VESSEL GENERAL PERMIT (VGP) OVERVIEW

The Vessel General Permit (VGP) is a crucial regulation established by the United States Environmental Protection Agency (EPA). Specifically, it aims to control and reduce pollution from vessel discharges into U.S. waters. Since the regulation is comprehensive, this article highlights the main aspects of the VGP. Additionally, it includes references to specific parts of the official Final 2013 VGP document as necessary.

Table of Contents

1. INTRODUCTION

2. UNDERSTANDING THE VESSEL GENERAL PERMIT (VGP)

• REGULATORY FRAMEWORK

• DISCHARGES CATEGORIES COVERED BY THE VGP

3. VESSEL GENERAL PERMIT (VGP) STEP-BY-STEP PROCESS

4. TECHNICAL AND OPERATIONAL REQUIREMENTS

• EFFLUENT LIMITS – GENERAL

• EFFLUENT LIMITS AND REQUIREMENTS BY DISCHARGE CATEGORIES

• CORRECTIVE ACTIONS

• INSPECTIONS AND MONITORING

• RECORDKEEPING

• REPORTING

5. VESSEL GENERAL PERMIT SPECIFIC REQUIREMENTS

6. CONCLUSION

INTRODUCTION

The Vessel General Permit (VGP) aims to control and reduce pollution of U.S. waters originating from discharges incidental to the normal operation of a vessel. Primarily, the permit applies to commercial vessels 79 feet or longer operated as means of transportation. Additionally, smaller commercial fishing and other non-recreational vessels can also be eligible for coverage.

The VGP plays a vital role in maintaining the health of U.S. waters by regulating discharges that can harm marine life and water quality. It encourages the implementation of best management practices (BMPs) and the adoption of environmentally friendly technologies. Non-compliance with the VGP can result in significant penalties, fines, and operational restrictions.

While some discharge types like sewage and waste oil are not part of the scope of the VGP, the permit identifies 27 categories of discharge that are addressed in this article.

The purpose of this article is to provide an overview of the core document of the VGP, which we refer to as the Final 2013 VGP. While it cannot cover all the content in the 194-page official version, this article summarizes the main aspects. Furthermore, it references relevant sections of the official document for more detailed information. This approach simplifies the familiarization process for those encountering the VGP for the first time.

UNDERSTANDING THE VESSEL GENERAL PERMIT (VGP)

DISCHARGE CATEGORIES COVERED BY THE VGP

VESSEL GENERAL PERMIT STEP-BY-STEP PROCESS

This section outlines the steps to prepare a ship for Vessel General Permit compliance from scratch, organizing the concepts naturally to cover the essential requirements. While this article cannot encompass all aspects of the VGP, the process below illustrates the actions required for preparing a vessel, obtaining the necessary permits, and maintaining compliance. For more detailed information, please refer to the full document available on the EPA’s website.

STEP 1: PREPARE THE VESSEL FOR VGP COMPLIANCE

Before submitting the Notice of Intent (NOI), vessel operators must ensure their vessel is ready to comply with the VGP.

Technical Requirements: Planning well in advance is essential, as technical requirements often take months to implement. For vessels already compliant with IMO and MARPOL, the primary areas to check for additional VGP compliance include:

• Bilgewater Treatment Systems
• Ballast Water Management Systems (BWTS)
• Antifouling Hull Coatings
• Cathodic Protection
• Oil-to-Sea Interfaces
• Boat Engine Wet Exhaust
• Exhaust Gas Scrubber Systems

This article discusses these technical requirements in more detail in the relevant sections

Operational Requirements: Implement best management practices (BMPs), conduct routine inspections, and manage discharges effectively.  The “Technical and Operational Requirements” section below explains detailed practices.

STEP 2: SUBMIT A NOTICE OF INTENT (NOI) FOR VESSEL GENERAL PERMIT

Complete and submit the Notice of Intent (NOI) at least 7 days before your vessel enters U.S. waters. The EPA’s eNOI system allows to submit the NOI electronically. This form requires detailed information about the vessel, its operations, and its discharge practices. After submission, the EPA will issue a Vessel Permit Number (VPN), serving as proof of VGP coverage.

STEP 3: RECEIVE THE VESSEL PERMIT NUMBER (VPN)

Once the NOI is submitted, the EPA will review the information and issue a Vessel Permit Number (VPN). This number is essential as it confirms your vessel’s coverage under the VGP. Keep this documentation on board as it will be required during inspections.

