continuously
under
33
CFR
159.309
would
be
approximately
864
hours,
or
$
35,000
based
on
the
U.
S.
Department
of
Labor,
Bureau
of
Labor
Statistics'
National
Compensation
Survey
(
July
2003)
labor
rates
for
the
likely
range
of
personnel
involved
in
responding.
This
is
an
average
of
54
hours
per
response
for
ships
with
advanced
wastewater
treatment
systems.

For
the
remaining
14
ships
that
do
not
have
wastewater
treatment
systems
authorized
to
discharge
continuously,
EPA
estimates
it
would
take
an
average
of
approximately
29
hours
to
complete
and
review
responses
to
the
survey.
EPA
estimates
that
the
total
burden
for
these
14
vessels
would
be
approximately
406
hours,
or
$
15,000
based
on
the
Bureau
of
Labor
Statistics'
National
Compensation
Survey
(
July
2003)
labor
rates
for
the
likely
range
of
personnel
involved
in
responding.
This
is
an
average
of
29
hours
per
response.

EPA
estimates
that
the
total
burden
to
the
12
cruise
lines
operating
30
vessels
for
responding
to
the
survey
would
be
approximately
1,270
hours,
or
$
51,000.
EPA
estimates
that
there
would
be
no
start
up
or
capital
cost
associated
with
the
surveys
described
above.

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
37
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OW­
2003­
0081,
which
is
available
for
public
viewing
at
the
Water
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Water
Docket
is
(
202)
566­
2426.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OW­
2003­
0081
in
any
correspondence.
Appendix
A
SUMMARY
OF
COMMENTS
ON
THE
PUBLIC
NOTICE
FOR
THE
PROPOSED
INFORMATION
COLLECTION
FOR
LARGE
CRUISE
SHIPS
IN
ALASKA
AND
EPA'S
RESPONSE
A­
1
Summary
of
Comments
on
the
Public
Notice
for
the
Proposed
Information
Collection
for
Large
Cruise
Ships
in
Alaska
and
EPA's
Response
Survey
Section
No./
Topic
Comment
Response
1.
General
Cruise
Vessel
Information
a.
Request
passenger/
crew
capacity,
ports
and
other
itinerary,
b.
Request
itinerary
during
AK
offseason
a.
This
information
is
requested
in
the
survey.
b.
The
itinerary
outside
Alaska
is
not
required
for
the
purpose
of
this
survey.
This
information
is
also
largely
available
on
cruise
line
websites.

2.
Wastewater
Sources
Request
whether
graywater
and
sewage
are
mixed
or
separated.
This
information
is
requested
in
the
survey.

3.
WWT
Technology/
System
a.
Request
type
of
WWT
system,
installation
date
and
time
in
use.
b.
Request
whether
graywater
and
sewage
are
treated
separately,
as
a
mixture,
or
if
only
sewage
is
treated.
c.
Request
if
chlorine,
ammonia
or
other
chemicals
are
used.
d.
Request
the
destination
of
treated/
untreated
wastewater
and
how
documented.
e.
Request
capability
and
ports
for
discharge
to
shore
side
facility
a.­
e.
This
information
is
requested
in
the
survey.

3.
WWT
:
Performance
a.
Obtain
information
to
evaluate
performance
of
advanced
WWT
technologies.
b.
Request
frequency
of
WWT
sampling,
parameters
sampled,
and
by
whom
sampled.
c.
Request
the
effectiveness
of
removing
nutrients,
heavy
metals,
and
any
chemicals
contained
in
all
products
used.
a.­
b.
This
information
is
requested
in
the
survey
and
will
also
be
obtained
via
EPA's
sampling
program.
c.
This
information
is
requested
in
the
survey
(
existing
sampling
data)
and
will
also
be
obtained
via
EPA's
sampling
program
to
the
extent
that
such
pollutants
and
chemicals
are
monitored.

