Vessel General Permit
Under the Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels or 2013 VGP various types of discharge are authorised from vessels in US waters, if in accordance with requirements of the permit.
2013 VGP can be downloaded here.
Section 2.2.26 details the requirements for Exhaust Gas Scrubber Washwater Discharges, which are similar but not fully aligned with the MEPC.184(59) Exhaust Gas Cleaning System Guidelines. There are discharge limits for pH, PAH and turbidity, which must be continuously monitored, and nitrates/nitrites. However, there is also a requirement for vessel owner/operators to collect and analyse two sets of samples in the first year of permit coverage or system operation to demonstrate treatment equipment maintenance, probe accuracy, and compliance with the permit. After the first year, samples must be collected at least once per calendar year.
Samples of the following are required:
- Inlet water (for background),
- Water after the scrubber (but before any treatment system); and
- Discharge water.
Samples must be analysed for:
- Dissolved and Total Metals, including, Arsenic, Cadmium, Chromium, Copper, Lead, Nickel, Selenium, Thallium, Vanadium, and Zinc
- EPA 16 PAH
- Nitrate -nitrite
- pH
All results must be submitted to US EPA.
Vessel Incidental Discharge Act (VIDA)
The VGP is expected to be replaced under the Vessel Incidental Discharge Act (VIDA), which restructures the way EPA and the U.S. Coast Guard (USCG) regulate discharges. By December 2020, EPA is required to develop national standards of performance for approximately 30 discharges (similar to the discharges in the 2013 VGP). Two years thereafter (~2022), the U.S. Coast Guard (USCG) is required to develop corresponding implementation, compliance, and enforcement regulations.