STEP 4: DEVELOP AND MAINTAIN VGP DOCUMENTATION

Throughout the process, you must develop and maintain proper documentation. This includes:

• Copy of the VGP: Keep an updated copy of the VGP document on board the vessel.
• Copy of the Submitted NOI: Maintain a copy of the submitted NOI and the acknowledgment receipt from the EPA.
• Vessel Permit Number (VPN): Keep a copy of the VPN documentation on board.
• Record Keeping for VGP: Set up a system to maintain records of inspections, monitoring, corrective actions, and training. These records must be readily available for inspection.

For detailed information on each document and its requirements, refer to the “VGP Documentary Aspects” section below.

TECHNICAL AND OPERATIONAL REQUIREMENTS

EFFLUENT LIMITS – GENERAL

Part 2 of the Final 2013 Vessel General Permit includes details of effluent limits. Specifically, discharges related to the normal operation of the vessel must be minimized through best management practices. For instance, during deck-washing, discharging minimal debris is acceptable if efforts are made to remove garbage beforehand. Notably, the VGP explicitly prohibits diluting pollutants to meet acceptable limits.

Key aspects include:

• Material Storage: Minimize the time materials like cargo debris remain on deck. Additionally, potential pollutants must be stored in covered areas. If water from storage areas contacts oily materials, it must be processed through an Oily Water Separator or stored for shore disposal.
• Toxic and Hazardous Materials: These must be kept in protected, labeled, and secured containers, as far as ship design and safety allow.
• Fuel Spills/Overflows: Vessel General Permit requirements align closely with IMO regulations, including prompt containment and cleanup of spills. Moreover, vessels must use spill containment methods and ensure crew training to minimize spills. Specific requirements for fueling auxiliary vessels, such as lifeboats, are also detailed.
• Discharges of Oil Including Oily Mixtures: Generally, compliance with MARPOL ensures VGP compliance. However, the VGP specifies that oily water discharges must not exceed harmful limits as per 40 CFR Part 110, prohibiting discharges that cause visible sheen, sludge, or emulsions.
• Compliance with Other Statutes and Regulations: The Vessel General Permit may require adherence to additional regulations. For more information, please refer to the U.S. Government Publishing Office (gpo.gov). Due to space constraints, this article does not cover additional regulations that could have a connection with the Vessel General Permit.
• General Training: Operators must ensure personnel are trained in managing incidental discharges, including fuel spill response. Furthermore, training should cover notifying appropriate personnel and agencies and comply with recordkeeping requirements in Part 4.2 of the VGP.

EFFLUENT LIMITS AND REQUIREMENTS BY DISCHARGE CATEGORIES

The Final 2013 VGP document lists 27 categories of discharges. This article focuses on the main Vessel General Permit requirements that exceed those covered by IMO regulations, including MARPOL.

1 Deck Washdown and Runoff and Above Water Line Hull Cleaning

Operators must minimize the introduction of debris and pollutants. Accordingly, it is essential to sweep the deck with a broom to remove debris before washdowns. Additionally, use cleaning agents sparingly, avoiding harmful substances like detergents with nonylphenols (NP) or nonylphenol ethoxylates (NPEs).

2 Bilgewater/Oily Water Separator Effluent

Vessels must use bilgewater treatment systems to reduce oil content to less than 15 ppm, as required by MARPOL. Moreover, the VGP imposes additional monitoring, record-keeping, and reporting requirements. Additionally, vessels equipped with Oil Content Meters (OCMs) sensitive to 5 ppm may qualify for reduced monitoring if specific conditions are met.

Compliance

Discharges must adhere to 40 CFR Parts 110, 116, and 117, and 33 CFR §151.10, ensuring protection of water quality from oil and hazardous substances.

Discharge Restrictions

The use of dispersants, detergents, emulsifiers, or chemicals to obscure oil in bilgewater is prohibited, except for maintenance in machinery spaces without altering oil properties.

Minimization of Discharge

Operators must minimize bilgewater discharge by reducing its generation. Alternatively, they can use shore facilities where feasible or discharge beyond 3 nautical miles from shore.