3.
WWT:
Waste
Storage,
Sludge
Handling
a.
Request
capability
for
sludge
handling/
disposal
and
wastewater/
waste
storage.
b.
Request
if
sludge
is
hazardous
and
disposal
method.
a.­
b.
This
information
is
requested
in
the
survey.
Summary
of
Comments
and
Responses
to
Public
Notice
(
Continued)

Survey
Section
No./
Topic
Comment
Response
A­
2
3.
WWT:
Costs,
Operation
&
Maintenance
a.
Obtain
retrofit
costs
for
advance
WWT
systems.
b.
Request
types
of
WWT
malfunctions
and
handling
of
wastewater
during
maintenance.
c.
Request
type
and
frequency
of
WWT
maintenance.
d.
Request
staff
members
that
operate
or
oversee
system
and
type,
duration
and
frequency
of
training.
e.
Request
energy/
fuel
requirements
to
operate
WWT
system.
a.­
e.
This
information
is
requested
in
the
survey.

EPA
Policy
a.
Consider
best
management
practices
(
BMP)
instead
of
focusing
on
effluent
treatment,
such
as
discharging
while
underway
and
one
mile
from
land;
reducing
harmful
substances
in
the
waste
stream.
b.
Treatment
should
be
a
priority
over
BMP
a.­
b.
EPA
will
evaluate
both
pollution
prevention
and
management
practices
and
wastewater
treatment
technologies
in
developing
graywater
and
blackwater
discharge
regulations
for
this
industry
Sampling
Program
a.
Use
UNDS
program
sampling
methodologies
and
protocols.
b.
Use
USCG
requirements
for
number
of
samples.
c.
Sample
all
wastewater
treatment
(
WWT)
technology
types
used
by
large
ships.
d.
Use
ADEC
reports
to
assist
in
the
evaluation
of
WWT
systems
to
reduce
burden
a.­
b.
The
Generic
Sampling
and
Analysis
Plan
presents
details
of
the
sampling
program
for
the
Alaskan
cruise
ships.
This
plan
can
be
found
at:
http://
www.
epa.
gov/
owow/
oceans/
cruise_
ships
c.
EPA
consulted
with
cruise
lines
and
considered
UNDS
and
USCG
program
protocols,
and
other
stakeholders
regarding
technologies
and
vessels
to
be
sampled
and
other
details.
d.
EPA
plans
to
review
and
incorporate
into
its
analyses,
ADEC
reports
for
information
regarding
WWT
systems
and
performance.
Appendix
B
SUMMARY
OF
COMMENTS
RECEIVED
IN
CONSULTATIONS
ON
THE
DRAFT
SURVEY
FOR
LARGE
CRUISE
SHIPS
IN
ALASKA
AND
EPA'S
RESPONSE
B­
1
Summary
of
Comments
Received
in
Consultations
on
the
Draft
Survey
for
Large
Cruise
Ships
in
Alaska
and
EPA's
Response
Survey
Section
No./
Topic
Comment
Response
Part
A.
General
Cruise
Line
Information
a.
It
would
be
useful
to
collect
this
information
for
all
vessels
in
a
company's
fleet
to
capture
revised
itineraries.
b.
Consider
moving
the
survey
basis
year
from
2003
to
2004
as
2003
because
technical
and
economic
data
will
be
easier
to
obtain
and
more
up
to
date.
a.
General
Information
for
vessels
that
did
not
operate
in
Alaska
waters
in
2004
is
outside
of
the
scope
of
this
survey.
The
survey
does
request
a
list
of
vessels
that
may
operate
in
waters
in
and
near
Alaska
in
2005
­
2007.
b.
EPA
concurs
with
industry
recommendation
to
move
the
base
year.

