Transcript VGP Compliance Guidance Manual Training

Vessel General Permit
Compliance Guidance
Manual Training
Sarah K. Branch
Manager of Regulatory Affairs
Objectives of Training
• Provide a summary of the Vessel
General Permit (VGP) and how it
affects the industry
– What, Who, When, Where, & How
• Provide an overview of the VGP
Compliance Guidance Manual
• Demonstrate how to use the VGP
Compliance Guidance Manual
Vessel General Permit
Summary
Vessel General Permit Summary:
What is the VGP?
• National Pollutant Discharge Elimination
System (NPDES) permit
• Issued by the U. S. Environmental
Protection Agency (USEPA) as a result of
a Federal Court ruling
• Establishes permit limits and conditions
on 26 wastewater discharges incidental
to the normal operation of vessels that
were previously exempted by the USEPA
Vessel General Permit Summary:
When is the VGP Effective?
• USEPA issued the VGP on December 19,
2008
• U.S. Federal Court extended the effective date
60 days
• EPA published the Final VGP on February 6,
2009
– All vessels subject to coverage under VGP are
subject to the compliance requirements and
conditions as of February 19, 2009
• All vessels subject to VGP were automatically
covered as of the VGP effective date.
– However…certain vessels must submit a Notice of
Intent (NOI) between June 19 and September 19,
2009 to maintain coverage.
Vessel General Permit Summary:
What Vessels are Subject to the
VGP?
• All non-recreational vessels 79 feet in
length or longer
• Exceptions include:
– Fishing vessels that do not discharge
ballast water
– Vessels of the armed forces
• Both non-recreational vessels less
than 79 feet in length and commercial
fishing that discharge ballast water are
covered under VGP for discharge of
ballast water only.
Vessel General Permit Summary:
Where Does the VGP Apply?
• Discharges to the waters of the United
States
– Inland waters such as rivers, lakes,
streams, etc
– Also includes Territorial Seas:
• defined as “the belt of the seas
measured from the line of ordinary low
water along that portion of the coast which
is in direct contact with the open sea and
the line marking the seaward limit of inland
waters, and extending seaward a distance
of 3 nautical miles.”
• Discharges beyond the Territorial
Seas are not regulated by the VGP
Vessel General Permit Summary:
What are the Consequences?
• Any false statement, representation, or
certification required by VGP
– Fines ($10,000 per violation)
– Cease and desist orders
– Jail time (up to 6 months per violation)
• Any knowing falsification or rendering
of inaccurate information, or tampering
with any monitoring device or method
required by VGP
– Fines ($10,000 per violation)
– Jail time (up to 2 years per violation)
• Repeat offenses after first conviction
– Fines ($20,000 per day of violation)
– Jail time (up to 4 years per violation)
Vessel General Permit Summary:
How Do You Comply with the VGP?