Special Conditions for Larger Vessels

• Vessels over 400 gross tons must not discharge untreated bilgewater with oil content above 15 ppm. Additionally, vessels should avoid treated discharges within 1 nautical mile of shore and limit them in protected waters unless necessary for safety.
• Discharge is acceptable when the vessel is underway at speeds exceeding 6 knots, except when safety concerns are present. However, shore disposal is preferable. Furthermore, operators must document and report all discharges, especially those related to safety, according to VGP Part 4.2.

Bilgewater Monitoring and Reporting

New vessels over 400 gross tons built after December 19, 2013, must annually monitor bilgewater effluent for oil and grease. Operators must analyze samples using ISO 9377-2 or EPA Method 1664 and document OCM readings. Furthermore, vessels maintaining oil and grease concentrations below 5 ppm for two consecutive years may waive further sampling under specific conditions. Additionally, operators must submit monitoring data, including OCM data, annually by February 28 of the following year. If a waiver applies, operators should note this in the report. They may also include the data in the vessel’s annual VGP bilgewater Discharge Monitoring Report (DMR).

3 Ballast Water

All ballast water discharges must comply with the Vessel General Permit and U.S. Coast Guard regulations (33 CFR Part 151). These discharges must not contain oil, noxious liquid substances, or hazardous substances prohibited under U.S. laws. Vessels must also adhere to specific numeric discharge limits for living organisms and indicator microorganisms.

Training:

Vessel personnel must be trained in ballast water and sediment management procedures. A written training plan and training records must be maintained onboard.

Ballast Water Management Plans

Each vessel must have a ballast water management plan that complies with the Vessel General Permit requirements, outlining procedures for managing ballast water and sediment. This plan must be accessible to the EPA upon request.

Mandatory Ballast Water Management Practices

To minimize invasive species introduction, vessels should avoid ballast water discharge or uptake in sensitive areas. They should minimize intake in areas with harmful organisms, near sewage outfalls, and during dredging. Regular cleaning of ballast tanks is required to reduce sediment accumulation.

Mandatory Practices for Lakers

Lakers operating in the Great Lakes must conduct annual sediment accumulation inspections, develop sediment removal policies, and maintain sea chest screens. Records of sediment removal must be kept onboard.

Ballast Water Numeric Discharge Limitations

Vessels must ensure ballast water discharges meet the following limits:

• Organisms ≥ 50 micrometers: < 10 living organisms per cubic meter.
• Organisms < 50 micrometers and ≥ 10 micrometers: < 10 living organisms per milliliter.
• Toxicogenic Vibrio cholerae: < 1 cfu per 100 mL.
• Escherichia coli: < 250 cfu per 100 mL.
• Intestinal enterococci: < 100 cfu per 100 mL.

Ballast Water Management Measures

Owners and operators must use one of the following methods to meet these discharge limits:

• A U.S. Coast Guard-approved Ballast Water Treatment System (BWTS) or an Alternative Management System (AMS).
• Onshore treatment facilities.
• Using public water supply water.
• No discharge of ballast water.

BWTS Monitoring and Calibration

Operators must conduct monthly BWTS performance monitoring, which includes regular calibration of sensors. Additionally, they should perform biological organism monitoring to ensure compliance with discharge limits. For vessels using biocides, it is essential to monitor residual levels to ensure they do not exceed specified limits, such as 100 µg/L for Chlorine and Ozone.

Recordkeeping and Recording

Operators must keep all sampling and testing records onboard for at least three years. Additionally, vessels need to report data annually, detailing compliance with numeric discharge limitations. These records should include the date, location, time of sampling, personnel involved, and results obtained.

Interim Requirements for Non-compliant Vessels

Vessels not yet compliant with treatment standards must perform ballast water exchange or flushing as applicable. This measure helps mitigate invasive species risk until full compliance is achieved.

Vessels entering the Great Lakes

Additional measures apply to vessels entering the Great Lakes via the Saint Lawrence Seaway System, including mandatory ballast water exchange and flushing to prevent non-native species introduction.

Vessels in the U.S. Coast Guard Shipboard Technology Evaluation Program (STEP)

Vessels in STEP are exempt from certain VGP requirements if they meet conditions outlined in their participation agreement. This includes exemptions from specific ballast water management measures, provided they comply with ongoing evaluation criteria.

4 Anti-Fouling Hull Coatings

All anti-fouling coatings must comply with the Clean Hull Act of 2010 and, if applicable, FIFRA registration requirements. Coatings produced in the U.S. must meet these standards, while non-U.S. coatings must not contain banned biocides or toxic materials. Specifically, coatings must not contain Tributyltin (TBT) or any organotin compound used as a biocide, as restricted under U.S. regulations.