1.
General
Cruise
Vessel
Information
a.
What
is
meant
by
"
waters
in
and
near
Alaska"?
b.
Q.
24
duplicates
15
and
should
not
be
asked
twice.
c.
Why
is
the
length,
beam
and
draft
of
the
vessel
needed?
d.
Who
will
account
for
and
sign
off
on
pre­
population
data
regarding
ship
capacity
and
registry?
e.
Add
Hubbard
Glacier
and
move
the
other
national/
state
parks
from
later
question
to
the
port
itinerary
question.
a.
The
term
"
Waters
in
and
near
Alaska"
is
defined
in
the
Introduction
to
the
survey
on
page
xi
as
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.
This
definition
is
identical
to
the
applicability
of
Title
XIV.
b.
Q.
15
request
the
number
of
days
for
year
2004.
Q.
24
requests
the
number
of
days
for
each
voyage
and
the
number
of
passengers
and
crew
for
each
voyage.
c.
This
information
is
needed
for
discharge
dilution
modeling.
Vessel
size
could
also
be
used
as
a
basis
for
developing
differing
control
and
treatment
options
and
associated
discharge
limitations.
Much
of
this
information
is
publicly
available
and
will
be
"
pre­
populated"
for
survey
respondent
to
reduce
burden.
d.
Pre­
population
data
will
be
obtained
from
available
sources,
such
as
ADEC
ship
registries
and
reports,
and
will
be
quality
checked
after
data
entry
into
the
prepopulation
database
and
vessel­
specific
survey.
Survey
respondents
will
be
directed
to
verify
pre­
entered
data
as
part
of
completing
and
certifying
survey
information.
e.
Port
destinations
and
park
or
other
destinations
are
separate
questions
for
ease
of
data
analysis.
Summary
of
Comments
Received
in
Consultations
on
the
Draft
Survey
and
EPA's
Response
(
Continued)

Survey
Section
No./
Topic
Comment
Response
B­
2
2.
Wastewater
Sources:
Flow
Diagram
a.
Include
post
treatment
wastes.
b.
Request
specific
wastewater
sources
(
sinks,
toilets,
etc.).
c.
"
Simple"
diagrams
do
not
exist
and
will
take
more
time
than
estimated
to
include
the
information
requested.
a.
Information
for
treated
wastewater
is
included
in
the
wastewater
treatment
section.
b.
Specific
wastewater
sources
are
included
in
information
for
the
CHT
tanks
and
other
questions.
c.
The
example
WWT
block
diagram
illustrates
a
simplified
schematic
for
the
diagram.
Based
on
EPA's
observations
during
cruise
vessel
site
visits
and
sampling
episodes,
such
diagrams
can
be
readily
prepared
from
existing
ship's
diagrams
and
control
room
screen
captures.
Summary
of
Comments
Received
in
Consultations
on
the
Draft
Survey
and
EPA's
Response
(
Continued)

