USA - EPA’s

N P D E S – VGP 2013

Implementation Deadline
19th December 2013
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 EPA – NPDES - VGP
Environmental Protection Agency
National Pollutant Discharge Elimination
System
Vessel General Permit
- Enacted under the Federal Clean Water Act of
1972 (amendment of 1999)
- Implementation deadline for VGP 2013

19th December 2013

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 NPDES – VGP - Applicability
What Vessels are covered?

 Vessel General Permit (“VGP”) applies to ALL Vessels

managed by Anglo Eastern that have discharges
incidental to their normal operations in the waters of the
United States.

 All waters of Great Lakes are covered which are under

US territory

 Flag of the Vessel or duration of stay in US waters does

not matter

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 NPDES – VGP - Terms

What is a Pollutant?
- All discharges from a vessel into the water from normal
operations, other than which are already regulated.

What is Discharge of a Pollutant?

- Addition of the Pollutant to the Navigable waters of the
United States (Some states have additional definition)

What is Navigable Waters?

Extending to the outer reach of the 3 mile territorial sea
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 NPDES – VGP - Enforcement
Multiple levels of enforcement
 EPA is the custodian for these regulations, and will be the
central Enforcement Agency who decide on penalty.
 USCG is authorized to check, review records & check
requirement compliance for NPDES – VGP along with their
PSC items.
 State Environmental Agency have dedicated inspectors for
checking of EPA & additional State requirements and they
regularly visit vessels in some States such as California,
New York & other Great lake States.

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 NPDES – VGP - Applicability

Applicable to all our vessels

visiting US ports on or after
19th December 2013.

Need to start self – inspection of vessel,

monitoring, training, record keeping,
corrective action and reporting prior
to above date on discharges from the vessel.

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 NPDES - VGP Requirements
 Identify the applicable discharges (out of 27+2)
 Inspections (Daily/Weekly/Annually . . . .)
 Monitoring - continuous
 Requires ship to follow Best Management
Practices (BMPs) for each discharge.
 Reporting – Deviations & Periodic
 Detailed Recordkeeping requirements
 Training – Dual level requirements
 Onerous Civil & Criminal penalties for non-
compliance
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 NPDES - VGP Deviation

What if Compliance problems are found?

 The VGP requires “Corrective Action”

 VGP contains severity based Triggers for Corrective

Action

 Time based Deadlines for taking Corrective Action

(24 hour reporting, 5 day follow-up reporting)

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 NPDES - VGP - BMPs
What does “Best Practices Management” really mean?
 Does it mean – proper maintenance?
 Does it mean – in good operating condition?
 Can I do what I have always done?
 Can I do that when it is convenient?

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 NPDES - VGP - BMPs
“Practices that a reasonable person in the
marine industry would expect to see for a
well-maintained vessel.”
BMPs
Can’t be assumed
Must be investigated
Should be supported
Constantly changing
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 NPDES - VGP - BMPs
Under the VGP the term “minimize” means
reduce and/or eliminate to the extent
achievable using control measures (including
best management practices) that are
technologically available and economically
practicable and achievable in light of the
best marine practice.

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 NPDES – VGP - 27 Discharges 1/3
1 Deck Runoff & above waterline hull cleaning
2 Bilge Water / Oily Water Separator Effluent
3 Ballast Water
4 Anti-fouling Leachate from Anti-Fouling Hull Coatings/Hull Coating
Leachate,
5 Aqueous Film Forming Foam (AFFF)
6 Boiler/Economizer Blow down
7 Cathodic Protection
8 Chain Locker Effluent
9 CP Propeller, Thruster, Stern Tube, Thruster bearings, Stabilizers,
Rudder Bearings, Azimuth Thrusters & Pod Propulsion where
Hydraulic Fluid and other oil – sea interfaces; wire rope &
mechanical equipment subject to immersion.
10 Distillation and Reverse Osmosis Brine
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NPDES – VGP - 27 Discharges 2/3
11 Elevator Pit Effluent
12 Fire main Systems
13 Freshwater Layup
14 Gas Turbine Wash Water
15 Graywater (except in Great Lakes)
16 Motor Gasoline and Compensating Discharge
17 Non-Oily Machinery Wastewater
18 Refrigeration and Air Condensate Discharge
19 Seawater Cooling Overboard Discharge (Including Non-Contact
Engine Cooling Water; Hydraulic System Cooling Water,
Refrigeration Cooling Water)