Operators must ensure that organotin compounds used as catalysts do not exceed 2500 mg of total tin per kilogram of dry paint. Furthermore, they must use coatings designed to resist sloughing or peeling. Additionally, operators need to either effectively overcoat or remove previous TBT coatings to prevent TBT leaching.

To ensure compliance with VGP requirements, it is advisable to consult with a coating specialist or trusted supplier. Operators should consider using coatings with the lowest effective biocide release rates, rapidly biodegradable components, or non-biocidal alternatives, especially in copper-impaired waters. If operators use copper-based coatings, theys must document the decision-making process in their records.

Summary of Compliance Requirements:

• Adhere to the Clean Hull Act of 2010 and FIFRA label requirements.
• Avoid banned biocides and toxic materials.
• Limit organotin compounds.
• Consult experts for suitable coatings and alternatives.
• Properly document and overcoat/remove TBT coatings.

5 Aqueous Film Forming Foam (AFFF)

Vessels may discharge AFFF in US waters in case of an emergency compromising vessel and crew safety.

Vessels sailing outside the territorial sea more than once per month must not discharge AFFF within VGP waters for maintenance or training. Accordingly, in such situations, vessels must collect fluorinated AFFF for onshore disposal. For regulatory certification and inspection purposes, discharging AFFF is acceptable. However, operators must minimize the amount or effluent and, if possible, opt for a substitute, non-fluorinated foaming agent.

For vessels that do not leave the territorial sea more than once per month, operators must also collect AFFF discharges for onshore disposal unless they use a non-fluorinated agent. Furthermore, training should take place as far from shore as possible. In fact, training and maintenance should never take place in port.

Notably, AFFF discharges from within 1 nm of waters referenced in Appendix G are permissible only in emergencies or specific government-contracted operations. Finally, operators must document all emergency discharges in these areas in the ship’s log.

6 Boiler/Economizer Blowdown

Operators should minimize the discharge of boiler/economizer blowdown in port, especially if they use chemicals to reduce impurities. Furthermore, vessels over 400 gross tons that leave the territorial sea at least once per week must avoid discharging blowdown in permit waters unless necessary due to prolonged stay, pre-drydock, or safety concerns. Notably, discharging blowdown in waters referenced in Appendix G is not permissible except for safety purposes. Additionally, operators should conduct such discharge as far from shore as possible..

7 Cathodic Protection

To prevent hull corrosion, operators must maintain cathodic protection systems diligently. Moreover, they should minimize discharges from sacrificial anodes, such as zinc, magnesium, and aluminium, particularly avoiding the flaking of large, corroded portions. Furthermore, operators should use anodes only as necessary to protect the hull, sea chest, rudder, and other exposed areas.
The choice of anode material plays a crucial role. Specifically, operators should prefer magnesium for freshwater and aluminium for seawater, while zinc is less desirable due to its higher toxicity. If a vessel requires a more harmful anode material, operators must document the reason, especially after the first drydocking post-December 19, 2013.
Additionally, operators must prioritize proper maintenance and replacement of anodes during maintenance periods to reduce metal release. They must ensure anodes do not create hotspots for fouling organisms. Accordingly, to prevent these hotspots, operators should flush-fit the anodes or fill gaps as appropriate.
The EPA recommends using ICCP or other advanced technologies, particularly for new vessels, to reduce reliance on sacrificial anodes. When using ICCP, operators must also maintain dielectric shields to prevent flaking, ensuring compliance and optimizing the system’s efficiency.

8 Chain Locker Effluent

When removing anchor chains from the water, operators should thoroughly wash them to remove sediment and marine organisms. During dry-docking, they should clean the chain lockers to eliminate sediments and pollutants. Furthermore, for vessels that regularly sail outside permit waters (at least once per month), operators should clean, rinse, or pump out the space beneath the chain locker mid-ocean before re-entering permit waters, if feasible. Additionally, operators should avoid rinsing or pumping out chain lockers in permit waters unless necessary for safety. In such cases, they must document these actions accordingly.

9 Oil-to-Sea Interfaces and lubrication systems

Protective seals on controllable pitch propellers, azimuth thrusters, propulsion pods, rudder bearings, and other oil-to-sea interfaces must be maintained to minimize oil leaks. The discharge of oil must not exceed harmful quantities as defined in 40 CFR Part 110.

