ClassNK TEC-0968

Final-VGP-issued-by-EPAClassNK has issued Technical Information TEC-0968 regarding the final Vessel General Permit which will come into force on December 19, 2013

2013 Vessel General Permit for discharges of pollutants incidental to their normal operation of vessels, published by the U.S. Environmental Protection Agency on March 28, 2013 will become effective on December 19, 2013. This will replace the 2008 Vessel General Permit (2008VGP) which is currently enforced.

The vessels which intend to navigate within 3 miles from US territorial waters except recreational vessels are subject to the 2013VGP.The 2013VGP incorporated fish hold effluent to its coverage and made more stringent regulations for the vessels entering Great Lakes.

Remarkable points added to the permit:

1) Ballast water monitoring

Ballast water numeric discharge limitations and implementation schedule which are aligned with the requirements of USCG rules has been established. In addition to USCG requirements, in case of using ballast water treatment system, monitoring requirements like functionality monitoring, applicable sensors' calibration monitoring, Effluent biological organism monitoring and residual biocide and derivative monitoring for using active substances etc. in treated water are added to ensure that the ballast water treatment system is working correctly. Also, records of the sampling and testing results are required to be retained on-board for at least 3 years in the vessel's recordkeeping documentation.

2) Bilge water monitoring

New build vessel which the keel is laid after 19 December 2013 and greater than 400 gross tons, that may discharge treated bilge water into the waters must sample and analyse the discharges in every year. Bilge water effluent must be monitored at least once in a year in accordance with 2.2.2.1 of 2013VGP. Also, records of the sampling and result of analysis are required to be retained on-board for at least 3 years in the vessel's recordkeeping documentation. The oil content of the effluent should not exceed 15ppm.

3) Gray water monitoring

New build vessel which the keel is laid on or after 19 December 2013, has a maximum crewcapacity greater or equal to 15 and/or any vessel operating on the Great Lakes that may dischargegray water into the waters must collect two samples at least 14 days apart of gray water to bemonitored in accordance with 2.2.15.2 of 2013VGP. Also, records of the sampling and result ofanalysis are required to be retained on-board for at least 3 years in the vessel's recordkeepingdocumentation.

4) Use of an Environmentally accepted lubricants (EAL)

All the vessels subject to the 2013VGP are required to use an EAL that is "biodegradable","minimally-toxic" and "not bioaccumulative" as defined in Appendix A of 2013VGP in alloil-to-sea interferences that may leak oil e.g. stern tubes, thrusters, controllable pitch propellers,rudder stocks and pintle bearings etc. unless technically infeasible.According to the 2013VGP, "technically infeasible" means that;a) No EAL products are approved for use in a given application that meets manufacturerspecifications for that equipment.b) Products which come pre-lubricated (e.g., wire ropes) have no available alternativesmanufactured with an EAL.c) Products meeting a manufacturer's specifications are not available within any port inwhich the vessel calls.d) Change over and use of an EAL must wait until the vessel's next dry docking.Also, with regard to the use of an EAL in the sealing devices for the stern tube or the thruster, theseal ring may swell, and it may have an unfavorable effect on the use of the sealing device for thestern tube or the thruster in case where the seal ring has a high affinity for the EAL.Therefore, if you consider to use an EAL in the currently used sealing devices for the stern tubeor the thruster, you need to inquire to the sealing device manufacturer about whether the currentlyused seal ring is compatible with the EAL or not (whether the EAL is available to it or not) inadvance of using it.

5) Exhaust gas scrubber washwater monitoring

All the vessels subject to the 2013VGP are required to continuously monitor and record pH,PAHs (as available), turbidity, and temperature of exhaust gas scrubber wash water discharge, andto sample and analyse pH, PAHs, Dissolved and Total Metals, and Nitrate-Nitrite exhaust of gasscrubber washwater discharge in every year in accordance with 2.2.26.1 of 2013VGP.Also, records of the sampling and result of analysis are required to be retained on-board for atleast 3 years in the vessel's recordkeeping documentation.

6) Training requirements

Owners/Operators must ensure that all concerned who take part in the management of incidentaldischarges or who may affect those discharges are adequately trained in implementing the termsof this permit. In addition to this, operators should also ensure that appropriate vessel personnel istrained in the procedures for responding to fuel spills and overflows, including notification ofappropriate vessel personnel, emergency response agencies and regu


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