Nautical Institute : US Gulf

Over 50 members and guests, including members of Houston Chapter of the Kings Point Alumni, attended the US Gulf Branch technical meeting, addressing the requirements of the new Vessel General Permit (VGP) at the Hess Club, Houston, on 11th March 2009.

Speakers were:

1. Dr. Ryan Albert – Environmental Protection Agency (EPA) Headquarters in Washington – Dr. Albert is the main lead from EPA for the Vessel General Permit,
2. CDR Robert L. Smith, JR, – USCG, Chief Prevention Dept, Sector Houston, Galveston, and
3. Capt. Kuldeep Singh – Director, GMS – International Trainer for Gallagher Marine Services on the implementation of VGP requirements.

The aim of the presentation was to get an overview of the VGP requirements and the pitfalls that may be faced by the industry, on its implementation. As some members may be aware, it is a new requirement and most vessels sailing within 3 nm of the US shoreline need to comply. To date, it is yet to be enforced but it won’t be long before the USCG (most likely) will begin enforcing it.

For further details please visit http://cfpub.epa.gov/npdes/home.cfm?program_id=350

In summary, the EPA has implemented issuance of a VGP to cover discharges incidental to the normal operation of commercial and recreational vessels under the Clean Water Act (CWA) within 3 nautical miles of the shore. The VGP requirements affect any vessel over 300 GT, or length > 79 feet, or with ballast water capacity in excess of 8 cubic meters. The regulations came in force on 6th Feb 2009 and the vessel documentation requirements kicked in on 19th February 2009.

There are 26 kinds of potential pollutants that are addressed by the VGP:

1. Deck wash down and runoff
2. Bilge water
3. Discharges of ballast water
4. Antifouling hull coatings
5. Aqueous Film Forming Foam (AFFF)
6. Boiler/Economizer blow down
7. Cathodic protection
8. Chain locker effluent
9. Controllable pitch propeller, thruster hydraulic fluid & other oil to sea interfaces
10. Distillation and reverse osmosis brine
11. Elevator pit effluent
12. Firemain systems
13. Freshwater lay-up
14. Gas turbine wash water
15. Gray water
16. Motor gasoline and compensating discharge
17. Non-oily machinery wastewater
18. Refrigeration and air condensate discharge
19. Seawater cooling overboard discharge
20. Seawater piping biofouling prevention
21. Boat engine wet exhaust
22. Sonar dome discharge
23. Underwater ship husbandry discharges
24. Welldeck discharges
25. Gray water mixed with sewage from vessels
26. Exhaust gas scrubber wash water discharge

It should be noted, discharges such as sewage, garbage, photo processing effluent, effluent from dry cleaning operations, and discharges of medical waste etc. are covered under other regimes and therefore, are not covered under the VGP.

To obtain a VGP, the vessel’s owner/operator should submit a NOI to EPA. Vessels less than 300 GT and no more than 8 cubic meters of ballast water will not be required to submit an NOI and will be automatically authorized to discharge according to VGP requirements.

The VGP requires various monitoring, inspection, and recording procedures by the ship’s crew, on a regular basis, of all the areas that the permit covers. It also requires annual and dry dock inspections to ensure that hard-to-reach areas are inspected. Therefore, to successfully implement the VGP requirements, vessels should be provided with (or develop) procedures and guidance on how to implement and record the requirements. It should be borne in mind that if the VGP requirements are integrated into the SMS, these requirements will become mandatory for compliance worldwide and will be subject to all internal procedures including auditing and management review

Violations could result in an administrative or civil penalty, and a knowing or negligent violation could constitute a criminal offence under the CWA. In this instance, action could be taken by imposing fines, or imprisonment, or both.

A lively Q & A session followed the three excellent speakers and unsurprising, the continuing criminalization of ship’s staff was mentioned on more than one occasion. During this session it became clear that in addition to the general requirements of the VGP each US State could (and some will) implement their own standards.

We are particularly grateful to our sponsors of this event:

ABS Consulting
Gallagher Marine Services (GMS)
Anglo-Eastern Group

Captain André L. Le Goubin MNI