Vessel General Permit

LT Bryan Wendleton

What is VGP?

The VGP is a Clean Water Act National Pollutant Discharge Elimination System (NPDES) permit that authorizes, on a nationwide basis, discharges incidental to the normal operation of non-military and non-recreational vessels greater than or equal to 79 feet in length.

The VGP and the CG

• The VGP require vessel operators to utilize best practices in the management of shipboard discharges incidental to the normal operation of the vessel in order to protect the marine environment, the Coast Guard shares a mutual interest in ensuring vessels comply with VGP provisions.

• Therefore, in fulfilling its role as the nation’s lead maritime law enforcement agency and to carry out its mission of environmental stewardship, it is in the interest of the Coast Guard to assist the EPA in the detection and reporting of VGP deficiencies onboard vessels.

*MOU signed 2011

VGP Exam Items

• Routine Visual Inspections– Cargo holds, machinery areas

chemical storage areas, well deck & other deck areas

– Ship’s watch• Annual Vessel Inspections– Hull, bilges, pumps & OWS– Protective seals for lub & hydraulic

oil leaks– Oil & chemical storages– All visible pollution control

measures

Documentation

• Routine inspection log• Annual inspection records• Corrective action assessment log• Dry-dock inspection records• Grey water discharge• Training

Small Vessel General Permit (proposed)

• All non-recreational, non-military vessels less than 79 feet (24.08 meters).

• Applicable to discharges incidental to the normal operation of a vessel.

What is Covered?

• Anti-fouling hull coating leachate• Bilge water• Deck runoff• Fish hold effluent• Gray water• Non-contact engine cooling water• Packing gland effluent• Underwater hull husbandry

What is not covered?

• Sewage• Used oil• Garbage or Trash• Tetrachloroethylene

RequirementsManagement Area Highlighted Management Practices

Include:

General Requirements Oil, including oily mixtures, may not be discharged in quantities that may be harmful or cause a visible sheen

Fuel Management Regularly inspect the fuel and hydraulic systems for any damage or leaks, repair if found.

Engine and Oil Control Preference for environmentally acceptable lubricants

Solid and Liquid Waste Management Prevent monofilament line, fishing nets, lines, lures, rope, bait boxes, and hooks from entering any waste stream covered by this permit

Requirements Cont.Management Area Highlighted management practices include:

Vessel Hull Maintenance Must use phosphate free, non-toxic soaps

Gray Water Minimize gray water discharges in areas that have heavy vessel traffic or recreational use and in marine sanctuaries, national wildlife refuges, national wild and scenic rivers, and national wilderness areas.

Fish Hold Effluent Minimize discharge of fish hold or dirty ice while in port. If onshore treatment available, must use it

Seawater Cooling Overboard

Minimize thermal impacts to the receiving waters by discharging seawater cooling overboard while the vessel is underway.

Deck Wash down and Runoff

Minimize the introduction of on deck debris, garbage, residue and spill into deck wash down and runoff discharges.

Inspection Items

• VGP Compliance• Sign and maintain a copy of the VGP permit

authorization and record of inspection(PARI) form

• Records of quarterly visual inspections & any corrective actions taken

• Pollution prevention

Documentation

• Permit Authorization and Record of Inspection Form

• Quarterly Inspection Records• Corrective Action Assessment

Record

Questions?