US Environmental Protection AgencyNational Pollution Discharge Elimination SystemVessel General Permit

Training Aims

Understand : What is VGP? What is it’s relevance? Who does it apply to? What sources of information exist? What do I need to do? How do I comply?

• General • Vessel Specific

What is the recording requirement? What is the inspection requirement? What are the training requirements? What are Corrective Actions? Are there penalties for non-compliance? How do I report non-compliance? How does this relate to other legislation?

Presentation Contents

SECTIONS I / II

Plan Familiarisation and Environmental Protection

All Ranks

SECTION III

Fuelling Operations Spill Management

Officers and Crew involved in Bunkering Operations

SECTION IV

Ballast Water and Sediment Management

Officers and Crew involved in Ballast Operations

SECTION V

Additional Tanker Requirements

Officers and Crew involved on Tankers

Sections I / II

SECTIONS I / II

Plan Familiarisation and Environmental Protection

All Ranks

SECTION III

Fuelling Operations Spill Management

Officers and Crew involved in Bunkering Operations

SECTION IV

Ballast Water and Sediment Management

Officers and Crew involved in Ballast Operations

SECTION V

Additional Tanker Requirements

Officers and Crew involved on Tankers

What is VGP?

Permits the routine and necessary discharges incidental to the operation of the vessel

Not required to be held on board

Vessel Control Group will submit Notice of Intent (NOI) to discharge under VGP.

Why is the VGP Relevant?

It makes demands on your time and attention Conduct Processes Record Keeping

... and the penalties for non-compliance, falsification of records or tampering with equipment are severe

All the instructions you require are in V Ships Compliance Manual and Record Book

Who Does VGP Apply to?

Owners and Operators of commercial and large recreational vessels operating in the waters of the USA

Only applies when operating in US waters

Vessel General Permit – Sources of Information

Vessel General Permit V Ships Compliance Manual This Training

www.epa.gov.npdes

What Do I Need To Do?

Gain Awareness / Conduct Training Record training in VGP Record Book

Read VGP / V Ships Compliance Manual Ensure Compliance in Your Vessel Conduct Inspections / Maintain Records

Compliance Summary (I)

Deck Washdown and Runoff and Above Water Line Hull Cleaning (Part 2.2.1)

Decks to be kept clear of any residue that could be washed overboard by rain, spray or deck washdown.

No deck washdown in permit waters Deck surfaces to be maintained in good condition

 

Compliance Summary (II)

Bilgewater (Part 2.2.2) Bilgewater from machinery spaces must not be

discharged in waters covered by this permit except in an emergency

Bilgewater from cargo spaces is not to be discharged in the waters covered by this permit unless in exceptional circumstances.

If a discharge is necessary it must not produce any sheen on the water

 

Compliance Summary (III)

Ballast Water (Part 2.2.3) Vessels must ensure V.Ships Ballast Water Log is properly

maintained Exchange carried out as per additional VGP requirements

appropriate to the voyageNOTE: ADDITIONAL TO USCG REQTS IN 33 CF 155

 Anti-Fouling Hull Coatings (2.2.4) Vessels must have a certificate onboard stating type of anti-fouling

paint and that:• FIFRA standard or meets US standards.• TBT free

If TBT coating still on hull, then certificate stating that effective sealing coat applied.

Certificate or statement that anti-fouling coatings are maintained and applied in accordance with the permit’s requirements.

Compliance Summary (IV)

Aqueous Film Forming Foam (AFFF) (2.2.5) Discharges of AFFF are authorized for emergency

purposes. A record of this discharge must be maintained.

Maintenance and training discharges are not permitted within waters covered by the permit for foreign trading vessels

Maintenance and training discharges for coastal vessels must be retained onboard for shore disposal.

 Boiler/Economizer Blowdown (2.2.6) Discharges of boiler blowdown in waters covered by

this permit are prohibited except for safety purposes.