Maintenance and Spill Response:
Whenever possible, operators should perform maintenance on oil-to-sea interfaces in drydock. However, if in-water maintenance or emergency repairs are necessary, they must utilize appropriate spill response equipment, such as oil booms, to contain any oil leaks. Moreover, operators need ready access to spill response resources to clean up spills promptly. Additionally, after applying lubricant to submerged equipment, they should thoroughly remove excess lubricant, unless the vessel’s Master considers it unsafe to do so.

Environmentally Acceptable Lubricants (EALs):
Operators must use EALs in oil-to-sea interfaces unless technically infeasible. EALs, which are biodegradable, minimally toxic, and non-bioaccumulative, provide an environmentally friendly option. However, technical infeasibility may arise if EALs fail to meet manufacturer specifications, if EAL products are unavailable, or if replacement must await the next drydock. Therefore, if operators cannot use EALs, they must document the reason and report it in the Annual Report.

Seawater-Based and Air Sealing Systems:
he EPA recommends seawater-based systems for stern tube lubrication to eliminate oil discharge. Alternatively, air sealing systems create an air barrier to prevent oil-water contact, offering another acceptable option.

Compliance and Documentation:
Vessels can obtain a Vessel Permit Number (VPN) while awaiting drydock to replace seals and oil with EALs, provided the operator documents and reports the technical infeasibility. It is advisable to check with authorities to ensure compliance.

10 Distillation and Reverse Osmosis Brine

Brine from distillation systems and reverse osmosis reject water must not contain or contact machinery, industrial equipment, toxic or hazardous materials, or wastes.

11 Elevator Pit Effluent

Operators must not discharge untreated elevator pit effluent within permit waters, except in emergencies. They may manage the effluent with bilgewater if it meets Part 2.2.2 requirements, or treat it using an oily-water separator, ensuring an oil content below 15 ppm. Additionally, operators must document all emergency discharges in the ship’s log.

12 Firemain Systems

Operators may discharge water from firemain systems for emergency purposes, testing, inspections, and secondary uses if the intake comes from surrounding waters or potable water supplies without additives. When possible, they should conduct these discharges outside port and permit waters. Furthermore, discharges in waters listed in Appendix G are only acceptable in emergencies or for anchor washdown.

13 Freshwater Layup

Minimize the use of disinfection or biocidal agents during freshwater layup to the minimum necessary to prevent aquatic growth.

14 Gas Turbine Washwater

Operators must avoid discharging gas turbine washwater directly within permit waters. Instead, they should collect it separately and dispose of it onshore, ensuring no mixing with bilgewater. Additionally, operators must ensure that oils from gas turbine washwater do not exceed harmful quantities according to 40 CFR Part 110.

15 Graywater

Operators must minimize graywater discharge in port. Vessels capable of storing graywater should avoid discharging it in waters listed in Appendix G. For ships unable to store graywater, they must minimize production in these areas. Vessels over 400 gross tons that travel more than 1 nm from shore should discharge graywater beyond 1 nm while underway, unless they meet specific treatment standards. Operators should also minimize kitchen oils and opt for phosphate-free, minimally-toxic soaps. Graywater discharge should maintain pH levels between 6.0 and 9.0. In nutrient-impaired waters, operators must minimize graywater discharge, preferably storing it for onshore disposal or releasing it in deep, well-circulated areas.

Additional Requirements for Certain VGP Vessels Operating in the Great Lakes:
Non-commercial vessels must either store all graywater for onshore discharge to an NPDES facility or ensure that graywater discharge does not exceed 200 fecal coliform units per 100 mL and 150 mg/L of suspended solids. Accordingly, operators must conduct monitoring to demonstrate compliance, and they must retain records for at least three years.

Graywater Monitoring:
For vessels constructed after December 19, 2013, with a crew capacity of 15 or more and providing overnight accommodations, as well as vessels subject to Part 2.2.15.1, operators must collect and analyze two samples per year. These samples should include BOD, fecal coliform (or E. coli), suspended solids, pH, and total residual chlorine. Additionally, operators must maintain records of sampling and analysis for at least three years. However, if vessels do not enter permit waters for a year, monitoring becomes unnecessary. In such cases, operators should note this in the Annual Report.

