U.S.
EPA
VESSEL GENERAL PERMIT
U.S. EPA
VESSEL GENERAL PERMIT
• Went into effect February 19, 2009, on‐line availibility
after June19th
• NOI due within 9 months later (Sep 19, 2009)
• Discharge management plan
– Deck runoff
– Ballast water
– AFFF
– Boiler Blowdown
– Chain locker effluent
– Greywater
– Rudder Bearing lubrication
– Seawater cooling
• Expanded Self‐Reporting
• Comprehensive Inspections, Logs
• Annual Declaration of Violations
U.S. EPA
VESSEL GENERAL PERMIT
• Deck Run‐off • Boiler/Exhaust Gas
• Bilge Water/OWS economizer Blow Down
effluent • Cathodic Protection
• Ballast Water • Chain Locker effluent
• Anti‐fouling • Controllable Pitch
Leachetefrom Anti‐ propeller Hydrolic fluid
fouling Hull coating – Stern Tube Oil
• Aquaous Film Forming Discharge
Foam (AFFF)
U.S. EPA
VESSEL GENERAL PERMIT
• Freshwater generator • Well deck discharge
distillation • Grey water mixed with
• Hull Cleaning sewage
• Grey Water • Exhaust gas scrubber
• Fire Main System wash water discharge
• Non‐oily Machinery • Inert gas Scrubber
Waste Water
• Small Boat Engine wet
exhaust
U.S. EPA
VESSEL GENERAL PERMIT
DECK RUN-OFF
•Ensure decks are clean, clear of
debris: garbage & chemicals.
•Use non-toxic chemical
cleaner.
•Utilize scupper plugs
U.S. EPA
VESSEL GENERAL PERMIT
Ballast Water
•Ensure the vessel has an updated Ballast Water Management Plan
(BWMP).
•Ensure additional State Regulations (California, Oregon, Washington)
are complied with.
•How do you document your sediment removal?
9Tank inspection Report – Dry dock, etc…
•What is ballast water training?
9Sampling procedures - exchange methods - safety factors –
regulations – reporting procedures – completing handling logs,
etc…
U.S. EPA
VESSEL GENERAL PERMIT
Aqueous Film Forming Foam (AFFF)
No Maintenance or
training with actual foam
in port limits, except in
the case of an
emergency.
U.S. EPA
VESSEL GENERAL PERMIT
Boiler Economizer Blow Down
• Vessels greater than 400 GT which leave the US territorial sea at
least once per week, boiler/economizer blow down may not be
discharged in waters listed in the VGP except for safety
purposes.
• For all vessels, Boiler/Economizer blow down may not be
discharged in or within 1 nm of waters federally protected
wholly or in part for conservation purposes except for safety
purposes.
U.S. EPA
VESSEL GENERAL PERMIT
Cathodic Protection
• Impressed Current Cathodic Protection if the
EPA’s Prefered method of protecting the hull.
• Inspect & replace anodes
in dry dock.
U.S. EPA
VESSEL GENERAL PERMIT
Chain Locker Effluent
• Clean anchor(s) during retrieval.
• Clean out, pump out, or rinse
chain lockers at least 50nm
offshore.
• Clean & inspect during drydock
U.S. EPA
VESSEL GENERAL PERMIT
Controllable Pitch Propeller Hydraulic Fluid, Stern Tube
Oily Discharge, and Rudder Bearing Lubrication
Discharge
• Monitor for leaks, oil sheen, & change in
tank ullage.
• Inspect during
drydock
U.S. EPA
VESSEL GENERAL PERMIT
Small Boat Wet Exhaust
• Lifeboat and rescue boats to be maintained.
• Consider buying four stroke engines
• Retain oil residue from barrels.
U.S. EPA
VESSEL GENERAL PERMIT
Underwater Ship Husbandry (Hull Cleaning)
• Hull repairs that require raw materials or other potentially toxic
chemicals should be conducted while the vessel is drydocked.
• It is recommended that extensive hull cleaning be conducted
when the vessel is in dry‐dock or when the byproducts of the
cleaning can be contained and disposed of properly, especially
when cleaning hulls using water pressure based systems.
• Use of non‐toxic anti‐foulant paints such as silicon based paints
will reduce the discharge of toxic materials into
the water column during any cleaning.
U.S. EPA
VESSEL GENERAL PERMIT
Seawater Cooling Overboard Discharge
• Clean sea strainers and remove fouling organisms
from seawater piping and cooling systems while at
sea and greater than 50nm from shore.
U.S. EPA
VESSEL GENERAL PERMIT
Graywater
• Utilize holding tank if equipped.
• Discharge graywater greater than
1nm from shore while underway.
• Make the attempt to reduce the amount of graywater
generated onboard (galley drain, showers, laundry,
etc…).
• Utilize non‐toxic and phosphate free soaps and
detergents.
U.S. EPA
VESSEL GENERAL PERMIT
• Applicable in US waters
• NOI to be filed no later than Sept. 19th 2009 for all
TORM Vessels
• Newbuilding/Purchase of vessels: 30 days grace
period
• Vessels will be required to submit a Notice of Intent
(NOI) to discharge any of the twenty‐six identified
effluents.
• Enforcement ???? USCG vs EPA
• Self Reporting a MUST
U.S. EPA
VESSEL GENERAL PERMIT
• Inspections
‐ Routine Inspections (not less often than weekly)
‐ Quarterly for non‐visible waste Streams
‐ Annual Inspections and Dry Docking
• Records
‐ PMS: records of inspections
‐ Records of violations
• Reports
‐ Violation reports are a must and have to be recorded onboard
• Training & Discipline
‐ Train onboard crew
‐ Demonstrate proficiency
‐ Reprimand of violations