Survey
Section
No./
Topic
Comment
Response
B­
3
2.
Wastewater
Sources
a.
There
is
a
heavy
focus
on
wastewater
destinations.
Put
more
emphasis
on
wastewater
sources.
b.
Request
additional
parameters
(
fecal
coliform)
in
untreated
graywater
and
sewage.
c.
Request
the
active
ingredient
and
amount
of
pesticides
where
active
ingredient
is
a
constant.
d.
Request
2001
wastewater
volumes
for
direct
discharge
and
transfer
to
shore
side
facilities
for
comparison
and
to
show
changes
driven
by
the
law.
e.
It
is
impossible
to
determine
actual
amount
eaten
or
disposed
to
specific
destinations.
f.
Providing
the
ship
alterations
to
reroute
blackwater
and
graywater
sources
to
a
collection
or
holding
tanks
would
require
days
of
study.
g.
Does
not
make
sense
to
ask
whether
BW
or
GW
systems
use
vacuum
or
sea
water.
a.
Graywater
and
blackwater
sources
applicable
to
the
purpose
of
the
survey
are
included.
An
expanded
list
of
wastewater
sources
has
been
added
to
applicable
questions
in
this
section
in
response
to
this
comment.
b.
Raw
wastewater
sampling
data
for
all
parameters
is
requested
in
Section
5:
Sampling
Data
c.
Active
ingredient
has
been
added
to
the
question.
The
amount
of
pesticides
can
be
obtained
in
survey
follow­
up
if
needed.
d.
Year
2000
(
prior
to
Title
XIV
requirements)
information
is
requested
in
the
survey.
e.
The
survey
requests
"
approximate
amount
of
meals
served
per
day"
not
amount
eaten
or
disposed
per
person.
When
exact
data
are
not
available,
respondents
are
instructed
in
the
survey
introduction
and
each
technical
section
to
provide
best
estimates
and
note
on
the
comment
page
the
method
of
estimation.
f.
Information
collected
during
EPA
ship
visits
and
sampling
episodes
indicates
all
graywater
and
blackwater
sources,
as
defined
by
the
survey,
are
currently
routed
to
collection
or
holding
tanks.
EPA
anticipates
that
this
question
is
applicable
to
few,
if
any,
cruise
vessels.
g.
EPA
clarified
this
question
regarding
the
use
of
vacuum
(
as
opposed
to
gravity)
and
the
use
of
sea
water
(
as
opposed
to
fresh
water).
Summary
of
Comments
Received
in
Consultations
on
the
Draft
Survey
and
EPA's
Response
(
Continued)

Survey
Section
No./
Topic
Comment
Response
B­
4
2.
Wastewater
Sources
(
continued)
h.
Ask
for
the
amount
of
laundry
water
used
instead
of
the
amount
washed.
What
does
this
have
to
do
with
effluent
quality
or
economic
impact?
I.
Stress
that
sampling
is
not
required
for
the
untreated
graywater
and
blackwater
BOD
and
COD
concentrations.
j.
Do
not
use
"
excess"
food
liquids.
k.
It
is
likely
that
numerous
different
cleaning
products
are
added
to
untreated
graywater
or
blackwater.
l.
Distinguish
types
of
"
shop
sinks."
h.
The
amount
of
laundry
washed
will
be
used
as
a
"
normalizing
parameter"
to
allow
comparison
of
laundry
wastewater
flows
for
ships
of
different
sizes/
number
of
passengers
(
e.
g.,
calculation
and
comparison
of
m3
of
laundry
wastewater
per
metric
ton
of
laundry
washed).
I.
"
If
available"
was
added
to
the
question.
j.
The
question
was
reworded
to
request
"
food
pulper"
wastewater
generation.
k.
Only
the
top
ten
chemicals
added
are
now
requested
in
the
survey.
l.
Added
engine
room
and
non­
engine
room
shop
sinks
to
the
question.

3.
WWT:
Technology/
System
a.
Ensure
that
the
question
re:
distance
from
shore
where
the
WWT
system
operates
is
in
the
final
survey.
b.
Holding
tanks:
Request
holding
times
and
effluent
data
c.
Request
same
information
for
bilge
tanks.
d.
To
determine
whether
vessel
speed
during
discharge
depends
on
the
type
of
wastestream,
request
the
vessel
discharge
speed
for
each
waste
stream.
e.
Unrealistic
to
determine
the
surface
area
of
the
unit.
f.
Use
a
better
term
than
"
tank"
for
pH
adjustment.
a.
This
information
is
included.
b.
Holding
time
can
be
estimated
using
the
information
requested.
Sampling
data
are
requested
in
Section
5.
c.
Bilge
water
is
outside
the
scope
of
this
survey.
d.
Vessel
speed
during
discharge
will
be
provided
in
the
requested
Discharge
Record
Book.
These
records
can
be
used
to
provide
information
to
analyze
vessel
speed
versus
type
of
wastestream.
e.
EPA
clarified
this
question
to
request
the
wastewater
treatment
unit
"
footprint"
or
surface
area
on
the
deck.
This
information
is
necessary
to
understand
the
space
requirements
for
wastewater
treatment
equipment.
f.
Term
was
revised
to
pH
adjustment
"
unit."
Summary
of
Comments
Received
in
Consultations
on
the
Draft
Survey
and
EPA's
Response
(
Continued)