• Complete vessel assessment
–
–
–
–
Vessel Class
NOI (if required)
Covered Discharges
Chart Course for Vessel Specific Program
• Key factors to maintain compliance
– Best Management Practices (BMPs)
– Recordkeeping
– Reporting
• VGP Compliance Guidance Manual
VGP Compliance Guidance
Manual
Overview
VGP Compliance Guidance Manual Overview:
VGP Compliance Manual Objectives
• Provide prescriptive program for selfimplementing permit
• Provide sequential stepwise
procedure for vessel specific program
• Provide a consistent reference basis
for all OMSA members
• Decipher EPA “jargon” into common
usage terms
• Streamline process of vessel analysis
VGP Compliance Guidance Manual Overview:
VGP Compliance Manual
Organization
• Section 1 - Introduction
• Section 2 - Vessel Assessment Form
• Section 3 - Permit Requirements
• Section 4 - Forms and Instructions
• Section 5 - Appendices
VGP Compliance Guidance Manual Overview:
Section 1 – Introduction
• Disclaimer
• How the manual is organized
• Explanation of how to use the manual
• Summary of the VGP
VGP Compliance Guidance Manual Overview:
Section 2 – Vessel Assessment Form
• Vessel Type
• Notice of Intent (NOI) Applicability
• Types of Discharges
• Additional Information
VGP Compliance Guidance Manual Overview:
Section 3 – Permit Requirements
• Requirements Applicable to All Vessels
• Discharge Specific Requirements
• Vessel Class Specific Requirements
• State Specific Requirements
VGP Compliance Guidance Manual Overview:
Requirements Applicable to All
Vessels
• Material Storage
• Toxic and Hazardous Materials
• Fuel Spills/Overflows
• Discharges of Oil Including Oily
Mixtures
• Compliance with Other Statutes
and Regulations
VGP Compliance Guidance Manual Overview:
Discharge Specific Requirements
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Deck Washdown and Runoff and
Above Water Line Hull Cleaning
Bilgewater
Ballast Water
Anti-Fouling Hull Coatings
Aqueous Film Forming Foam (AFFF)
Boiler/Economizer Blowdown
Cathodic Protection
Chain Locker Effluent
Controllable Pitch Propeller and
Thruster Hydraulic Fluid and Other Oil
to Sea Interfaces…
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
Seawater Cooling Overboard
Discharge
Seawater Piping Biofouling Prevention
Boat Engine Wet Exhaust
Sonar Dome Discharge
Underwater Ship Husbandry
Discharges
Welldeck Discharges
Graywater Mixed with Sewage from
Vessels
Exhaust Gas Scrubber Washwater
Discharges
VGP Compliance Guidance Manual Overview:
Discharge Vessel Class Specific
Requirements
• Large Cruise Ships (N/A to OMSA)
• Medium Cruise Ships (N/A to OMSA)
• Large Ferries (N/A to OMSA)
• Barges
• Oil or Petroleum Tankers
• Research Vessels
• Emergency Vessels (Fire Boats, Police Boats)
• Vessels Employing Experimental Ballast Water
Treatment Systems
VGP Compliance Guidance Manual Overview:
State Specific Requirements
• Additional permit limits and conditions
established by individual US states upon
approval of the VGP under CWA
– Additional conditions only apply within waters
under the jurisdiction of the applicable State
• 28 US States, Territories, and Indian Tribal
Lands approved the VGP with additional
conditions
– States of Interest – FL, CA, HI, NY
• 27 US States approved the VGP without
additional conditions
– Gulf Coast States – TX, LA, MS, & AL
VGP Compliance Guidance Manual Overview:
Section 4 – Forms & Instructions
• Applicability
• Recordkeeping/Inspections/Logs
• Reporting
VGP Compliance Guidance Manual Overview:
Applicability Forms
• Notice of Intent (NOI)
– Vessels equal to or greater than 300
gross tons and/or
– Ballast tank capacity of 8 cubic meters or
more
• Notice of Termination Form
(NOT)
– Only apply for those vessels that have
submitted an NOI
– New owner has taken over vessel
– Permanently ceased vessel operations
– Obtained coverage for all discharges
under another separate NPDES permit
VGP Compliance Guidance Manual Overview:
Recordkeeping/Inspections/Logs
•
•
•
•
•
•
•
•
•
•
•
•
•
Owner/Vessel Information
Routine Visual Inspection
Quarterly Visual Inspection
Comprehensive Annual Vessel Inspection
Dry Dock Inspection
Barge/ Tanker Supplemental Inspection
Ballast Water Discharge Recordkeeping
Experimental Ballast Water Treatment System
Corrective Action
Voyage Log
Maintenance Log
Discharge Log
Training Log
VGP Compliance Guidance Manual:
Reporting
• Annual Non-Compliance Report
• Spill/Release Report
• One Time Permit Report
• Discharge Monitoring Report
VGP Compliance Guidance Manual:
Appendices to VGP Compliance
Manual
• Appendix A: Final Vessel General
Permit (version 2/5/09)
• Appendix B: NOI Documentation
• Appendix C: Completed
Recordkeeping Forms/Documents
• Appendix D: Completed Reports
• Appendix E: Ballast Water
Management Plan(s)
How To Use the VGP
Compliance Guidance
Manual
How To Use the VGP Compliance Guidance Manual:
Step 1 - Complete Vessel Assessment
Form
Vessel General Permit Assessment Form
Vessel Owner/Operator:
OMSA Marine Services, LLC
Name of Vessel:
OMSA 1
Date Assessment Completed:
April 30, 2009
Vessel Type:
Tanker
Barge (See Section 3.3.1)
Oil or Petroleum Tanker (See Section 3.3.2)
Research Vessel (See Section 3.3.3)
Emergency Vessel (See Section 3.3.4)
Vessel Employing Experimental Ballast Water Treatment System (See Section 3.3.5)
Vessel General Permit (VGP) and Notice of Intent (NOI) Applicability
1. Is the non-recreational vessel less than 79
feet (24 meters) and discharges ballast
water?
