FREQUENTLY ASKED QUESTIONS

RE: USA ports - sewage holding tank

Q.
If vessel does not have sewage holding tank, it appears in accordance with the VGP, the vessel can not be
accepted to enter US Ports.
A. Sewage is not part of VGP as this is covered by different legislation. See VGP 1.2.3 Limitations on Coverage.
Sewage (1.2.3.2) comes under 33 CFR 159 Marine Sanitation Device. This allows approved treatment plant or holding
tank.

Questions regarding entries to VGP log book:

Q. 'Voyage Log' - enter US voyages only or all?
A. The permit is applicable in US Territorial waters only (3 mile limit). A vessel however on regular voyages to USA
should maintain the voyage log at all the times. A ship returning to US waters after a break should start from when
receiving voyage orders (i.e. returning to compliance)
Q,

'Chain Locker inspection' - all or in US waters only?

A. Chain locker inspections are required in dry-dock after cleaning (2.2.8) and all vessels must ensure a dry-dock
certificate is obtained (4.1.4). Chain lockers must not be pumped out in permit waters. The regulation states: For
vessels that regularly sail outside waters subject to this permit, if technically feasible, periodically clean, rinse, and/or
pump out the space beneath the chain locker prior to entering waters subject to this permit (preferably mid ocean).
A vessel is not required to inspect other than in dry-dock.
waters (i.e. emergency).

Section 8 of the record book is only for discharges in permit

Q. Graywater' - vessel's system operating permanently, no holding tank fitted.

What entries to be done ? (please give an example)
A. Very few non passenger vessels can store graywater, hence the BMPs in place for this (copied below)
All vessels must minimize the discharge of graywater while in Port.
Graywater must be stored onboard if the vessel has the capacity to do this.
Discharge of graywater is not permitted on the US Great Lakes.
Vessels that can store graywater must only discharge this when greater than 1 nm from shore while the vessel is
underway.
Vessel must use phosphate free and non-toxic soaps and detergents for any purpose.
Cooking oil must not be discharged with graywater. As much food and oil residue as practicable must be removed
from plates prior rinsing.
These BMPs must be complied with. Regarding log, suggest daily entry with estimate of quantity,
discharge techniques are limited, however if BMPs employed, unlikely any sheen or discolouration.

Minimizing

Q. Please clarify Ch. 2.2.26 and 5.5.1 of VGP manual. In 2.2.26 it is stated that low sulfur fuel to be used when in
waters covered by this permit in respect to EGS washwater discharge. However in part 5.5.1 we can read: "For vessels
which have an inert gas system, the effluent produced from inert gas scrubbers may be discharged into waters subject
to this permit" - but it does not specify type of fuels to be applied for flue gas.
The question is whether we should run our boilers with low sulfur fuel only during discharging in any US port, since
boiler flue gas for IG is supplied via scrubber? I understand that it concerns now all US ports not only these ones in
present US SECA?

A.
2.2.26 is a main engine or generator exhaust gas scrubber. Guidelines as per MEPC 170(57) must be complied
with. Not IGS scrubber.
5.5.1 is for IGS scrubbers and there are no special requirements. However: Vessel owner/operators must minimize
the discharge of effluent produced from inert gas scrubbers if feasible for their vessel design.

Q. Is there a need to have divers during the annual inspection?

A.

No, but if a diving inspection is done for some other reason, its results should be documented

Q. The VGP requires a watch inspection around and behind the vessel. How can this be implemented in practice?
A. For example, when you walk out on deck, have a look around that nothing is going off the ship that must not be,
that nothing trails behind etc

Q. The quarterly inspections require visual sampling of accessible waste streams. What is considered accessible?
A. EPA does not require making sampling ports on waste streams if not accessible for visual sampling which can be
done by putting a bottle/jar out and collecting a portion of a waste stream for visual examination

Q. Where can all waters with special protection status be found in the VGP?
A. In part 12 of the VGP are all federally protected waters , however EPA States that the list is not complete, some
individual states waters may not be there but includes all Marine Parks, Reserves, Sanctuaries etc.

Q.

Who will enforce the VGP?

A.

The USCG as per the MOU with the EPA click here

Q. What are phosphate free and non-toxic soaps and detergents?

A. Non-toxic soaps are those that do not exhibit potentially harmful characteristics and not labeled as Toxic. Phosphate
free soap is considered to contain 0.5% by weight or less of phosphates or derivatives of phosphates.
These products are normally labeled green, organic or environmentally friendly. An example of a typical product is:
SUNSHINECONCENTRATECLEANER
Safeforpeople,animals,plantsandtheenvironment.Allpurpose,concentratedcleaneristoughondirt,greaseandgrime,yetit
wontharmtheenvironmentoryourfamily.Itsbiodegradablecleaningandsudsingagentsbreakdowneasily,helpingtoprevent
foaminginlakesandstreams.Highlyconcentrated,thiscleanerisgoodforjustabouteverycleaningneedimaginablehousehold,
personal,autoandothers.It's100%organic,biodegradable,nontoxic,nonirritating,nonmagnetic,andnonvolatile.Containsno
pollutingborates,phosphates,ornitrates
These products are becoming more popular and are generally available in most countries.

Q. Do the VGP requirements have to be complied at for calls at the offshore port of LOOP and also the offshore
lightering areas in the Gulf of Mexico?
A. Part 1.2.1 of the Permit states that: This Permit is applicable in waters subject to the permit. These waters are
"waters of the United States" which extend to the outer reach of the 3 mile territorial sea
A ship that does not enter "waters of the United States" does not need permit coverage.
As both LOOP and the lightering areas are out with territorial waters, compliance is not required. EPA has confirmed
this is correct.

Q. In the VGP Logbook, ref 4.2 Section 8 (ix) Graywater, this requires estimated volume and location of graywater
discharged while in waters subject to this permit. What is a reasonable estimate for graywater discharge?
A. EPA estimates the volume of graywater generated by a vessel is in general, 30 85 gallons (110 to 320 litres
approx) per person per day. US Navy designers use a generation standard of 50 gallons per person per day when
constructing graywater collection systems.

Q. Who carries out the inspections, completes the records and signs the forms?
A. The Master as person in charge has overall responsibility for maintenance of the Vessel General Permit and is the
key signatory as required by CFR 40 Part 122.22. Inspections Records must be signed by the person conducting the
inspection, if not the Master. Persons conducting the inspection must be either be a signatory or be his duly authorized
representative.
The Chief Engineer as head of the Engine department is a duly authorized representative.
The Chief Officer as head of the Deck department is a duly authorized representative.
The Master must issue an authorization letter to any other person carrying out inspections as required by section 4.
The routine inspections (weekly/quarterly) should be carried out by the department heads. Items such as the voyage
record can be delegated to the Second Officer.
All persons onboard must be made aware of the requirement for their individual working areas e.g. galley staff and
minimizing graywater contamination.
All persons must be aware of their responsibility to report violations.

Q. The VGP requires that anti-fouling hull coatings not subject to FIFRA registration (i.e. not produced for sale and
distribution in the United States must not contain any biocides or toxic materials banned for use in the United States
(including those on EPAs List of Banned or Severely Restricted Pesticides). This requirement applies to all vessels,
including those registered and painted outside the United States. What evidence is required?
A. Vessels must ensure that a certificate is obtained for anti-fouling applied. Alternativly the paint specification
showing that it is suitable for use in USA.