Survey
Section
No./
Topic
Comment
Response
B­
5
3.
WWT:
Incineration
a.
Analysis
of
the
incineration
waste
stream
composition
and
stack
gas
emissions
would
be
useful.
b.
Request
strategies
to
keep
mercury
out
of
the
incineration
waste
stream
and
how
mercury
is
managed,
tracked
and
documented.
c.
Request
other
chemical
wastes
in
the
incineration
waste
stream.
a.
Ash
samples
will
be
collected
during
EPA's
sampling
program;
stack
gas
emissions
samples
will
not
be
collected.
Sampling
data
for
wastewater
treatment
residuals
are
requested
in
Section
5.
Information
regarding
the
type
of
incinerator
air
scrubbers
and
the
destination
of
any
wastewater/
slurry
is
included.
Sampling
data
for
stack
gas
emissions
are
not
requested
because
this
wastestream
is
outside
the
scope
of
this
survey.
b.
This
information
is
outside
the
scope
for
the
purpose
of
this
survey.
c.
This
information
is
outside
the
scope
of
this
survey.
(
Note:
This
wastestream
is
mostly
trash.)

3.
WWT:
Waste
Storage,
Sludge
Handling
Request
data
for
treated
sewage
including
flow
rates,
sludge,
etc.
Sampling
data
are
requested
in
Section
5.
Information
on
flow
rates
and
sludge
are
included
in
the
tables
for
WWT
unit
operations.

3.
WWT:
Operation
and
Maintenance
Ask
about
filtration
system
clogging
and
how
they
are
handled.
WWT
operation
and
maintenance
is
requested
in
the
survey.

4.
WWT
Costs
a.
Everyone
will
respond
that
no
space
is
available
for
additional
WWT
units.
b.
The
capacity
of
power
generators
varies
depending
on
ship
speed
and
whether
at
dock.
Reword
question
to
determine
if
generator
could
support
additional
WWT
units.
a.
Yes/
No
response
was
deleted
and
question
was
reworded.
b.
Question
was
revised
to
ask
if
additional
generator
capacity
would
be
required
for
additional
WWT
units.

5.
Sampling
Data
Require
sampling
and
analysis
if
sampling
data
are
not
available.
Additional
sampling
data
for
selected
cruise
vessels
will
be
collected
during
EPA's
sampling
program.
EPA
believes
these
data,
in
combination
with
sampling
data
submitted
in
response
to
the
survey
as
well
as
from
other
sources,
will
be
sufficient
in
developing
discharge
limitations.

6.
Pollution
Prevention
Requests
costs
or
costs
savings
associated
with
pollution
prevention.
This
information
is
requested
in
the
survey.
Summary
of
Comments
Received
in
Consultations
on
the
Draft
Survey
and
EPA's
Response
(
Continued)

Survey
Section
No./
Topic
Comment
Response
B­
6
Part
C:
Financial
and
Economic
Information
a.
Q.
8:
Fees
paid
by
the
vendor
to
the
cruise
lines
should
be
subtracted
from
the
cost.
Use
"
net
revenue
from
onshore
operations"
instead
of
"
value
transferred"
b.
Request
costs
for
installation
of
advanced
WWT
systems.
c.
It
would
take
[
a
total
of]
200
hours
of
research
and
collection
by
high
level
personnel
(
e.
g.,
MBA's,
CPA's)
to
complete
this
section
[
for
six
cruise
ships
operating
in
Alaska].
Some
financial
information
is
not
recoverable
in
the
categories
requested
(
e.
g.,
byship
basis)
and
would
be
difficult
to
extract
without
reviewing
thousands
of
invoices.
a.
"
Net
revenue
from
onshore
operations"
replaced
value
transferred
in
response
to
this
comment.
b.
This
information
is
requested
in
survey
Section
4:
WWT
Costs.
c.
EPA's
estimates
of
response
burden
have
been
adjusted
in
response
to
these
comments.