2. Is the non-recreational vessel 79 feet (24
meters) or longer?
3. Is the vessel 300 gross tons or greater?
4. Does the vessel have the capacity to hold 8
cubic meters (2113 gallon) or more of
ballast water?
Types of Discharges:
No
Yes
If Yes, VGP applies.
No
Yes
If Yes, VGP applies.
No
Yes
No
Yes
If you answered Yes to either Question 3 or Question 4, a
Notice of Intent (NOI) must be submitted (see Section 4.1).
(check all that apply)
X
Deck Washdown and Runoff & Above Water Line Hull Cleaning
(Complete Section 3.2.1)
X
Bilgewater
(Complete Section 3.2.2)
X
X
Ballast Water
Anti-Fouling Hull Coatings
(Complete Section 3.2.3)
(Complete Section 3.2.4)
X
Aqueous Film Forming Foam
(Complete Section 3.2.5)
Boiler/ Economizer Blowdown
(Complete Section 3.2.6)
Cathodic Protection
Chain Locker Effluent
(Complete Section 3.2.7)
(Complete Section 3.2.8)
X
Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil/Sea Interfaces (Complete Section 3.2.9)
X
Distillation & Reverse Osmosis Brine
Elevator Pit Effluent
(Complete Section 3.2.10)
(Complete Section 3.2.11)
Firemain systems
(Complete Section 3.2.12)
Freshwater Layup
(Complete Section 3.2.13)
Gas Turbine Wash Water
Graywater
(Complete Section 3.2.14)
(Complete Section 3.2.15)
Motor Gasoline and Compensating Discharge
(Complete Section 3.2.16)
Non-Oily Machinery Wastewater
(Complete Section 3.2.17)
Refrigeration & Air Condensate Discharge
Seawater Cooling Overboard Discharge
Seawater Piping Biofouling Prevention
(Complete Section 3.2.18)
(Complete Section 3.2.19)
(Complete Section 3.2.20)
Boat Engine Wet Exhaust
(Complete Section 3.2.21)
How To Use the VGP Compliance Guidance Manual:
Step 2 – Determine Additional Vessel
Specific Requirements
How To Use the VGP Compliance Guidance Manual:
Step 3 – Complete BMP Information for
Each Applicable Discharge
DECK WASHDOWN AND RUNOFF AND ABOVE WATER LINE HULL CLEANING
Permit Requirement
Is Discharge Applicable to Vessel?:
(Check One)
Yes
No
Identify Best Management Practice(s) Used on the Vessel or Cross Reference Vessel Specific
Management Plans/Practices where the BMPs are Established
Minimize on-deck debris, garbage, residues and
spills from being discharged in deck washdown and
deck runoff.
Routine inspections are conducted each day. Crew is trained on good housekeeping
practices.
