Vgp Guidance

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INTERTANKO Guidance and Compliance Plan for the EPA Vessel General Permit Requirements 1. 2. 3. 4. 5. General Compliance Dates Notice of Intent Inspections Guidance on the Requirements 5.1 Company Compliance Map 5.2 Regular Inspection and Sampling Records 5.3 Additional Specific Requirements for Oil Tankers 5.4 Corrective Action 5.5 Dry-dock Inspection Certification Report

Annexes I Model Compliance Map II Model Weekly Inspection Record III Model Annual Inspection Record IV Model Sampling Record V Model Corrective Action Assessment VI Model Dry-dock Inspection Certification Report 1. General On 18 December 2008 the U.S. Environmental Protection Agency (EPA) issued the final Vessel General Permit (VGP) under the authority of the Clean Water Act (CWA) requirements for the National Pollutant Discharge Elimination System (NPDES) programme. The requirements will apply to 26 different discharges incidental to the normal operation of all commercial vessels 79 feet or greater in length when operating within the 3 mile territorial sea of the United States commencing on 6 February 2009. The purpose of this document is to provide INTERTANKO members with guidance for compliance with the VGP requirements. This guidance has not been reviewed or approved by the U.S. EPA. It is the responsibility of each member to review the VGP and ensure that all of the requirements applicable to its vessels have been implemented. It is not the intent of INTERTANKO to duplicate all the VGP requirements in this document. However, a copy of the full test of the final VGP should be kept on board. The final VGP can be seen at http://www.epa.gov/npdes/pubs/vessel_vgp_permit.pdf In summary, the VGP contains six sections and a number of Appendices as follows: • Section 1 contains the general requirements and identifies 26 different vessel discharges that are "eligible for coverage".

INTERTANKO Guidance and Compliance Plan for the EPA Vessel General Permit Requirements



Section 2 contains the effluent limits and related requirements for each of the 26 vessel discharges. Many of the requirements are based upon "Best Management Practices". The exceptions to this pertain to bilge water discharges, ballast water discharges, antifouling hull coatings, grey water discharges and underwater husbandry. In the latter, a combination of new requirements and existing international and national requirements apply. In addition to these 26 discharges, Section 2 also contains requirements for material storage, toxic and hazardous materials, fuel oil spills/overflows and discharges of oil. Section 3 contains the corrective action that must be taken if problems are identified. Section 4 contains the inspections, monitoring, reporting and recordkeeping requirements, which are quite onerous. Section 5 contains vessel class-specific requirements with section 5.5 focusing on oil tankers and petroleum tankers. Section 5.5 contains additional requirements for the inert gas scrubber, deck seals, scuppers, supplemental inspections and crew training. Section 6 contains the specific requirements for individual States and Indian Tribes. The Appendices contain definitions, EPA regional contacts, areas covered, procedures for filing a Notice of Intent or a Notice of Termination and requirements for federally protected waters.

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2. Compliance Dates The VGP is effective on 6 February 2009. However, under Section 1.1, the requirements for inspections, training, record keeping, and reporting are required to be met by 19 February 2009. 3. Notice of Intent The owner or operator of a vessel 300 gross tons or more is required to submit a Notice of Intent (NOI) for each vessel to be covered by the permit. The NOI form can be found in Appendix E of the VGP. The NOI is required to be submitted at the earliest by 19 June 2009, but no later than 19 September 2009. Until 19 September 2009 all vessels will be automatically covered by the permit and are authorised to discharge...
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