Sewage Discharge Requirements for a Canadian Flagged vessel entering US Waters

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Sewage Discharge Requirements for a Canadian Flagged vessel entering US Waters

Postby aron » Mon Feb 19, 2018 12:38 pm

Hello to All,
I was wondering if anybody would be able to provide some input into the requirements and regulations for Canadian Flagged vessel entering US Waters in relation to sewage systems and the discharge of sewage.
The vessel that I am discussing has a black water holding tank, but only enough for 2-4 days at sea before being requried to be discharged over-board.
I have been looking at MARPOL, EPA and USCG websites to obtain more clear information. ... d-laws-and
At present our vessel is looking at spending up to 4 weeks operating within US waters and I was wondering if anyone else has had similar experiences and what the requriements were for your vessel.
The sewage is treated before discharge with our current system but we do not have a long endurance for holding sewage.
The option is available to us to install a much larger holding tank for black water, but I was wondering if there was a simpler option of possibly having to install a new piece of treatment equipment that would allow is to operate within this region.
Any thoughts or ideas would be greatly appreciatted,

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Big Pete
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Re: Sewage Discharge Requirements for a Canadian Flagged vessel entering US Waters

Postby Big Pete » Tue Feb 20, 2018 7:55 am

If you look in Marpol you will see the regulations regarding sewage and Grey/Gray water discharges for all vessels sailing outside their own Coastal Waters..
Basically raw sewage can be discharged into the Sea but you have to calculate the volume discharged per hour and the ship's speed per hour and not exceed the maximum volume of raw sewage per Mile. So, as the pump capacity ( pumping rate is usually fixed you have to make sure the vessels speed does not drop below that required for the pumping rate. I think the US Coastguard will also require you to Chlorinate the Discharge to kill all Bacteria, so you will have to treat the Holding Tank with Chlorine Tablets and allow enough time for the Chlorine to be dispersed throughout the tank and to kill all the Bugs before you pump out. Ideally I would dose the Holding Tank with Chlorine Tablets immediately after pumping it out to give it the longest possible contact time, and, because Chlorine is destroyed by contact with air, a top up dose shortly before discharging.
You can only do this a certain distance from Land and I am not sure how far off the US Coast you have to be to do this under the latest regs.
Check with the Ship's Agent in the USA what the regs are Now. The Bridge by Law, must have a copy of Marpol, look at both lots of regs and you will have to comply with the higher of the 2 standards if there is a difference.
With a holding tank you will have to Hold all the sewage in the tank in Port and within (if it hasn't changed), 3 Miles from Land.
Under International Law all Foreign going ships must be fitted with a MARPOL sewage flange on Deck to enable you to pump all your sewage ashore when you arrive in Port and as required during your Port stay so that you have sufficient space to enable you to hold the sewage until you can legally pump it overboard.
I would inform the Bridge every time that you pump sewage ashore that they can record the time position course and speed at start and end of discharge and you must record the same and the quantities in the ER Log Book.

When you are way from Land Gray water can also be discharged into the Sea but in recent years some Ports refuse to allow Grey water to be discharged within the Port Limits so that must all be retained onboard even if you have the latest all singing all dancing sewage treatment plant.
On one Old ship I sailed on a few years ago, we found that the Port we were going to would not allow the discharge of any treated sewage or Grey water to the Sea so we had to rig all the Grey water lines to run into a Ballast tank and hook up the sewage treatment discharge to the MARPOL sewage Flange and through a hose into a big tank on the Quayside.

Your cheapest option would be to lash a big tank on Deck and pump your waste into it. If you can crane it ashore to be emptied, very good otherwise you will need a sewage pump on Deck to pump it to a road tanker as required. I expect that it will be expensive and that the US might require all the sewage to be incinerated as a potential Bio Hazzard as it does not originate from a US Flag ship.