Vessel fitted with perimeter spill rails and scuppers
(when required by their class societies).
Machinery on deck must have coamings or drip
pans to collect oily water and to prevent spills (if
feasible).
Drip pans must be drained to waste container for
proper disposal and/or periodically wiped/ cleaned.
Spill rails and scuppers are equipped on vessel.
Minimize the presence of floating solids, visible
foam, halogenated phenol compounds, dispersants
and surfactants in deck washdowns.
Minimize washdowns in port.
Maintain topside surface and above water line
portions of the vessel.
Minimize residual paint droplets and/or overspray
from entering surface waters when conducting
maintenance painting.
Deck washings are conducted with non-toxic and
phosphate free cleaners and detergents that are
not caustic or are only minimally caustic and are
biodegradable.
All deck machinery have drip pans or other appropriate containment to prevent spills and to
collect oily water.
The drip pans are cleaned every week and oily waste is collected in specified sealed oily
waste container on deck.
Crew are trained on proper deck washdown procedures. Inspections are conducted before
each deck washdown to remove any trash and other loose material. Deck washing is
typically conducted without soap.
Deck washdowns in port are only conducted if necessary.
Inspections of deck surface and areas above water line are conducted every day.
Crew are trained on proper painting procedures. Paint nets, drop cloths, etc. are used when
painting.
Crew are trained on proper deck washdown procedures. If soap is used, the only soaps are
non-toxic, phoshate free soaps. A review of MSDS for each soap used is conducted to
ensure that soap is non-toxic and phosphate free.
How To Use the VGP Compliance Guidance Manual:
Step 4 – Complete Applicable Forms
Notice of Intent (NOI)
• NOI form should be available in June 2009
• Electronic submittal via eNOI Systemhttp://cfpub.epa.gov/npdes/enoi.cfm
• Existing vessels must submit by September 19,
2009 to maintain authorization
• VGP authorization after September 19, 2009
for vessels required to submit an NOI will take
at least 30 days to become effective
– Ownership transfers
– New vessels constructed after September 19,
2009
– Existing vessels that have not obtained
authorization
How To Use the VGP Compliance Guidance Manual:
Example Routine Visual Inspection Form
VESSEL NAME: OMSA 1
DATE
(1)
TIME
5/1/09
5:30 AM
5/3/09
5:30 AM
5/10/09
5:15 AM
LATITUDE &
LONGITUDE
AT TIME OF
INSPECTION
PRINTED
NAME OF
PERSONNEL
CONDUCTING
INSPECTION(2)
29.1330
90.2994
30.1451
87.0117
29.0412
90.0687
John M
Omsa
John M
Omsa
John M
Omsa
SIGNATURE OF
PERSONNEL
CONDUCTING
(2)
INSPECTION
MONITORING,
TRAINING,
INSPECTION
(3)
DOCUMENTATION
CARGO
(3)(4)
HOLDS
ACCESSIBLE
AREAS WHERE
CHEMICALS,
OILS, DRY
CARGO &
OTHER
MATERIALS
ARE STORED,
MIXED, OR
(3)(4)
USED
John M Omsa
JMO
JMO
JMO
JMO
See
Findings
JMO
John M Omsa
JMO
JMO
See Findings
JMO
JMO
JMO
John M Omsa
JMO
JMO
JMO
JMO
JMO
JMO
MACHINERY
STORAGE
AREAS
(including
boiler
areas)(3)(4)
DECK
AREAS and
WELL
(3)(4)
DECKS
VISUAL
MONITORIN
G OF WATER
BEHIND AND
AROUND
THE
VESSEL(3)(5)
(6)
FINDINGS/ADDITIONAL DOCUMENTATION :
5/1/09 – A small patch of oily water observed on deck. Oily water was immediately cleaned up and crew informed of housekeeping requirements. No evidence of oil entered water.
5/3/09 – Lid on used oil container was not closed and sealed. Lid was properly closed and sealed at time of inspection. Crew was informed of finding and provided training on proper material
storage.