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 NPDES – VGP - 27 Discharges 3/3
20 Seawater Piping Biofouling Prevention
21 Boat Engine Wet Exhaust
22 Sonar Dome Discharge
23 Underwater Ship Husbandry
24 Welldeck Discharges
25 Graywater Mixed with Sewage from Vessels
26 Exhaust Gas Scrubber Washwater Discharge
27 Fish Hold Effluent

And additional “Water Quality based” effluent limits

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NPDES – VGP - Tanker Discharges

1 Deck Seal Water Discharge: When such seals

are installed as an integral part of an IG
system – Tankers only

2 Inert Gas System Scrubber Water Discharge -

Tankers only

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 1. Deck Wash down and Runoff and
above water line hull cleaning
 EPA encourages use of EALs in all deck equipments
 Clear the vessels’ decks prior to conducting deck wash downs
 Machinery on deck must have coamings with plugs
 Discharges must be free from floating solids, foam, halogenated
phenol compounds, and dispersants
 Restrict/minimize deck wash downs while in US ports or US
Navigable Waters (up to 3 NM)
 Minimize the discharge of materials associated with exterior
topside surface preservation & topsides to be well maintained to
reduce the rust, etc..
 No/minimal over side painting
 If required, Discharge must be conducted with bio-degradable
cleaners (“Phosphate free” and “minimally toxic”)
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 2. Bilge Water
 Must be in compliance with MARPOL / CFRs

 Use of OWS / discharge of bilge water should

NOT be done in waters covered under the permit
(within 3 NM from US BASE LINE) as stated in
AESM record book to avoid additional analysis,
monitoring and reporting to EPA.

 As per EMS manual (for all AESM ships), vessels

should not use OWS within 12 nm from shore.

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 3. Discharges of Ballast Water
 Comply with the USCG regulations
 Discharges may not contain oil, noxious liquid substances or
hazardous substances
 Training of the master, operator, person-in-charge, and crew
 Maintain a ballast water management plan
 Mandatory Ballast Water Management Practices
 Mandatory BMPs for ‘Lakers’
 Ballast water exchange, early in the voyage if possible (>200nm)
 Vessels engaged in Pacific near shore voyages
 Saltwater flushing for NOBOB vessels
 Vessels may not discharge un-exchanged or untreated ballast
water or sediments
 Vessels using BW treatment system to comply with additional
record keeping and monitoring requirements.

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 4. Anti-Fouling Hull Coatings
 Coatings to be FIFRA {Federal Insecticide, Fungicide, and
Rodenticide Act} registered
 Non-FIFRA coatings must not contain any biocides or
toxic materials banned in the US
 Coatings should contain lowest effective biocide release
rates, rapidly biodegradable components, or non-biocidal
alternatives
 Discharge of TBT is prohibited
 When vessels spend considerable time (30 days/year, or
uses these waters as home port) in certain US navigable
waters (copper impaired) & if are using copper-based anti-
foulant paints, then the reason for using this type of paint
needs to be documented.
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 5. Aqueous Film Forming Foam
Discharges are only authorized for
emergency/rescue purposes
Discharges are not authorized for vessels
sailing out at least once a month for routine
maintenance or training purposes

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 6. Boiler/Economizer Blowdown
Minimize the discharge in US ports or US
Navigable Waters (up to 3 NM), if chemicals
or other additives are used

Vessels which leave the territorial sea at least

once per week, must not blow down in waters
covered under the permit.

