Vessel General Permit Compliance Guidance Manual Training

1. Vessel General Permit Compliance Guidance Manual Training Sarah K. Branch Manager of Regulatory Affairs

2. Objectives of Training • Provide a summary of the Vessel General Permit (VGP) and how it affects the industry • What, Who, When, Where, & How • Provide an overview of the VGP Compliance Guidance Manual • Demonstrate how to use the VGP Compliance Guidance Manual

3. Vessel General Permit Summary

4. Vessel General Permit Summary:What is the VGP? • National Pollutant Discharge Elimination System (NPDES) permit • Issued by the U. S. Environmental Protection Agency (USEPA) as a result of a Federal Court ruling • Establishes permit limits and conditions on 26 wastewater discharges incidental to the normal operation of vessels that were previously exempted by the USEPA

5. Vessel General Permit Summary:When is the VGP Effective? • USEPA issued the VGP on December 19, 2008 • U.S. Federal Court extended the effective date 60 days • EPA published the Final VGP on February 6, 2009 • All vessels subject to coverage under VGP are subject to the compliance requirements and conditions as of February 19, 2009 • All vessels subject to VGP were automatically covered as of the VGP effective date. • However…certain vessels must submit a Notice of Intent (NOI) between June 19 and September 19, 2009 to maintain coverage.

6. Vessel General Permit Summary:What Vessels are Subject to the VGP? • All non-recreational vessels 79 feet in length or longer • Exceptions include: • Fishing vessels that do not discharge ballast water • Vessels of the armed forces • Both non-recreational vessels less than 79 feet in length and commercial fishing that discharge ballast water are covered under VGP for discharge of ballast water only.

7. Vessel General Permit Summary:Where Does the VGP Apply? • Discharges to the waters of the United States • Inland waters such as rivers, lakes, streams, etc • Also includes Territorial Seas: • defined as “the belt of the seas measured from the line of ordinary low water along that portion of the coast which is in direct contact with the open sea and the line marking the seaward limit of inland waters, and extending seaward a distance of 3 nautical miles.” • Discharges beyond the Territorial Seas are not regulated by the VGP

8. Vessel General Permit Summary:What are the Consequences? • Any false statement, representation, or certification required by VGP • Fines ($10,000 per violation) • Cease and desist orders • Jail time (up to 6 months per violation) • Any knowing falsification or rendering of inaccurate information, or tampering with any monitoring device or method required by VGP • Fines ($10,000 per violation) • Jail time (up to 2 years per violation) • Repeat offenses after first conviction • Fines ($20,000 per day of violation) • Jail time (up to 4 years per violation)

9. Vessel General Permit Summary:How Do You Comply with the VGP? • Complete vessel assessment • Vessel Class • NOI (if required) • Covered Discharges • Chart Course for Vessel Specific Program • Key factors to maintain compliance • Best Management Practices (BMPs) • Recordkeeping • Reporting • VGP Compliance Guidance Manual

10. VGP Compliance Guidance ManualOverview

11. VGP Compliance Guidance Manual Overview:VGP Compliance Manual Objectives • Provide prescriptive program for self-implementing permit • Provide sequential stepwise procedure for vessel specific program • Provide a consistent reference basis for all OMSA members • Decipher EPA “jargon” into common usage terms • Streamline process of vessel analysis

12. VGP Compliance Guidance Manual Overview:VGP Compliance Manual Organization • Section 1 - Introduction • Section 2 - Vessel Assessment Form • Section 3 - Permit Requirements • Section 4 - Forms and Instructions • Section 5 - Appendices

13. VGP Compliance Guidance Manual Overview:Section 1 – Introduction • Disclaimer • How the manual is organized • Explanation of how to use the manual • Summary of the VGP

14. VGP Compliance Guidance Manual Overview:Section 2 – Vessel Assessment Form • Vessel Type • Notice of Intent (NOI) Applicability • Types of Discharges • Additional Information

15. VGP Compliance Guidance Manual Overview:Section 3 – Permit Requirements • Requirements Applicable to All Vessels • Discharge Specific Requirements • Vessel Class Specific Requirements • State Specific Requirements

16. VGP Compliance Guidance Manual Overview:Requirements Applicable to All Vessels • Material Storage • Toxic and Hazardous Materials • Fuel Spills/Overflows • Discharges of Oil Including Oily Mixtures • Compliance with Other Statutes and Regulations

17. Deck Washdown and Runoff and Above Water Line Hull Cleaning Bilgewater Ballast Water Anti-Fouling Hull Coatings Aqueous Film Forming Foam (AFFF) Boiler/Economizer Blowdown Cathodic Protection Chain Locker Effluent Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil to Sea Interfaces… Distillation and Reverse Osmosis Brine Elevator Pit Effluent Firemain Systems Freshwater Layup Gas Turbine Wash Water Graywater Motor Gasoline and Compensating Discharge Non-Oily Machinery Wastewater Refrigeration and Air Condensate Discharge Seawater Cooling Overboard Discharge Seawater Piping Biofouling Prevention Boat Engine Wet Exhaust Sonar Dome Discharge Underwater Ship Husbandry Discharges Welldeck Discharges Graywater Mixed with Sewage from Vessels Exhaust Gas Scrubber Washwater Discharges VGP Compliance Guidance Manual Overview:Discharge Specific Requirements