16 Motor Gasoline and Compensating Discharge

Operators must ensure that discharges do not contain oil in harmful quantities, as defined in 40 CFR §110.3, including visible sheen or oil concentrations exceeding 15 ppm. They should visually monitor compliance for any oily sheen. Furthermore, operators should minimize discharges in port and contain any observed oily sheen. Notably, discharge is not allowed in waters listed in Appendix G.

17 Non-Oily Machinery Wastewater

Non-oily machinery wastewater must be free from harmful oil quantities as defined in 40 CFR Part 110 and toxic or bioaccumulative additives. Additionally, packing gland or stuffing box effluent must not produce a visible sheen of oil.

18 Refrigeration and Air Condensate Discharge

Refrigeration and air condensate discharge must not contact oily or toxic materials if discharged directly overboard. If commingled with oily water for internal recycling, it must meet all requirements of Parts 2.1.4 and 2.2.2.

19 Seawater Cooling Overboard Discharge

Non-contact engine cooling water, hydraulic system cooling water, and refrigeration cooling water discharges should occur while underway to minimize thermal impacts. Use shore-based power in port when available and compatible. Maintenance must comply with Part 2.2.20 requirements.

20 Seawater Piping Biofouling Prevention

Operators must use biofouling chemicals according to FIFRA labels. Additionally, they cannot use pesticides or chemicals banned in the U.S. Moreover, operators should use the minimum amounts of biofouling chemicals necessary, with active agents containing as little chlorine as possible. Furthermore, they must regularly remove fouling organisms and dispose of them according to regulations, preferably more than 50 nm from shore.

21 Boat Engine Wet Exhaust

Vessel operators should ensure engines remain well-maintained, well-tuned, and operate on low sulfur or alternative fuels. Additionally, the EPA recommends using four-stroke engines for those with wet exhaust covered under the Vessel General Permit. Notably, operators must use environmentally acceptable lubricants (EALs) for two-stroke engines unless it’s technologically infeasible. If operators cannot use EALs due to infeasibility, they should document the reasons in their recordkeeping.

22 Sonar Dome Discharge

The vessel should not discharge sonar dome water for maintenance purposes in permit waters. Moreover, biofouling chemicals used on sonar domes should be non-bioaccumulative whenever alternatives are available.

23 Underwater Ship Husbandry and Hull Fouling Discharges

To minimize the transport of attached living organisms into U.S. waters, vessel operators should perform rigorous hull cleaning in drydock or at facilities that treat washwater. Additionally, when cleaning in water, use appropriate methods to reduce the discharge of fouling organisms and antifouling coatings. Notably, operators should avoid cleaning copper-based antifoulant paints in copper-impaired waters within the first 365 days after application. If such cleaning is necessary, operators must document the reasons.

24 Welldeck Discharges

Small vessels must not discharge graywater and washdown discharges in permit waters unless there is an emergency. Furthermore, these discharges must be free from garbage and harmful oil quantities as defined in 40 CFR Part 110.

25 Graywater Mixed with Sewage from Vessels

When graywater mixes with sewage, the resulting discharges must meet the graywater discharge limits outlined in Part 2.2.15 or Part 5 of the permit. Additionally, all discharges must comply with CWA section 312 and its regulations..

26 Exhaust Gas Scrubber Washwater Discharge

Discharges must not contain harmful oil quantities, following the specifications in 40 CFR Part 110. Moreover, operators must dispose of sludge and residues from washwater treatment onshore. The discharge must comply with numeric effluent limits for pH, PAHs (Polycyclic Aromatic Hydrocarbons), turbidity, and nitrates/nitrites, along with continuous and analytical monitoring requirements. For vessels lacking a USCG-approved exhaust gas scrubber system, operators must ensure compliance with the VGP’s numeric effluent limits and monitoring requirements. In cases of uncertainty, consulting with the equipment manufacturer or experts is advisable.

Exhaust Gas Scrubber Washwater Discharge Standards

• pH: Minimum of 6.0 at overboard discharge, with a maximum difference of 2.0 units during maneuvering and transit.
• PAHs: Maximum 50 μg/L PAHphe above inlet water PAH concentration, normalized to 45 t/MWh.
• Turbidity: Maximum 25 FNU/NTU above inlet water, averaged over 15 minutes.
• Nitrates / Nitrites: Prevent discharge beyond 60 mg/L, normalized to 45 t/MWh or associated with 12% NOx removal.