CBI
Claims
a.
Do
not
provide
the
option
to
claim
CBI
for
questions
or
comments.
b.
Delete
the
questions
and/
or
delete
the
CBI
check
boxes
a.
EPA
is
required
to
allow
survey
respondents
to
make
CBI
claims
for
all
information,
except
effluent
data
or
publicly
available
information.
EPA
requires
the
requested
data
to
conduct
the
analysis
for
EPA
to
develop
discharge
regulations.
b.
The
CBI
check
boxes
for
the
comments
at
the
end
of
survey
sections
are
needed
to
document
any
CBI
claims
for
the
comment
independent
of
response
to
the
corresponding
survey
question.
Summary
of
Comments
Received
in
Consultations
on
the
Draft
Survey
and
EPA's
Response
(
Continued)

Survey
Section
No./
Topic
Comment
Response
B­
7
Monitoring
Requirements
a.
Cruise
ship
operators
should
have
a
totals
page
of
water/
air
discharge
data
per
ship
and
total
number
of
ships
for
in­
house
tracking,
control,
and
monitoring
total
volume
on
a
yearly
basis.
b.
Sailing
maps
and
location
of
discharge
should
be
a
required
for
total
individual
and
total
cruise
ship
saturation/
discharge
monitoring.
a.
Part
B,
Section
2
requests
the
total
volume
of
untreated
graywater
and
blackwater
discharged
in
waters
in
and
near
Alaska
in
2004.
Part
B,
Section
3
requests
discharge
flow
rates
from
any
graywater
and/
or
blackwater
treatment
systems
for
treated
wastewater,
sludge,
and
other
residuals.
Part
B,
Section
3
requests
copies
of
each
vessel's
Sewage
and
Graywater
Discharge
Record
Book
for
2004
including
discharges
of
sewage
and
graywater
treatment
system
sludges,
which
records
all
releases
of
treated
and
untreated
sewage,
graywater,
and
sewage/
graywater
mixture
to
waters
in
and
near
Alaska.
b.
Part
B,
Section
3
requests
copies
of
each
vessel's
Sewage
and
Graywater
Discharge
Record
Book
for
2004.
These
records
include
the
vessel's
latitude
and
longitude
at
the
time
the
discharge
port
is
opened
and
at
the
time
the
discharge
port
is
secured.

Introduction
a.
Add
the
"
need
to
protect
land
and
water
habitat,
and
food
resources
of
Alaska"
as
part
of
the
need
and
requirements
of
the
survey.
Also
cite
State
laws
in
addition
to
Federal
Clean
Water
Act.
b.
Move
discussion
of
"
best
estimate"
forward
and
highlight.
a.
The
purpose
of
this
survey
is
to
collect
information
for
use
in
developing
blackwater
and
graywater
discharge
regulations
for
large
cruise
vessels
that
operate
in
Alaskan
waters.
Such
regulations
are
authorized
by
"
Title
XIVCertain
Alaskan
Cruise
Ship
Operations"
of
the
Miscellaneous
Appropriations
Bill
(
H.
R.
5666)
passed
by
Congress
on
December
21,
2000
in
the
Consolidated
Appropriations
Act
of
2001
(
Pub.
L
106­
554)
(
Sections
1401­
1414).
b.
The
"
best
estimate"
discussion
is
in
bold
in
the
Introduction
and
was
added
to
the
introduction
of
each
technical
section.