Installing a full sewage treatment Plant would be a major Dry Dock job and very expensive. Nowadays you have to take samples of the treated sewage you are discharging and monitor them for Chlorine concentration and "B.O.D." Biological Oxygen Demand, the amount of Oxygen that will be taken out of the Sea in order to fully Bio Degrade the treated sewage pumped overboard. We can't suffocate all the wee beasties living in the Sea.
So using one would be a steep learning curve and usually they take about a week for the "Bugs" inside the reactor to multiply enough to digest all the sewage. You would also have to remove and dispose of all cleaning materials containing Chlorine, Ammonia, Bleach and the like because if they go down the toilets they will kill all the Bugs in the reactor and stop the system working until all the poison has been flushed out and then it will take a week for the Bugs to regrow.
Remember US Coastguard can come on board any time and take samples from the system and send them to a Lab to make sure you are complying.

The key point in the US Regs appears to be: -

"While sewage is defined as a "pollutant" under the CWA, sewage from vessels within the meaning of section 312, is exempt from this statutory definition [33 U.S.C. 1362(6); see also 33 U.S.C. 1322(a)(6) (definition of "sewage")]. Sewage from vessels also includes graywater for commercial vessels operating on the Great Lakes and is also exempt [33 U.S.C. 1322(a)(10) (definition of "commercial vessels" for purposes of section 312)]. Therefore, vessel owners/operators are not required to obtain NPDES permits before discharging sewage. However, vessels discharging graywater and sewage in one effluent stream, and are not otherwise "commercial vessels" under CWA section 312, are required to follow the requirements outlined in CWA section 312 and the VGP."

Unfortunately the link to MARPOL is too vague to be any help to you and you have to BUY the information from MARPOL however your ship and the Managers Office should both have up to date copies of MARPOL. If you go down the Sewage Treatmentroute the plant must be certified by the US Coastguard if you want to use it in US waters. Historically the USA insisted that treated sewage was Chlorinated before discharge, other Countries didn't want to poison their waters with Chlorine and insisted that the treated sewage WAS NOT treated.

Hope you find this useful.
Big Pete
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D Winsor
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Re: Sewage Discharge Requirements for a Canadian Flagged vessel entering US Waters

Postby D Winsor » Tue Feb 20, 2018 12:21 pm

The USCG will have the most up to date information as where the dumping of treated waste water and waster water holding tanks is permitted. Many of the most recent up to date electronic charts have overlays indicating the zones where waste water must be held and holding tanks can be dumped within the Great Lakes System. New York, Michigan and Wisconsin have the most restrictive rules with respect treated waste water discharges from the MSD or Marine Sanitation Device. There are also no zones within Canadian Territorial Waters where the discharge of untreated waste water is permitted.
There are few restricted zones on the Canadian side of the border for the discharge of treated waste water but just about all the US states that border the Great Lakes do not permit the dumping of any waste water including Black, Grey or Galley waste water. All waste water must be treated in the MSD and held on board while in transit through State controlled waters or discharged to a certified shore facility unless otherwise stated on the VGP or Vessel General Permit. You will also be required to record in the official Deck and Engineroom logs the Latitude and Longitude of the Holding tank discharges as well as emergency discharges within restricted zones.
I would also have on board the results of the most recent lab analysis of your waste water discharge available for both USCG and State authorities
If you vessel is SOLAS Class as opposed to Great Lakes Class as the rules are much more strict for SOLAS vessels even the discharge of water ballast is either severely restricted or in some cases not even permitted.
If your vessel has a small holding tank and you run in to a capacity issue you could have to resort to shutting off non essential water services such as washing machines and dish washers to reduce the amount of water being dumped in the holding tank
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Re: Sewage Discharge Requirements for a Canadian Flagged vessel entering US Waters

Postby The Dieselduck » Fri Mar 16, 2018 6:25 pm

From what I understand the apparent inaction by the regulators in the US forced a lawsuit which the government lost, and the US EPA was pushed on its heels to enforce its laws, and to come up with some action. Their action was the VGP, which like DWinsor states is quite a piece of work. There is quite a bit of activities especially with paperwork around the VGP, including considerable paperwork, weekly inspections, and logging, crew training, etc.

Essentially - this may have changed - but like DWinsor says there is no discharge overboard. Usually the grey water is the problem, as black water treated by an approved MSD (Marine Sanitation Device) is okay, as I understand it.

In practicality, for the length of time we were operating in US waters, we would hold our waste, until we tip toed back into Canadian waters, as I was not sure which state you could or could not, and what to discharge.

here is the link to the US EPA's VGP website. ... d-laws-and
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