NACO

National Association of Charterboat Operators

2013 Vessel General Permit – Major Changes and Challenges

Currently this only affects vessels greater than 79' and/or carry more than 150 passengers or 50 or more passengers on overnight trips

On March 28, 2013, the US Environmental Protection Agency (EPA) issued the 2013 Vessel General Permit (2013 VGP) to regulate discharges incidental to the normal operation of commercial vessels. As the 2013 VGP becomes effective on 19th December 2013, about 12,500 foreign flagged vessels are expected to be subject to VGP requirements and be required to obtain authorization under this new permit. New ships (ships built after December 19, 2013) will be obliged to comply with various new requirements e.g. the monitoring of treated bilge water and grey water and ballast water treatment.

The EPA has added training as a new requirement of the 2013 VGP, requiring vessel operators to outline their training plans to ensure that all key vessel personnel sufficiently understand the nature of the eligible discharges and the terms of the permit, and are properly trained to respond to fuel spills and operate and maintain the pollution prevention equipment of their vessels.

 

GL Academy has recently updated and enriched its training course Vessel General Permit: Environmentally sound trading in US waters to help vessel operators, shore and shipboard personnel comply with the new requirements.

 

The most important changes of the 2013 VGP are summarized below:

Reporting requirements

All vessels granted with a permit are required to submit an Annual Report each calendar year, except for 2013. The Annual Report practically replaces the one-time and the annual non-compliance reports of the 2008 VGP by consolidating them into one reporting form. As well as data relative to the actual discharges of a vessel and the voyages conducted in US waters, information must be incorporated in the Annual Report on the functionality monitoring of the ballast water treatment system installed on a vessel, as well as the analytical monitoring of the exhaust gas scrubber effluent water, bilge water and grey water.

Ballast water treatment

The EPA has aligned the VGP requirements on ballast water treatment with those of the US Coast Guard (Standards for Living Organisms in Ships’ Ballast Water Discharged in US waters, 33 CFR Part 151 and 46 CFR Part 162) by adopting identical, numeric ballast water discharge limits, which in turn are identical to those of the IMO D2 standard. These limits must be met by using a ballast water treatment system, any available onshore treatment facilities, or a public water supply system. A ballast water treatment system, through which discharge is to take place in US waters must be type approved by the US Coast Guard or designated as an Alternate Management System.

However, what makes the VGP requirements more stringent is the mandatory monitoring of ballast water treatment systems, consisting of the following:

• functionality monitoring, at least monthly, of certain parameters depending on the treatment process employed as well as periodical calibration of all sensors and control equipment, either onboard the vessel or ashore,

• effluent biological monitoring, twice per year or one per year depending on the results (if they are below permit levels for two consecutive years, then monitoring can take place annually after the first year out of the five in total that the permit is valid), and

• initial and maintenance monitoring of residual biocides and other secondary by-products used or generated during the treatment. When discharging treated ballast water, these residual compounds must not exceed certain limits determined by the EPA, again depending on the treatment process.

Lubricating oils

All vessels must use Environmentally Acceptable Lubricants – EAL (which are biodegradable, not toxic and not bio-accumulative) in all oil to sea interfaces, unless it is not technically feasible (that means that such commercial products are not approved for use in a given shipboard application, or there are not yet any alternatives, etc.). Any use of lubricants that are not characterized or certified as EAL must be documented in the Annual Report.

Τraining

The 2013 VGP places emphasis on the sufficient training of vessel personnel who actively take part in the management of incidental discharges. Training has become one of the six general requirements applicable to all ships regardless of their type. The other existing requirements include: material storage, the management of toxic and hazardous materials, the prevention of overflows and fuel spills, the control of oil discharges and compliance with other regulations.

The revised GL Academy training course on the 2013 VGP is intended to provide useful information on the new requirements to help Masters, vessel officers and shore personnel become familiar with the sound management of potential discharges from their vessels and the proper implementation of the applicable federal and state requirements. It has been structured to explain in detail each eligible type of discharge, the respective generic or numeric effluent limits and the associated best available management practices, the requirements on reporting and recordkeeping, and to propose a sound way of planning and conducting inspections and monitoring.

 

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