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Vessel-General-Permit

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[MUSIC PLAYING] [AUDIO OUT] [MUSIC PLAYING] As seafarers, we base our livelihood on the health of our oceans and waterways for our industry, commerce, recreation, and trade to survive. We must ensure that our operating practices, our vessels, and our ports protect the environment and sustain the seas. More and more the marine environment, our air and water, our vessels and ports, is subject to oversight and regulation. The United States Environmental Protection Agency, the EPA, has lately put into effect a new protocol, the Vessel General Permit or VGP. In this 15-minute video, we'll introduce the VGP permit and compliance process. We'll describe what's covered and the types of discharges to look out for and will assist you in getting started with registering, record keeping, and reporting. We'll also give you four practical tips from seafarers and organizations already complying with VGP on how to incorporate it into your ongoing best practices. [MUSIC PLAYING] You cannot comply with this permit from the office. You have to have people on board who understand the requirements and work those processes, particularly the inspection and monitoring requirements. Jon Turvy works with the cruise industry to ensure compliance with environmental regulations. Among the latest is the Vessel General Permit process, VGP. If you look at this permit, and you really look at what's required in terms of the operating practices, they're not that significantly different than what most people are already doing. Specifically, the Vessel General Permit is a license granted by the United States Environmental Protection Agency, the EPA. It regulates any of 27 incidental discharges into US waters within 3 nautical miles of shore. Failure to comply with VGP can bring fines of up to $10,000 per violation and imprisonment. VGP doesn't prohibit discharges from ships. It just says, we must use best practices in controlling what we discharge into the environment, and VGP doesn't apply to recreational vessels, to vessels under 79 feet, and to fishing vessels, with the exception of their ballast water. What the Notification of Intent does is put that vessel into the universe of regulated vessels so EPA can track them, and if you don't have coverage under the permit, you are in violation of the Clean Water Act. Step number one in VGP compliance is to file a Notice of Intent with the EPA. The NOI can be filed electronically via the EPA website. An NOI Compliance Regime must be filed for each vessel in a fleet that is 300 gross tons or more or has the ability to hold or discharge more than 8 cubic meters of ballast, effectively putting it under EPA license. What people are concerned about is with sort of the additional inspection and record keeping requirements that come along with rules like this. Oh boy, more paperwork. You can hear the complaints already, but those who've worked with VGP say if you're already doing good housekeeping, inspection, and reporting you won't find VGP much of an extra burden at all. In fact, VGP incorporates many of the inspection and reporting requirements already in place with the United States Coast Guard, with the IMO and with MARPOL. The few new forms and procedures created can be easily incorporated into a preexisting SMS, Safety Management System. [MUSIC PLAYING] You may now stop or pause the program here if you wish. [MUSIC PLAYING] For an up close look at VGP, we took a ferry boat ride on Washington State's Puget Sound, home to one of the world's busiest ferry systems. OK, Dave, it looks like we're on the upper car decks here. What we have over here-- Like other environmental regulations, VGP focuses mainly on what you can and can't put overboard from your vessel into US waters, with an emphasis on incidental discharges that occur as part of a vessel's normal operations. First, of course, there are some discharges which are not covered including sewage, oil of any type, garbage or trash, medical waste, and any hazardous materials. I'd like to just make a comprehensive deck round to ascertain the conditions of our scuppers and our car deck to make sure that we're staying in compliance with our Vessel General Permit. We asked the Washington State Ferry Systems Dave Jamison and State Department of Ecology's Guy Grayson to guide us through the Ferry Wenatchee with VGP compliance in mind. We have a very comprehensive safety management system that covers discharge and maintenance of the vessels and, strictly speaking, most of the items under the Vessel General Permit are already covered under our Safety Management System. Different areas of VGP will apply depending on your vessel type, a ferry, a barge, a container ship, a cruise liner, will all have their own specific operations and processes to monitor. For instance, a ferry like this one carries no ballast water, so VGP monitoring of ballast water does not apply on this boat. It does on others. You'll also need to make sure you're meeting specific state and Indian Country Lands requirements. VGP compliance depends on regular inspection, cleaning, maintenance, reporting, and repair. Deck runoff is a primary concern for virtually all vessels, making sure no chemicals, oils, or other toxic substances escape overboard. We looked at hydraulic systems where rescue boats are lowered and raised to ensure that no fluids might be escaping, and we paid special attention to hose connections where wastes are pumped off the boat to tanks on shore to ensure no leakage or runoff and whether clean-up kits and systems were in place should there be a spill or overflow. Below decks all the liquids involved in cooling, cleaning, lubricating, and preventing corrosion are potential hazards if they escape into the environment. Sources for these must be regularly inspected and any discharge incidents reported, including the drive shafts, bearings, and