US Issues Final Rules For Vessel Discharges

The US Environmental Protection Agency has tightened permitted discharges from vessels in its waters. The rules have an impact on ballast-water treatment, the use of lubricating oils, hull coatings and discharges from exhaust-gas scrubbers.

The 2013 Vessel General Permit will come into force from December 19 this year, replacing the first VGP which was finalised in 2008. It regulates the same 26 specific discharge categories as the 2008 version, but also covers ballast-water discharge limits for most vessel types.

The ballast-water requirements in the agency’s VGP align with that of the US Coast Guard rules from 2012, but also includes rules to ensure that the ballast-water systems are working properly.
One of the main reasons for reworking the VGP was a court ruling that the agency should include ballast-water regulations, from which it had previously been exempt.

While the criteria for how efficient a ballast-water system is remains similar to the standards written by the International Maritime Organization, the US is not directly accepting approved systems from other IMO member states.

It will, through the US Coast Guard, approve all ballast-water technologies that will be used in its waters. There is a provision, though, for a manufacturer with a system approved by an IMO flag administration to submit that technology to be an alternative management system.

This is a five-year grace period while the manufacturer seeks type-approval from the US. Testing for approval has to be in an approved test facility, of which there are barely any to date. The US VGP is also demanding that shipowners properly train crews to use the system on a US-bound vessel and maintain proper record keeping to demonstrate that the systems are properly maintained and functioning.

Under the US rules, which will possibly reflect the guidelines being developed for the IMO, sampling and monitoring will fall into three categories.

First, the system must be working according to the manufacturer’s requirements, its functionality assessed at least once a month. The details within the VGP are precise. If a system has a filter, a chlorination process or ultraviolet light, the VGP stipulates how this testing should be done.

Second, any sensors used need also to be calibrated annually. The industry has been sceptical about the ability to monitor ballast-water discharges to ensure compliance either with the IMO rules or the similar US ones.

However, sensor calibration and upkeep also refers to sensors used to test ballast-water alkalinity and turbidity.

The VGP points out, however, that while some sensors may require removal and shipment to the manufacturer for recalibration and service, the vessel will be banned from normal ballast-water discharges, even if the treatment system remains operational.

The third level of monitoring referenced by the new VGP is for biological organisms in the discharge.
Once a vessel operating in US waters is required to have a treatment system on board, in all cases by January 1, 2016, it will be required to meet certain standards in terms of the amount of organisms left active in the discharge water.

To ensure compliance, the VGP is establishing some biological indicator compliance monitoring standards.
Samples will be taken, according to guidance the EPA has already established, at least twice in the first year of installation. If the samples remain well below the requirements, a vessel can have samples taken once a year after that.

The VGP states that if high-quality data is not available, samples will be taken four times a year.
Additionally, in light of at least one approved ballast-water treatment system being withdrawn from the market due to an active substance that remained active upon discharge, the US rules now have criteria for the concentration of the active substance in the ballast water when discharged.

This includes chlorine dioxide, chlorine, ozone, peracetic acid and hydrogen peroxide.

The US Vessel General Permit is a requirement for all vessels entering US waters, although there are some exemptions.

The Environmental Protection Agency says it has simplified its reporting procedures to make application easier.

However, some US states have added criteria to the VGP, particularly in the Great Lakes and in relation to ballast-water exchange and the levels of sediment permitted in ballast tanks.

The discharges covered by the VGP include:
1. Deck washdown, run-off and above water line cleaning
2. Bilgewater and oily water separator effluent
3. Ballast water
4. Anti-fouling hull coatings/hull coating leachate
5. Aqueous film-forming foam fire suppressant
6. Boiler and economiser blowdown
7. Cathodic protection
8. Chain locker effluent
9. Lubricants in interfaces with sea — hydraulic fluids for controllable pitch propellers and thrusters, stern tubes, stabilisers, rudder bearings and wire ropes subject to immersion
10. Brine
11. Elevator pit effluent
12. Firemain systems
13. Freshwater lay-up
14. Gas turbine washwater
15. Greywater
16. Motor gasoline and compensating discharge
17. Non-oily machinery waste water
18. Refrigeration and air condensate discharge
19. Seawater-cooling overboard discharge
20. Seawater-piping biofouling prevention
21. Boat engine wet exhaust
22. Sonar dome discharge
23. Underwater ship husbandry
24. Welldeck disharges
25. Graywater mixed with sewage
26. Exhaust gas scrubber washwater discharge
27. Fish-hold effluent.

for further information see Lloyd’s List


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