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 7. Cathodic Protection
Minimize the flaking of large, corroded
portions of anodes
Sacrificial electrodes must use less toxic
metals
Magnesium & Aluminum to be used instead
of Zinc
Use of Impressed Current Cathodic
Protection system (ICCP) is recommended

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 8. Chain Locker Effluent
 Anchor chain must be thoroughly washed down by
hosing down whilst heaving up anchor.
 Chain lockers must be cleaned thoroughly during dry
docking
 If feasible, periodically clean, rinse and/or pump out
the space beneath the chain locker prior to entering
US WATERS (under VGP)
 Chain lockers not to be rinsed/ pumped in US waters,
if vessel leaves US waters once a month

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9. CP Propeller, Thruster, Stern Tube, Thruster
bearings, etc., where Hydraulic Fluid and other
oil – sea interfaces; wire rope & mechanical
equipment subject to immersion.
 Vessels must use an EAL (environmentally acceptable lubricant) in
all oil-to-sea interfaces, unless technically infeasible
 EAL – biodegradable, minimally-toxic, non bio-accumulative
lubricants
 Protective seals must be maintained in good operating order
 Maintenance activities should be conducted in dry-dock
 Operators must have appropriate spill-prevention equipment
(SOPEP) with up to date reporting information (addresses)
 Wire ropes and other mechanical equipments must be thoroughly
wiped down to remove excess lubricant

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10. Distillation and Reverse Osmosis Brine

Brine shall not contain or come in contact

with machinery, toxic or hazardous materials,
or wastes
Preferably not to be used in US ports or US
Waters covered under the permit
If cleaned, the brine and other debris not to
discharged in waters covered under the
permit

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 11. Elevator Pit Effluent
EPE means the liquid that accumulates in
and is discharged from the sumps of elevator
wells on off-shore vessels / rigs. (not
applicable for any AESM vessel).
Discharge of effluent from the pit is not
authorized

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 12. Fire-Main Systems
Discharges are authorized for emergency,
testing & inspection purposes.
May be discharged in port for certification,
maintenance & training purposes provided
direct intake from surrounding water with out
additions.
Minimize the discharge while in US ports or
US Navigable Waters (up to 3 NM)
Prohibited to use in Federally protected
waters (12.1)
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 13. Freshwater Layup
FWLU means the potable water or fresh water
which is filled up in seawater pipe lines when
vessel is laid up and having anti-corrosive
chemicals, disinfection or biocidal agents.
Minimize the amount of chemicals used in
freshwater layup
Not applicable if vessel is not laid up in US
waters

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 14. Gas Turbine Wash Water
GTWW means the water released from washing
gas turbine components

Must not be discharged in US ports or US

Navigable Waters (up to 3 NM)

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 15. Graywater

Minimize the discharge while in Port

No discharge in Federally-protected areas &
nutrient impaired waters if storage available
Discharge greater than 1 nm from shore while
the vessel is underway, if storage available
Kitchen oils must be minimized
Must use phosphate free and non-toxic soaps
Additional monitoring & record keeping required
for vessels built after 19 December 2013
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16. Motor Gasoline and Compensating
Discharge

MG&CD means the sea water taken into and

discharged from, motor gasoline tanks to
eliminate free space where vapors could
accumulate.
Discharge must have oil concentrations of
less than 15 ppm (to be avoided in US waters)

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 17. Non-Oily Machinery Wastewater

Discharge must be free from oils and any

toxic additives
Check this discharge does not have any
debris, traces of oil or garbage carried along
with it. (A/C room drain, Battery room drain,
Accommodation condensate drain)
Record the discharge
Non-oily machinery waste water may also be
drained to the bilge

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 18. Refrigeration and Air Condensate
Discharge

Discharge should not come into contact with

oily or toxic materials
Check this discharge does not have any oil
content
Make entry in NPDES Record book every
watch.

