MarPol Squared

As you may be aware, the US Environmental Protection Agency was sued by environmentalist groups, and subsequently was ordered to implement regulations under the Clean Water Act which will affect discharges from vessels during normal operation. As a result, most commercial operators in US waters, are required to have a Vessel General Permit, which dictates various limits on 26 various streams of effluent from vessels.

This new set of requirements are now in effect, and have been implemented rather quickly. The regulations stipulate various test, training and checks to be carried out on the various discharges but more importantly, stipulates further record keeping. Record keeping is of course the critical point in this exercise, seeing how in the past, US law enforcers use the Oil Record Book to prosecute, ultimately, MarPol infractions. The following waste streams are now required to fall under the VGP…

  • Deck Runoff and Above Water Line Hull Cleaning
  • Bilgewater/Oily Water Separator Effluent
  • Ballast Water
  • Anti-fouling Leachate from Anti-Fouling Hull Coatings/Hull Coating Leachate,
  • Aqueous Film Forming Foam (AFFF)
  • Boiler/Economizer Blowdown
  • Cathodic Protection
  • Chain Locker Effluent
  • Controllable Pitch Propeller and Thruster Hydraulic Fluid and other Oil Sea Interfaces including Lubrication discharges from Paddle Wheel Propulsion, Stern Tubes, Thruster Bearings, Stabilizers, Rudder Bearings, Azimuth Thrusters, and Propulsion Pod Lubrication
  • Distillation and Reverse Osmosis Brine
  • Elevator Pit Effluent
  • Firemain Systems
  • Freshwater Layup
  • Gas Turbine Wash Water
  • Graywater
  • Motor Gasoline and Compensating Discharge
  • Non-Oily Machinery Wastewater
  • Refrigeration and Air Condensate Discharge
  • Motor Gasoline and Compensating Discharge
  • Seawater Cooling Overboard Discharge (Including Non-Contact Engine Cooling
  • Water; Hydraulic System Cooling Water, Refrigeration Cooling Water)
  • Seawater Piping Biofouling Prevention
  • Boat Engine Wet Exhaust
  • Sonar Dome Discharge
  • Underwater Ship Husbandry
  • Welldeck Discharges
  • Graywater Mixed with Sewage from Vessels
  • Exhaust Gas Scrubber Washwater Discharge

These new regulations are on top of existing MarPol requirements, and the EPA estimates that approximately 61,000 domestically flagged commercial vessels and approximately 8,000 foreign flagged vessels may be affected by this permit.

You can read about it at the US EPA‘s website, and view their pdf presentation, and also participate in an initial discussion we had on it in The Common Rail forum area a few months back.

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