From 19 December 2008, all commercial vessels, except commercial fishing vessels, of 79 feet (24.08 meters) in length or greater with discharges of pollutants incidental to their normal operation, including but not limited to ballast water discharges, into the US three mile territorial sea or inland waters will become subject to the EPA final Vessel General Permit (VGP) requirements [see Club circular 16/08].  Members whose vessels will be calling at US ports after this date are recommended to begin development of a compliance programme based upon the requirements found in the EPA proposed VGP.

The following information on VGP requirements has been obtained from GMS’ recent Client Advisory (7-08) EPA –NPDES – Vessel General Permit and Compliance: 

The VGP sets 5 effluent limit requirements applicable to all vessels:

• Material Storage
• Toxic and Hazardous Materials
• Fuel Spills and Overflow
• Discharges of Oily and Oily Mixtures;
• Compliance with other Regulations and Statutes.

Additionally, the VGP identifies and regulates 28 specific discharge types that are “incidental to the operation of a vessel”. Many of these effluents, such as oil, bilge water and ballast water discharges, are already regulated and current management practices will likely need little change to be compliant

Most of the other limitations typically are through “Best Management Practices” – deemed practical methods to minimize or eliminate discharge. A Matrix listing these discharge types and the method to control their discharge follows this Advisory.

Some of the 28 listed effluents, such as sonar dome water discharge and gas turbine water wash waste, are not likely to be generated by most commercial vessels involved in trade.