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 19. Seawater Cooling Overboard
Discharge
When possible, to discharge only while
underway to reduce thermal impact to the
receiving waters

To reduce quantity EPA recommends use of

shore power provided
Readily available
Shore system capable of providing full power
Vessel equipped to connect
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 20. Seawater Piping Biofouling
Prevention
SWPBP means the discharge of seawater containing
additives used to prevent the growth and
attachment of biofouling organisms in dedicated sea
water cooling systems
The vessel to use:
Minimum amount of biofouling chemicals (FIFRA reg)
As little chlorine as possible
Remove fouling organisms on a regular basis
Removed organisms shall not be discharged unless
>50nm
Remove any organisms while at sea
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 21. Boat Engine Wet Exhaust
BEWE means the seawater that is mixed and
discharged with small boat propulsion engine
exhaust to cool the exhaust and quiet the engine.

Maintain L/B Engine in good operating order and

check cooling water discharged in US ports or US
Waters (under VGP), does not have any oil sheen.
4 stroke engines recommended against 2 stroke
engines
2 stroke engines must use EALs, else to be
documented in Record Book.

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 22. Sonar Dome Discharge
Sonar Dome Discharge means the leaching of antifouling materials
into the surrounding water and release of seawater or freshwater
retained within the sonar dome.
Water inside the dome shall not be discharged
Biofouling chemicals that are bio-accumulative shall
not be used for the exterior of Sonar domes

Remark: Not applicable for AESM vessels.

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 23. Underwater Ship Husbandry
Discharges
UWSHD: means the materials discharged during the inspection,
maintenance, cleaning and repair of hulls or hull appendages
performed while the vessel is waterborne.

Hull-cleaning activities should take place in dry-dock

Minimize the discharge of fouling organisms and antifouling hull
coatings
Must not result in any visible cloud or plume of paint in the water
specially with copper based paints.
When carrying our under water hull cleaning use soft brushes
and explore vacuum technologies to such in waste.
No hull cleaning up to 365 days after paint application for copper
based A/F paints, else to be documented in the Record book

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 24. Welldeck Discharges
Welldeck Discharges: It means the water that
accumulates from seawater flooding of the docking
well (welldeck) of a vessel used to transport, load
and unload amphibious vessels and from
maintenance and fresh water washings of the
welldeck and equipment and vessels stored in the
welldeck of small vessels

No discharge, except oil-free and garbage-

free
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 25. Graywater Mixed with Sewage
from Vessels

Must comply with the effluent limits for

graywater discharge under VGP.
Must meet standards set forth by CWA for
discharge

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26. Exhaust Gas Scrubber Washwater
Discharge
 Discharge must not contain oil
 Sludge generated must not be discharged
 Must have pH above 6.0 at discharge, except during
maneuvering (max difference of 2.0 pH between I/L &
O/L of water)
 Sampling & analyzing and annual calibration of
equipment to be carried out as stated in VGP 2013
 Records of above to be retained for 3 years.
Remark: Above monitoring is not required for tankers IG
system scrubbers except monitoring of oil sheen.
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 27. Fish Hold Effluent

Prevent the discharge of excess fish hold

water & ice while in port
Large solid pieces of fish are present, then
effluent discharge is prohibited

Remark: Not applicable for AESM vessels.

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 NPDES - VGP – Tanker Requirements

 IGS Scrubber & Deck Seal Discharge

 Visual Sheen Test after every operation
 Discharge of water from Deck Seals authorized when
such seals are installed as integral part of an IGS
system
 All scuppers to be plugged
 Reprimand Procedure must be developed for crew
actions that lead to violations of any effluent limit set
forth in this permit or procedure set forth in the SMS
to minimize the discharge of pollutants

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 NPDES – VGP – Limitation of Coverage
Non – covered Discharges 1/3
1.This permit does not apply to any vessel when it
is operating in a capacity other than as a
means of transportation.
2.Sewage discharges from vessels do not require
a NPDES permit as they are covered under
 Section 312 of the Federal clean Water Act
 40 CFR 140
 33 CFR 159
Individual states may prohibit sewage discharge (NDZ)

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NPDES – VGP – Limitation of Coverage
Non – covered Discharges 2/3
3. Used or spent oil no longer being used for
their intended purposes.