Exhaust Gas Scrubber Analytical Monitoring Requirements

• Operators must continuously monitor pH, PAHs, and turbidity. Additionally, they must conduct analytical monitoring by collecting and analyzing two samples in the first year and one sample annually thereafter. These samples must be tested for various parameters, including dissolved and total metals and PAHs.

27 Fish Hold Effluent

To begin with, minimize the discharge of fish hold water and ice while stationary at the pier. Moreover, do not discharge large solid fish waste without employing physical separation methods, such as screens. Instead, dispose of solid fish waste onshore or at sea, but only outside protected areas. Furthermore, use shore-based discharge facilities if available and economically feasible, provided they have an NPDES permit. Additionally, do not discard unused live bait overboard unless it was caught in the same waterbody; in such cases, documentation is required for purchased bait.

Additional Water Quality-Based Effluent Limits

This section ensures that discharges meet applicable water quality standards. Generally, complying with the permit conditions achieves this goal. However, if discharges exceed water quality standards, operators must take corrective actions and report to the EPA. Furthermore, the EPA may impose additional limitations or require individual permits when necessary.

Discharges to Impaired Waters:

• Without an EPA-Approved TMDL: Compliance with Part 2.3.1 and any additional EPA requirements is required, even if the water is not listed as impaired.
• With an EPA-Approved TMDL: Discharges must align with the Waste Load Allocation (WLA) in the TMDL. The EPA will inform operators of any additional necessary limits or controls.

CORRECTIVE ACTIONS

Noncompliance with the permit requirements constitutes a violation of the Clean Water Act (CWA) and may lead to enforcement actions. Specifically, the Final 2013 VGP specifies three situations requiring corrective actions:

1. Violation of effluent limits, including necessary modifications identified during EPA inspections.
2. Control measures failing to meet water quality standards.
3. Improper implementation or ineffectiveness of pollution control measures or best management practices.

Upon identifying non-compliance, operators must conduct a corrective action assessment, including:

• A description of the problem, including date, time, location, observed impact, and the person documenting it.
• Explanation of the cause, if known, or steps to determine it.
• Description and schedule of corrective actions, with an indication if drydocking is needed.
• Details of the corrective action implementation, including dates and personnel involved.

Deadlines for corrective actions

The Vessel General Permit sets deadlines for completing corrective measures:

• Immediate Solution: Implement immediately.
• Simple Measures: Complete within 2 weeks.
• External Resources Required: Unless impracticable, complete within 3 months; document reasons for delays.
• Dry-Docking Required: Complete at the next dry-docking.

Extensions may apply if the vessel leaves the US and re-enters at a later time.

Liabilities

Taking corrective actions does not eliminate potential liabilities for the violation. Moreover, failing to take corrective measures constitutes an additional permit violation. Notably, the EPA may impose stricter requirements or compliance schedules beyond the VGP’s provisions, and these will take precedence in case of conflict.

 INSPECTIONS AND MONITORING

Vessel operators must conduct various inspections, including routine visual inspections, extended unmanned period (EUP) inspections, annual inspections, and drydock inspections.

Routine Visual Inspections

These inspections must occur weekly or once per voyage, whichever is more frequent. However, for vessels with multiple voyages per day, one inspection per day is sufficient. Additionally, inspections should cover accessible areas onboard and check for exposed garbage or potential pollutants. Inspectors must document findings, including date, time, location, personnel, observations, and potential issues. Moreover, the inspector must sign the report, and records should be available for EPA review upon request.

Extended Unmanned Period (EUP) Inspections

During periods like dry-docking or lay-up (13 days or more), it is acceptable to replace routine inspections with EUP inspections, as detailed in Part 4.1.1.2 of the Final 2013 VGP.

Annual Inspections

Qualified personnel must conduct these comprehensive inspections, covering all areas that are accessible without dry-docking the vessel. Specifically, this includes inspecting the hull, niche areas, ballast tanks, bilges, Oily Water Separator sensors, oil discharge monitoring systems, hydraulic oil sealing systems, storage areas, and pollution control measures. Additionally, the inspection should review monitoring data, maintenance records, and previous annual inspections to ensure compliance..

Drydock Inspection reports

These reports must be available to the EPA upon request and should document significant maintenance activities to prevent pollution. Typically, this includes cleaning the chain locker, inspecting and eliminating living organisms from the hull and external areas, antifouling treatment, cathodic protection, and maintaining pollution control equipment. Moreover, all inspection logs should include descriptions of findings, corrective actions planned or taken, inspection dates, and the inspector’s name and title.

