US Environmental Protection Agency

National Pollution Discharge Elimination System

Vessel 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 voyage
NOTE: 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!
Reporting non-Compliance

 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
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