Compliance Summary (V)

Cathodic Protection (Part 2.2.7) If anodes are used, the least toxic anode material must be used. Sacrificial anodes must not be used more than necessary. During drydock cleaning and replacing to be carried out as required to

reduce excessive flaking or releases from the oxidizing anodes or the dialectic coating from ICCP systems

A certificate from dry-dock must be onboard confirming that hull and cathodic protection have been inspected, cleaned and are maintained.

Chain Locker Effluent (Part 2.2.8) Anchor chain must be thoroughly washed down after every use. Chain lockers must only be pumped out when more than 50 NM from

shore. Chain lockers must be cleaned out during dry-dock. Certificate or statement in dry-dock report, confirming that the chain locker

has been thoroughly cleaned out

Compliance Summary (VI)

Underwater Seals / Wire Ropes and Mechanical Equipment Subject to Immersion. (Part 2.2.9)

Seals must be maintained in good condition and checked/replaced as necessary in dry-dock.

Dry-dock maintenance report to be retained onboard Wire rope must be free of excess lubricant. For in water maintenance, an oil boom must be used to contain

any hydraulic oil leakage. Operators of the vessel must have appropriate equipment such as oil absorbent pads on hand to clean any potential oil spills

Distillation and Reverse Osmosis Brine (Part 2.2.10) Brine from the distillation system and reverse osmosis reject water

shall not contain or come in contact with machinery or industrial equipment, toxic or hazardous materials, or wastes

Compliance Summary (VII)

Elevator Pit Effluent (Part 2.2.11) Elevator Pit Effluent must not be discharged overside except in an

emergency. Elevator pit effluent must be recovered to ER bilge tank for

discharge ashore or through OWS. All discharges must be recorded and logged.

Firemain Systems (Part 2.2.12) Discharges from firemain systems are authorized for emergency

purposes. Minimize the discharge from the firemain system while in port. Do not discharge firemain systems in waters listed in Part 12.1

except in emergency Washing down the anchor chain to comply with anchor wash down

requirements as per 2.2.8 is permitted.

Compliance Summary (VIII)

Freshwater Layup (Part 2.2.13) Minimize the amount of disinfection agents used in

freshwater layup to the minimum required to prevent aquatic growth.

Gas Turbine Wash Water (Part 2.2.14) Gas turbine wash water must not be discharged within

waters subject to this permit

Compliance Summary (IX)

Graywater (Part 2.2.15) All vessels must minimize the discharge of graywater while in Port. Graywater must be stored onboard if the vessel has the capacity

to do this. Vessels that can store graywater must only discharge this when

greater than 1 nm from shore while the vessel is underway. Vessel must use phosphate free and non-toxic soaps and

detergents for any purpose. Ensure this is specified when orderering.

Cooking oil must not be discharged with graywater. As much food and oil residue as practicable must be removed

from plates prior rinsing.

Compliance Summary (X)

Motor Gasoline and Compensating Discharge (Part 2.2.16) Vessels must not discharge water used for this purpose

in waters under this permit. Water used for this purpose must be returned to an oily

bilge tank and be discharged through the oily water separator (OWS) at below 15ppm.

Non-Oily Machinery Wastewater (Part 2.2.17) Non-oily machinery wastewater can be discharged if

control measures are instituted to keep the waste stream free of oils and additives.

Any machinery space waste water is to be regarded as potentially oily as disposed of as required by MARPOL via the OWS where permitted or discharged ashore.

 

Compliance Summary (XI)

Refrigeration and Air Condensate Discharge (Part 2.2.18) No discharge of this type is allowed in the waters

covered by this permit. Seawater Cooling Overboard Discharge (Including Non-

Contact Engine Cooling Water; Hydraulic System Cooling Water, Refrigeration Cooling Water) (Part 2.2.19)

Cooling water discharge when stopped must be limited to minimum required.

Cooling water strainers and filters are to be regularly cleaned when more than 50NM from the shore.

Shore power should be considered if available and the vessel has a compatible system.

Compliance Summary (XII)

Seawater Piping Biofouling Prevention (Part 2.2.20) Biofouling chemicals for seawater piping must be FIFRA approved and used

according to their FIFRA label. Products are prohibited from discharge if they are banned for use in the U.S.