seals in the vessel's propulsion systems. Of the 27 discharge types covered, the most common are deck runoff, deck and hull wash down, bilge water, ballast water, hull coating leachate, underwater hull cleaning, and gray water. Other discharge types include firefighting foam, boiler blow down, cathodic protection, chain locker effluent, hydraulic and lubricating fluids, desalination brine, and exhaust scrubber waste water. The permit itself has a pretty extensive system for conducting vessel inspections, recording the results of those inspections, and documenting the corrective actions for deficiencies that you may find. You may now stop or pause the program here if you wish. [MUSIC PLAYING] VGP is not a huge new burdensome process. It can be incorporated into your standard cleaning, maintenance, inspecting, and reporting regimen fairly simply. With that in mind, here are four tips for getting started. Tip number one, read the permit carefully and determine both your shore-side and on-board responsibilities. So get started. That's really the bottom line is get started, and the place I would for sure get started is with the routine vessel inspections that occur either once per voyage or once per week. On board, incorporate VGP into your regular inspection regimen and best management practices. On shore, identify the discharge types you need to track and report on vessel by vessel. Submit the appropriate EPA documents, such as the Notice of Intent, the NOI. Make sure you comply with any applicable state requirements. Ensure that correct records are maintained and reports submitted and that management certifies these submissions. Tip number two. Generate the appropriate procedures, forms, checklists, and training materials to ensure VGP compliance. The paperwork burden is really very minor. The daily entry in the wheelhouse log and the annual inspection report by the engine crew and any incidental reports, including the discharge log in the engine department. Those are just minor additional paperwork burdens. It's not really burdensome. Here today we got the Vessel General Permit for the Wenatchee. That's correct. Inside here we have all the documentation that is required for the Chief. Procedures, training, and checklists are important. They should be customized to the vessel type. On the ferry we visited, for instance, only 7 of the 27 VGP discharge types are relevant and regularly inspected and reported on. Generate procedures and documentation, including procedures for training your officers and crews on the specifics of VGP. Make the necessary changes or additions to inspection routines. Use checklists for the discharges covered and reminders of the reporting requirements. If necessary, you may wish to prepare a standalone VGP manual containing your procedures and documentation. Tip number three. Integrate VGP procedures into your ongoing best practices and Safety Management System. If you have to clean up spills all time because you have faulty hose connections, you're wasting your energy. It's better to do the proactive maintenance, correct the problem, and that's a big part of VGP and Safety Management Systems are doing good housekeeping, doing inspections so you know where you problems are, taking corrective actions, doing your reporting or your logging based on your Safety Management System or VGP and then reporting. Not only are most of the inspections required by VGP just good housekeeping, they actually can help lessen workloads, increase efficiency, and identify potential problems before they become problems. For example, as you clean your hull better or more often, your fuel costs go down. If you find more environmentally friendly detergents or deck wash you find, oftentimes you don't need to wash as often, or you can wash more often without triggering some restrictions that some ports may have. Integrate VGP into your Maritime Best Practices and your Safety Management System. These should already cover material storage, handling of toxic and hazardous wastes, fuel spills and overflow, discharges of oil and oily mixtures, and general compliance with regulations applicable to incidental discharges. Tip number four. Set up your inspection and reporting schedule and your procedures for taking corrective actions in case of accident, spillage, or other noncompliance. One of the features of this permit is the submission of an annual Report of Noncompliance. This report requires vessel operators to report all of the things, all of the elements of the permit, that they did not comply with through the course of the year, and that report must be signed and certified by a responsible corporate official. All instances of noncompliance must be reported at least once per year to the regional office of the United States Environmental Protection Agency. The Vessel General Permit reflects our heightened concern for the safety and integrity of our waterways. It need not be intimidating, restrictive, or a paperwork burden. In fact, our VGP experts have suggested that the best practices incorporated into VGP can actually contribute to more efficient operations, better housekeeping, and a continually improving Safety Management System. Follow the basics introduced in this program, read the permit carefully, generate the appropriate compliance tools, integrate VGP into your ongoing Safety Management System and inspect, monitor, report, and follow up with corrective actions. Your reward will be a cleaner, better functioning vessel and preservation of the waterways that are crucial to our operations and our livelihoods. [MUSIC PLAYING]

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Duration: 15 minutes and 31 seconds
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Language: English
License: Dotsub - Standard License
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Views: 6
Posted by: maritimetraining on Feb 8, 2017

Vessel-General-Permit

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