U.S. Environmental Protection Agency (EPA) 2013 Vessel General Permit (VGP) Annual Inspection and Reports

Recently, the U.S. EPA sent email guidance to users of the EPA’s 2013 Vessel General Permit (VGP) Notice of Intent (NOI) system reminding vessel owners and operators that they are required to submit a VGP Annual Report for 2014.

As advised previously, the deadline to submit an annual report for calendar year 2014 to the EPA is 28 February 2015.

This report must be sent electronically, using the EPA’s website.

By early September, the EPA hopes to update their system to allow the VGP Annual Reports to be submitted.

ECM recommends that you submit your VGP Annual Report to the EPA as soon as your vessel completes its last call to the U.S. in 2014.

What Vessel Operators Need To Do Now

ECM recommends that you do the following to avoid potential problems with VGP Annual Report submissions later.

  • Arrange for a comprehensive VGP Annual Inspection conducted by a trained VGP inspector in 2014 as soon as possible but as close to the last U.S. port call for 2014 as possible. Data from the VGP Annual Inspection is required in the VGP Annual Report.
  • Begin assembling data for each of your vessels
    • 2014 drydocking dates (if any)
    • Future drydocking dates.
    • Ballast tank information. Note: all tanks, including capacity, will need to be listed separately in the VGP Annual Report.
    • Anti-fouling paint information including application date.
    • Status of conversion to Environmentally Acceptable Lubricants (EAL) for all oil to sea interfaces
    • Reports of monitoring of discharges by vessels with ballast water or graywater treatment systems
    • U.S. voyage information for 2014. Note: The VGP applies to discharges within “U.S. waters” which are defined as extending to three miles from the baseline, i.e. waters under State jurisdiction.

For further assistance please contact ECM EUROPE 

 

Source:

ECM Client Alert 20-2014

 

 

 

 

 

 

 

 

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