NOTES:
(1)
(2)
(3)
(4)
(5)
(6)
The inspection should be conducted weekly or per voyage, whichever is more frequent, but not more than once per day.
The person conducting the inspection must be the person in charge or his duly authorized representative.
Initials of personnel conducting inspection shall be inserted for verification that each category is reviewed.
The areas inspected should be free of garbage, exposed raw materials, oils, any visible pollutant that could be discharged and that pollution prevention mechanisms are in proper
working order.
The visual inspection of surrounding waters shall verify that there is no sheen, dust, chemicals, abnormal discoloration, foaming or other indicators of pollution originating from the
vessel. If specific water streams cannot be inspected (i.e. discharge below the water line) a sample must be collected quarterly, visually examined and documented. Refer to Quarterly
Visual Inspection Form.
If any potential non-compliance issues or potential problems are noted corrective actions must be initiated and documented (see Section 4.2.8).
How To Use the VGP Compliance Guidance Manual:
Example Barge/Tanker Supplemental
Inspection Form
VESSEL NAME: OMSA 1
DATE
TIME
LATITUDE & LONGITUDE
AT TIME OF INSPECTION
INSPECTION TYPE(2)
PRINTED NAME OF PERSONNEL
CONDUCTING INSPECTION(3)
SIGNATURE OF PERSONNEL
CONDUCTING INSPECTION(3)
VISUAL
SHEEN
OBSERVED?
(yes or no)
6/15/09
10:25 AM
30.3101/ 89.2570
Unloading Fuel Cargo
John M Omsa
John M Omsa
no
FINDINGS/ADDITIONAL DOCUMENTATION(4):
.
NOTES:
(1)
(2)
(3)
(4)
Barges include hopper barges, chemical barges, tank barges, fuel barges, crane barges, and dry bulk cargo barges.
Inspections required to be conducted include the following:
- Below deck discharges
- Deck washing
- Loading/Unloading Operations (Tanker only)
The person conducting the inspection must be the person in charge or his duly authorized representative.
If any potential non-compliance issues or potential problems are noted, or a visible sheen is evident, corrective actions must be initiated and documented, as required in the
VGP, Part 3.
How To Use the VGP Compliance Guidance Manual:
Example Corrective Action Form – Fuel
Spill
DATE OF NON-COMPLIANCE:
May 7, 2009
DESCRIPTION OF NON-COMPLIANCE DISCOVERED:
Oil sheen observed in the water on
due to release of diesel while fueling the vessel.
TYPE OF DEFICIENCY (Requires Immediate Attention, Simple
Adjustment, Moderate Adjustment, Major Renovations)
IMPACTS OBSERVED, IF ANY:
Immediate Attention
Approximately 4 barrels of diesel released into water
LOCATION ON VESSEL WHERE INCIDENT/DISCHARGE OCCURRED:
Fuel Tank
CAUSE (IF KNOWN) OR STEPS TAKEN TO IDENTIFY CAUSE: Investigation identified that the cause of
the fuel spill was the result of a faulty float switch that did not trigger high level alarm. Further review revealed
that there was no established preventative maintenance program for the high level alarm float switch, and
personnel fueling the vessel failed to check the visual fuel level gauge prior to refueling.
CORRECTIVE ACTIONS NECESSARY TO ELIMINATE PROBLEMS, INCLUDING A SCHEDULE FOR
IMPLEMENTING CORRECTIVE ACTIONS(1) :
DEADLINE FOR
EXPECTED
COMPLETION
CORRECTIVE ACTION STEPS
CORRECTIVE
IMPLEMENTATION
DATE/TIME
(2)
ACTION
DATE
Repair high level alarm float switch
5/8/09
5/8/09
5/8/09
Train crew on fueling operations
Establish preventative maintenance program for
fuel tank float switch high level alarm
5/8/09
5/8/09
5/8/09
5/31/09
5/15/09
5/12/09
Name & Title of Person
Identifying Non-Compliance:
Signature of Person Identifying
Non-Compliance:
Name & Title of Person
Recording Violation:
Signature of Person Recording
Non-Compliance:
Bob Spillman, Tankerman
Bob Spillman
John M Omsa, Vessel Owner/Captain
John M Omsa
NOTES:
(1)
It is recommended that undue delays in operation are noted.