Vessels must use the minimum amount of biofouling chemicals needed to keep fouling under control.

Vessels must remove fouling organisms from seawater piping on a regular basis. These must be discharged greater than 50NM from the shore.

Small Boat Wet Engine Exhaust (Part 2.2.21) These type of engines must be included in vessels planned maintenance system

(PMS) and be maintained in according with manufacturer’s instructions. Low sulphur fuel is to be used whenever possible.

Sonar Dome Discharge (Part 2.2.22) The water inside the sonar dome shall not be discharged within waters subject to

this permit for maintenance purposes. Vessel operators should not use biofouling chemicals that are bioaccumulative for

the exterior of sonar domes.

Compliance Summary (XIII)

Underwater Ship Husbandry Discharges (Part 2.2.23) Major hull-cleaning activities should take place in drydock. Maintenance on hulls while the vessel is waterborne must employ

methods that minimize the discharge of fouling organisms Cleaning of copper based antifoulant paints must not result in any visible

cloud or plume of paint in the water. Welldeck Discharges (Part 2.2.24)

Welldeck discharges that contain graywater must not be discharged except in cases of emergency.

Welldeck discharges from equipment and vehicle washdowns must be free from garbage and must not contain oil in quantities that may be harmful

Good housekeeping required to minimize general waste and debris discharge.

Discharges of Graywater Containing Sewage (Part 2.2.25) Graywater that contain sewage must not be discharged except in cases of

emergency.

Compliance Summary (VIX)

Exhaust Gas Scrubber Washwater Discharge (Part 2.2.26) Low sulfur fuel to be used when in waters covered by

this permit. Exhaust gas scrubber washwater discharge must not

contain oil, including oily mixtures, in quantities that may be harmful.

Sludge generated from exhaust gas scrubber washwater discharge must not be discharged in waters subject to this permit

Vessel Specific Requirements

Some specific requirements exist for certain vessel types: Large Cruise Ships Large Ferries Barges Oil / Petroleum Tankers Research Vessels Emergency Vessels Vessels with Experimental Ballast Water Treatment Systems

Masters / Superintendents must be aware of and observe these specific requirements

Training Requirement – General

‘EPA believes that emphasis on training and educating vessel crew on the use and environmental benefits of these [sound marine] practices should be standard practice’

V Ships meets this through: VMS – General Instructions to Masters and Chief Engineers:

Avoidance of Marine Pollution VMS – Safety and Environmental Procedures VMS – Fleet Operations 6/7 : Ancillary Systems V Ships Trainers Toolbag - Environmental and Pollution

Prevention V Ships Induction Course – ‘Avoidance of Pollution’ (to be

modified)

Recording Requirement

V Ships USA EPA VGP Record Book Vessel Particulars Voyage Log Finding of Inspections Deck Maintenance Record Paint Application Hull Antifouling AFFF Discharges Chain Locker Inspections Underwater Seal Maintenance Emergencies Requiring Discharge Graywater

Inspection Requirement

Routine Visual Inspection Per week / voyage

Quarterly Sample streams not visually apparent

Comprehensive Annual Inspection Dry Dock Inspection

ALL SEAFARERS – AT ALL TIMES

REPORT ANY SURFACE SHEEN TO MASTER / Duty Officer / OOW

Corrective Actions

Eliminate Problems - Prevent Repetition Examples of Identified Problems:

Violation of Effluent Limit Vessel Control Measures not Stringent Enough Pollution Control Measures / Best Management Practice nor being

properly operated Identify Problem - conduct Corrective Action Assessment (Details in V

Ships Compliance Manual) Describe Problem Explain Cause Determine Corrective Action Dry Dock Required – Y/N – when planned? Record when Implemented

Non-compliance – Max Penalties

First Violation - $10 000 and/or 2 years Jail Subsequent Violation – double Each Day is a Fresh Violation!