4. Garbage is not eligible for coverage under

the NPDES permit. It is instead covered
under
 33 CFR 151.66 (b) for Cargo and agricultural
cargo residues
 33 CFR 151 Part A

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NPDES – VGP – Limitation of Coverage
Non – covered Discharges 3/3
5. Photo processing effluent
6. Effluent from Dry Cleaning operations
7. Discharge of Medical waste
8. Discharge of Noxious Liquid Substances
covered under 33 CFR 151 Part A are not
eligible for coverage under this permit.
9. Tetrachloroethylene – TCE degreasers

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 NPDES – VGP – State Requirements

Nothing in this Permit shall be construed to

preclude the institution of any legal action or
relieve the Permittee from any responsibilities,
liabilities, or penalties established pursuant to
any state law or regulation.
The State requirements are extensive & onerous!

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NPDES – VGP – Corrective Action 1/4

Problem Triggering the need for corrective Action

 Violate one or more effluent limits
 Effluent limit exceeded as observed by EPA during
inspection or evaluation
 Become aware or EPA determines that measures do
not control discharges stringently as needed
 Become aware or EPA determines that BMPs are not
properly effected or maintained or not having the
intended effect

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 NPDES – VGP – Corrective Action 2/4

Corrective Action Assessment

Into the nature, cause, potential action for eliminating
the problem
 Description of the problem including date, time,
location, type of impact, & name/title/signature of the
person who discovered the problem
 Explanation of cause of the problem
 Description of corrective Action plan with timeline
 Implementation details of the Corrective Action and
name/title/signature of the person recording.
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 NPDES – VGP – Corrective Action 3/4

Deadline of Eliminating Problem

If local control measures can resolve the
problem then immediately but not longer than
2 Weeks.
If new equipment/spares required then within
3 months
If major work which can only be done in dry-
dock, then before re-launching after dry-
docking.
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 NPDES – VGP – Corrective Action 4/4

Effect of corrective Action – Verification

 As the above are VGP violations, EPA will
assess the proactive behavior in deciding
enforcement responses to permit violations.
 EPA may ask for additional info & issue more
stringent requirements than specified in the
permit

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NPDES VGP - Training Requirements 1/2

Training in Shipboard Environmental

Procedures (SEP) & demonstrate proficiency

 Additional Training for key personnel involved in

managing SEP discharge quantities &
demonstrate proficiency
 Develop & implement reprimand procedures for
SEP violations

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NPDES VGP - Training Requirements 2/2

Section 2.1.3 Fueling of Lifeboats & rescue Boats

Section 2.2.3.1 Ballast & Sediment Management

Section 5.5.4 Tankers – additioonal education & training

Requirement more than other ships.

All the above training to be documented on ALL

types of ships in record book section 10 prior
every arrival US 1st port.

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Recordkeeping in NPDES Record book
 Inspections, Monitoring, Recordkeeping & Reporting:
 Routine Daily & Weekly self inspections
 Analysis & monitoring (Graywater, Ballast water,
Exhaust gas scrubber)
 More comprehensive Annual inspections
 Annual reports need to be submitted by vessel for
each year latest by 15TH January of the following
year to group email ID for further processing. (First
report to send for calendar year 2014, including
relevant information from 19 December 2013 onwards)
 Dry-dock inspections
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NPDES – VGP – Penalties - Declaration
Why it matters!
I certify under penalty of law that this document and all
attachments were prepared under my direction or supervision
inaccordance with a system designed to assure that
qualified personnel properly gathered and evaluated the
information contained therein. Based on my inquiry of the
person or persons who manage the system, or those persons
directly responsible for gathering the information, the
information contained is, to the best of my knowledge and
belief, true, accurate, and complete. I have no personal
knowledge that the information submitted is other than
true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including
the possibility of fine and imprisonment for knowing violations.

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 NPDES – VGP - Penalties
Why it matters!

Noncompliance must be reported to the EPA

and if intentional, could be punished as a
crime.
Failure to disclose noncompliance could be a
crime.
Reporting incorrect (false) information could
be a crime
Contains widely different conditions imposed
by states, and that only apply in the waters of
that particular states.

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 Please record this
Training in the NPDES
Record Book!

Thank you!!!
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