RECORDKEEPING

Vessels covered by the VGP must maintain comprehensive records, including:

• Vessel Particulars: Basic vessel information.
• Voyage Log: Includes dates, ports, vessel agents, last port and country of call, and next port and country of call.
• Records of Violations: Document details of any violations, corrective action assessments, and relevant signatures.
• Inspection Logs: Findings from routine, annual, and drydock inspections.
• Monitoring Results: Analytical data and laboratory QA documentation for all monitoring activities.
• Specific EPA Requirements: Documentation on meeting specific water quality requirements by EPA.
• Additional Maintenance and Discharge Information: Includes records of deck maintenance, bilgewater disposal, antifouling paint applications, AFFF use, chain locker inspections, oil-to-sea interfaces, emergency discharges, gas turbine waterwash, graywater discharges, and EAL usage details.
• Other Documentation: Any other necessary records.
• Training Records: Documentation of training completed, possibly as part of the operator’s SMS or ISM procedures.

Additional Recordkeeping for vessels with Ballast Tanks

• Ballast Water Information: Total ballast capacity and tanks in ballast.
• Ballast Water Management: Details as per the ballast management plan.
• Discharge Details: Specifics of ballast water discharges in U.S. waters, including origin, dates, temperatures, water exchanges, etc.
• Sediment Disposal: Details of sediment discharge to shore facilities, if applicable.

These records must be thorough, including dates, locations, volumes, materials used, maintenance descriptions, and procedures, as applicable.

REPORTING

Annual Report:
Operators need to submit an Annual Report for each vessel with active permit coverage by February 28 of the following year. This requirement applies to vessels with an active NOI or those operating under a PARI form. Interestingly, operators may complete these reports electronically via the EPA’s website or eNOI system. Specifically, they must provide all necessary information and data accurately. If they qualify, they must postmark hard copy reports by February 21. Notably, the Annual Report replaces the annual noncompliance report and one-time report requirements from the 2008 VGP.

Combined Annual Reports for Unmanned, Unpowered Vessels under 400 GT:
Operators can submit a single Combined Annual Report for multiple vessels under specific conditions. They must ensure that all answers are the same, that they did not require any analytical monitoring, and that they submitted the report electronically. Furthermore, they must confirm that there were no instances of noncompliance. Additionally, each vessel needs to have either an NOI permit number or a unique identifier.

Reportable Quantities of Hazardous Substances or Oil:
If a discharge contains oil or hazardous substances in amounts equal to or exceeding reportable quantities, operators must notify the National Response Center (NRC). Moreover, they must record details of the release, including preventive measures, within 14 days. Importantly, such discharges are not authorized by the permit and may violate section 311 of the CWA.

Additional Reporting:
Part 4 requirements and the standard permit reporting provisions in Part 1.13 apply. Additionally, operators must report any noncompliance that may endanger health or the environment within 24 hours, followed by a written report within five days. If they report to the NRC as per Part 4.4.3, additional reporting is not necessary.

VESSEL GENERAL PERMIT SPECIFIC REQUIREMENTS

The VGP outlines numerous additional requirements for specific vessel types, operations, and individual states. Notably, Part 5 details class-specific requirements, varying standards and practices based on vessel design and function. Furthermore, Part 6 provides additional requirements for vessels operating in specific states or Indian Country lands, ensuring compliance with state-specific water quality standards.

Additionally, the VGP includes various appendices that offer further details and guidance. These appendices cover topics such as specific discharge monitoring procedures, compliance documentation, and additional technical specifications. Since the requirements are extensive and varied, covering all details in this article is impractical. Consequently, for comprehensive information, including specific operational practices and state-specific regulations, please refer to the Final VGP 2013 document.

CONCLUSION

In summary, the VGP provides detailed guidelines and requirements for vessel discharges in U.S. waters, going beyond IMO and MARPOL standards in some areas. Accordingly, this article has strived to summarize the key points while referring to the core Final VGP 2013 document when full details are necessary. Since the official document includes several appendices that provide practical details, such as definitions, EPA regional contacts, and specific forms, we encourage readers to review them.

If you have any comments, please feel free to use the form below or Contact Us by email.

To read the full Final 2013 VGP document, you can visit the EPA website:

Vessels | US EPA

or directly download the file from this page:

Regulations.gov/document/EPA-HQ-OW-2011-0141-0949