All non-compliance - at least annually to EPA National Response Center (NRC) - discharge of hazardous substance

/ oil  Submit to appropriate EPA Regional Office

24-hour reporting – any non-compliance which may endanger health or environment. Any information must be provided orally within 24 hours of you becoming aware;

5-day follow-up report – written submission must be provided within five days of you becoming aware;

Be prepared to communicate the information from the completed CORRECTIVE ACTION ASSESSMENT for any non-compliance which may endanger health or the environment

Submit CORRECTIVE ACTION ASSESSMENT within five days

Reporting non-Compliance

Other Legislation

Other guidance / legislation / convention still applies. Vessel still bound by:

ISM MARPOL VMS Vessel Response Plan

..... and others

Section III

SECTIONS I / II

Plan Familiarisation and Environmental Protection

All Ranks

SECTION III

Fuelling Operations Spill Management

Officers and Crew involved in Bunkering Operations

SECTION IV

Ballast Water and Sediment Management

Officers and Crew involved in Ballast Operations

SECTION V

Additional Tanker Requirements

Officers and Crew involved on Tankers

Training Requirement (VGP 2.1.3.)

‘Owners / operators shall ensure that any crew responsible for conducting fuelling operations are trained in methods to minimise spills caused by human error and / or the improper use of equipment’

V Ships meets this through: VMS – General Instructions to Masters and Chief Engineers:

Avoidance of Marine Pollution VMS – Safety and Environment Section 9 : Environmental

Protection VMS – Fleet Operations – 6-7.2 : Bunkering Procedures VMS - VRP / NTVRP VMS - TEC 08 : Bunkering Operations Checklist

Section IV

SECTIONS I / II

Plan Familiarisation and Environmental Protection

All Ranks

SECTION III

Fuelling Operations Spill Management

Officers and Crew involved in Bunkering Operations

SECTION IV

Ballast Water and Sediment Management

Officers and Crew involved in Ballast Operations

SECTION V

Additional Tanker Requirements

Officers and Crew involved on Tankers

Training Requirement (VGP 2.2.3.1)

‘All owners/operators of vessels equipped with ballast water tanks must train the master, operator, person-in-charge, and crew, on the application of ballast water and sediment managements and treatment procedures’

V Ships meets this through:

VMS – Safety and Environmental Procedures – Sect 9.9 : Ballast Changing

VMS - Tanker Vessel Operating Instructions - Sect 12 : Ballast Operations

VMS - Ballast Water Management Plan• Sect 2 – Operation of Ballast Water Management System• Sect 9 – Disposal of Sediments• Sect 11 – Duties of Ballast Water Management Officer• Sect 13 – Crew Training and Familiarisation• Sect 15 – Ballast Water Handling Record Book

Section V

SECTIONS I / II

Plan Familiarisation and Environmental Protection

All Ranks

SECTION III

Fuelling Operations Spill Management

Officers and Crew involved in Bunkering Operations

SECTION IV

Ballast Water and Sediment Management

Officers and Crew involved in Ballast Operations

SECTION V

Additional Tanker Requirements

Officers and Crew involved on Tankers

Training Requirement (VGP 5.5.4)Applying to Oil Tankers:

‘The ship’s crew members who actively take part in the management of the discharge or who may affect the discharge must receive training regarding shipboard environmental procedures and must be able to demonstrate proficiency in implementing these procedures’

‘Advanced training in shipboard environmental management procedures must be provided for those directly involved in managing specific discharge types or areas of the ship and these crew must be able to demonstrate proficiency in implementing these procedures.’

‘Appropriate reprimand procedures must be developed for crew actions that lead to violations of any effluent limit set forth in this permit or procedures established by the vessel operator to minimize the discharge of pollutants.’

V Ships meets this through: V Ships Induction Training – Environmental Awareness Module VMS – Tanker Operating Instructions

• Section 6 (Loading of Cargo)• Section 8 (Discharging)• Section 13 (Equipment)

VMS – Safety and Environment – Section 9 - Environmental Protection VMS - V Ships Vessel Response Plan (In compliance with OPA 90) V Ships Courses – Tanker Familiarisation / Tanker Safety (Petroleum), Environmental

Awareness - Tanker Training Matrix