Certification
If
certified
for
AK
ships,
why
needed
for
ships
that
are
not
operating
in
AK.
The
survey
should
be
completed
for
only
those
ships
that
operated
in
waters
in
and
near
Alaska
in
2004.
EPA
will
require
the
survey
to
be
completed
for
each
applicable
ship.
There
are
two
possible
certification
statements.
Statement
1
is
for
a
cruise
line
that
has
completed
the
survey
for
one
of
its
vessels.
Statement
2
is
for
a
cruise
line
that
may
have
erroneously
received
a
survey
for
one
of
its
vessels
which
did
not
in
fact
operate
in
Alaskan
waters
in
2004.
Summary
of
Comments
Received
in
Consultations
on
the
Draft
Survey
and
EPA's
Response
(
Continued)

Survey
Section
No./
Topic
Comment
Response
B­
8
Burden
for
Technical
Section
a.
For
2004,
RCCL
has
6
ships
with
6
different
WWT
systems.
It
would
take
20
hrs/
ship
to
complete
the
WWT
system
and
other
technical
information.
b.
EPA
did
not
include
expense
to
copy
blue
prints
or
sending
large
amounts
of
data
over
dedicated
satellite
communications
systems.
c.
Ships
are
underway
from
different
ports
every
day
making
data
collection
difficult.
a.
The
survey
technical
information
should
be
completed
for
only
those
ships
that
operated
in
waters
in
and
near
Alaska
in
2004.
ADEC
indicates
there
were
3
Royal
Caribbean
ships
in
the
2004
AK
season,
not
6.
Part
B
of
the
survey
is
vessel­
specific.
EPA
estimates
the
burden
per
response
to
be
approximately
36
hours
for
vessels
certified
for
continuous
discharge
for
the
technical
section.
To
reduce
respondent
burden,
EPA
plans
to
pre­
populate
vesselspecific
surveys
with
available
information
from
ADEC,
U.
S.
Coast
Guard,
and
cruise
line
websites.
b.
The
example
WWT
block
diagram
illustrates
a
simplified
schematic
that
could
provide
the
requested
information.
It
is
not
necessary
to
copy
blue
prints.
EPA
believes
respondents
costs
for
copying,
phone
charges,
etc.
would
be
minimal
and
that
labor
costs
comprise
the
majority
of
the
financial
burden
.
c.
EPA
understands
the
increased
logistics
requirements
for
ships
as
compared
to
landbased
facilities
and
has
revised
its
burden
estimates
accordingly.

Burden
for
Technical
Section
(
continued)
d.
60
days
to
complete
and
review
the
survey
is
not
sufficient
especially
for
those
companies
that
have
dozens
of
ships.
Financial
information
does
not
reside
with
any
one
person
and
that
a
meeting
with
and
at
individual
companies
with
a
number
of
persons
may
be
necessary
­
this
may
necessitate
EPA
personnel
travel
to
the
home
offices
of
the
various
companies.
e.
Reduce
the
scope
of
the
survey
and
supplement
with
the
detailed
information
obtained
from
ship
visits
and
sampling
episodes.
d.
EPA
believes
that
60
days
will
be
sufficient
to
complete
responses
to
the
survey
questionnaire.
EPA
will
consider
requests
for
additional
time
to
respond
on
a
case­
by­
case
basis
after
efforts
have
been
made
to
respond.
Also,
EPA's
estimates
of
response
burden
have
been
adjusted
in
response
to
this
and
other
comments.
Note:
Of
the
12
cruise
lines
that
will
receive
the
survey,
the
number
of
applicable
ships
per
cruise
line
ranges
from
1
to
7.
e.
The
detailed
information
obtained
from
ship
visits
and
sampling
episodes
may
not
represent
all
the
cruise
vessels
that
may
be
covered
by
the
discharge
limitations.
Vessel
size,
number
of
passengers,
WWT
systems,
etc.
vary
among
cruise
lines
and
vessels
and
that
ship­
specific
information
is
required
for
EPA's
analyses
and
development
of
discharge
limitations.