(2)
Corrective action deadlines
Immediate
Simple adjustments – 2 weeks
Moderate adjustments – 3 months
Major renovations (dry docking) – next available dock date
How To Use the VGP Compliance Guidance Manual:
Example Spill/Release Report
Do not delay notification to collect all information on this form
Reporter’s Last Name:
Omsa
First Name:
Position/Title: Vessel Owner
Personnel Contact Phone Numbers:
977 -995-9999
Company Name:
OMSA Offshore Services, Inc
Address: 19 OMSA Way
John
City: OMSA
State:
LA
Zip:
77777
Responsible
Party:
OMSA Oil Services, LLC
Time Called: 10:40 AM
(AM/PM)
Date of Spill: 5/7/09
Time of Incident: 10:25 AM
(AM/PM)
Spill Location: Bay St. Louis – Mississippi Sound
Nearest City:
Bay St. Louis
State: MS
County: Hancock
Spill Latitude:
30
Degrees
18
Minutes
53
Seconds
Spill Longitude:
89
Degrees
20
Minutes
39
Seconds
Source and Cause of Incident:
Approximately 4 barrels of diesel was spilled during refueling
operations
Material Description: Diesel fuel
CHRIS Code
Discharged
Quantity
Unit of
Measure
(bbl/gal)
Material
Discharged
to Water (Y/N)
Quantity
Unit of
Measure
(bbl/gal)
4
bbl
Y
4
bbl
Action Taken to Correct, Control, or Mitigate Incident:
Upon discovery of spill, fuel pump was
manually shut off. Spill was immediately contained and cleaned using spill booms and pads. All
Spilled material was collected and hauled offsite.
Number of Injuries:
0
Number of Deaths:
Were there evacuations (Y/N):
Was there any damage (Y/N):
0
N
N
Any information about the incident not recorded elsewhere on the report:
Agency Notified
Phone Number
Date
Time
USCG NRC
1-800-424-8802
5/7/09
10:40
N/A
Report
Number
AM/PM
96497
AM/PM
AM/PM
* Additional reports may be required depending on the severity of the spill (i.e. endanger human
health or the environment). Refer to Section 4.4.3 of the VGP for additional information.
How To Use the VGP Compliance Guidance Manual:
Example Maintenance Log
DATE
5/8/09
6/30/09
AREA/LOCATION OF
VESSEL
MAINTENANCE
AND/OR INSPECTION
Fuel Tank
Cabin, Bridge, and Galley
doors and window trim
TYPE OF
MAINTENANCE
PERFORMED
APPLICATION OR
PROCEDURES USED TO
PERFORM MAINTENANCE
MATERIALS USED
Adjusted float
switch
Operation and Maintenance
Manual
N/A
Routine painting
of exterior
surfaces
Vessel’s established exterior
painting procedures
Paint screens, drop cloths,
glossy white paint
NOTES:
MINIMUM DOCUMENTATION FOR THE FOLLOWING COMPONENTS IS REQUIRED, BUT NOT LIMITED TO (if applicable):
Non-routine deck maintenance
Graywater Treatment Systems
Paint Application
Marine Sanitation Devices
Bilgewater Treatment Systems and/or Oily Water Separators
Piping/Seawater Cooling Systems
Cathodic Protection
Engines
Oil to Sea Interfaces
Exhaust Gas Cleaning Systems
Firemain Systems
Underwater Ship Husbandry Activities
ADDITIONAL
NOTES
Equipment will be
placed on routine
PM schedule
How To Use the VGP Compliance Guidance Manual:
Example Training Log
DATE: May 7, 2009
NAME OF INSTRUCTOR: John M Omsa
NAME OF PERSONNEL
TITLE
Bob Spillman
Deckhand
Bob Spillman
Matthew Jones
Deckhand
Matthew Jones
Jake Omsa
Deckhand
Jake Omsa
SIGNATURE
TOPICS COVERED:
VGP General Requirements (Y/N)
Y
VGP Inspection Requirements (Y/N)
Y
Tanker Personnel-Shipboard Environmental Procedures (Y/N)
N
Ballast Water Management Requirements (Y/N)
N
Additional VGP Specific Requirements Covered (List Below):
Fueling Operations
How To Use the VGP Compliance Guidance Manual:
Example Dry Dock Inspection Form
DRY DOCK LOCATION: DRYDOCK, LLC
VESSEL NAME: OMSA 1
DRY DOCK REPRESENTATIVE
VESSEL REPRESENTATIVE
TITLE
Vessel Owner/Captain
Dry Dock Superintendent
PRINTED NAME
John M OMSA
Paul McElroy
SIGNATURE
John M Omsa
Paul McElroy
DATE
12/1/09
12/1/09
TIME
3:21 PM
3:21 PM
VGP REQUIREMENT
REVIEWED
AND
COMPLIANT
REVIEWED
AND
ATTENTION
IS NEEDED
NOTES
Y
The chain locker has been cleaned for both sediment and living organisms
The areas listed below have been inspected for attached living organisms, and all organisms have been removed or neutralized:
Vessel hull
Y
Propeller
Y
Rudder
Y
Thruster gratings
Y
Sea chest
Y
Other surface areas
Antifoulant coatings have been applied, maintained, and removed according to
FIFRA label, if FIFRA product.
New or exposed existing coating does not contain biocides or toxics that are
banned for use in the U.S.
Cathodic protection (anodes or dialectic coatings) have been cleaned and/or
replaced to reduce flaking.
Y
All pollution control equipment is functioning properly.
Seawater piping biofouling chemicals have been applied, maintained, and removed
according to FIFRA label, if FIFRA product.
Y
Y
Y
Y
NA
Chemical exchange not needed at this time
How To Use the VGP Compliance Guidance Manual:
Example Annual Non-Compliance Report
Vessel Name: OMSA 1
Owner Name/Address: OMSA Offshore Services, LLC
Date: January 31, 2010
19 OMSA Way
Phone Number: 977 -995-9999
New Orleans, LA 70123
Person Reporting: John M Omsa
Title: Vessel Owner/Captain
NPDES Authorization Number (if applicable): N/A
Date of NonCompliance
Event
Receiving
Waterbody
(at time of
NonCompliance)
Nearest
City, State
at time of
NonCompliance
VGP
Requirement
5/7/09
Gulf of Mexico
Mobile, AL
Section 2.1.3
Deviation/NonCompliance
Description
See Corrective
Action Report
Cause or
General
Narrative
See Corrective
Action Report
Corrective
Action/Preventative
Measures/Remediation
Implemented
See Corrective Action Report
“I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered
and evaluated the information contained therein. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information
contained is, to the best of my knowledge and belief, true, accurate, and complete. I have no personal knowledge that the information submitted is other than true, accurate, and complete. I am aware that there
are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.”
John M Omsa
John M Omsa
Printed Name
Signature
1/31/10
Date
How To Use the VGP Compliance Guidance Manual:
Other Required Records and Reports
•
•
•
•
•
•
•
•
•
Owner/Vessel Information Form
Quarterly Visual Inspection Form
Comprehensive Annual Vessel Inspection Form
Ballast Water Discharge Recordkeeping Form
Experimental Ballast Water Treatment System
Form
Voyage Log
Discharge Log
One Time Report
Discharge Monitoring Report