18. VGP Compliance Guidance Manual Overview:Discharge Vessel Class Specific Requirements • Large Cruise Ships (N/A to OMSA) • Medium Cruise Ships (N/A to OMSA) • Large Ferries (N/A to OMSA) • Barges • Oil or Petroleum Tankers • Research Vessels • Emergency Vessels (Fire Boats, Police Boats) • Vessels Employing Experimental Ballast Water Treatment Systems

19. VGP Compliance Guidance Manual Overview:State Specific Requirements • Additional permit limits and conditions established by individual US states upon approval of the VGP under CWA • Additional conditions only apply within waters under the jurisdiction of the applicable State • 28 US States, Territories, and Indian Tribal Lands approved the VGP with additional conditions • States of Interest – FL, CA, HI, NY • 27 US States approved the VGP without additional conditions • Gulf Coast States – TX, LA, MS, & AL

20. VGP Compliance Guidance Manual Overview:Section 4 – Forms & Instructions • Applicability • Recordkeeping/Inspections/Logs • Reporting

21. VGP Compliance Guidance Manual Overview:Applicability Forms • Notice of Intent (NOI) • Vessels equal to or greater than 300 gross tons and/or • Ballast tank capacity of 8 cubic meters or more • Notice of Termination Form (NOT) • Only apply for those vessels that have submitted an NOI • New owner has taken over vessel • Permanently ceased vessel operations • Obtained coverage for all discharges under another separate NPDES permit

22. VGP Compliance Guidance Manual Overview:Recordkeeping/Inspections/Logs • Owner/Vessel Information • Routine Visual Inspection • Quarterly Visual Inspection • Comprehensive Annual Vessel Inspection • Dry Dock Inspection • Barge/ Tanker Supplemental Inspection • Ballast Water Discharge Recordkeeping • Experimental Ballast Water Treatment System • Corrective Action • Voyage Log • Maintenance Log • Discharge Log • Training Log

23. VGP Compliance Guidance Manual:Reporting • Annual Non-Compliance Report • Spill/Release Report • One Time Permit Report • Discharge Monitoring Report

24. VGP Compliance Guidance Manual:Appendices to VGP Compliance Manual • Appendix A:Final Vessel General Permit (version 2/5/09) • Appendix B:NOI Documentation • Appendix C:Completed Recordkeeping Forms/Documents • Appendix D:Completed Reports • Appendix E:Ballast Water Management Plan(s)

25. How To Use the VGP Compliance Guidance Manual

26. How To Use the VGP Compliance Guidance Manual:Step 1 - Complete Vessel Assessment Form

27. How To Use the VGP Compliance Guidance Manual:Step 2 – Determine Additional Vessel Specific Requirements

28. How To Use the VGP Compliance Guidance Manual:Step 3 – Complete BMP Information for Each Applicable Discharge

29. How To Use the VGP Compliance Guidance Manual:Step 4 – Complete Applicable Forms Notice of Intent (NOI) • NOI form should be available in June 2009 • Electronic submittal via eNOI System- http://cfpub.epa.gov/npdes/enoi.cfm • Existing vessels must submit by September 19, 2009 to maintain authorization • VGP authorization after September 19, 2009 for vessels required to submit an NOI will take at least 30 days to become effective • Ownership transfers • New vessels constructed after September 19, 2009 • Existing vessels that have not obtained authorization

30. How To Use the VGP Compliance Guidance Manual:Example Routine Visual Inspection Form

31. How To Use the VGP Compliance Guidance Manual:Example Barge/Tanker Supplemental Inspection Form

32. How To Use the VGP Compliance Guidance Manual:Example Corrective Action Form – Fuel Spill

33. How To Use the VGP Compliance Guidance Manual:Example Spill/Release Report

34. How To Use the VGP Compliance Guidance Manual:Example Maintenance Log

35. How To Use the VGP Compliance Guidance Manual:Example Training Log

36. How To Use the VGP Compliance Guidance Manual:Example Dry Dock Inspection Form

37. How To Use the VGP Compliance Guidance Manual:Example Annual Non-Compliance Report

38. How To Use the VGP Compliance Guidance Manual:Other Required Records and Reports • Owner/Vessel Information Form • Quarterly Visual Inspection Form • Comprehensive Annual Vessel Inspection Form • Ballast Water Discharge Recordkeeping Form • Experimental Ballast Water Treatment System Form • Voyage Log • Discharge Log • One Time Report • Discharge Monitoring Report