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COMPLIANCE WITH EPA VESSEL GENERAL PERMIT (VGP) REQUIREMENTS

The current VGP came into effect on December 19, 2013 and requires the implementation of
minimum best management practices for 27 types of discharges incidental to the normal
operations of a vessel when operating in US waters (0-3 nm).

The Vessel Incidental Discharge Act (VIDA) established a new framework for the regulation of
incidental discharges from vessels operating in the US. EPA and USCG will issue these regulations
to replace the VGP, however, they are not expected to be finalized until 2026.

Until that time the 2013 VGP and all requirements will remain in effect, and all current eNOIs
will remain valid and do not need to be resubmitted. New eNOIs will still be required for new
coverages or transfer in ownership.
VGP
ENFORCEMENT UPDATE: There has been a significant increase in enforcement of the 2013
VGP from EPA in the past few months. Specifically, EPA’s enforcement team is reviewing past
Annual Report submissions and ballast water management reports to ensure any applicable
monitoring data is being submitted to EPA.

REQUIRED ACTION: Ensure all necessary crew understand the VGP requirements that apply to
your vessel, all inspections are being carried out while operating in VGP waters, and all required
monitoring is being completed and submitted as part of your Annual Report. More information on
the specific requirements, reporting, and applicability, is included in this Checklist.

If a vessel meets any one or more of the following criteria it is eligible for coverage
APPLICABILITY and must enroll in the VGP:
• Is it a commercial vessel 79 feet in length or greater?
• Is it a commercial vessel over 300 GT?
• Is it a commercial vessel with a ballast water capacity of 8m3 or more?
RECREATIONAL Recreational vessels, those NOT carrying paying passengers for hire, as defined in
VESSELS section 502(25) of the Clean Water Act are NOT eligible for VGP coverage.
COMMERCIAL Commercial fishing vessels have been permanently exempted from the VGP
FISHING VESSELS requirements, with the exception of ballast water discharges.
Applicable vessels must have an active Notice of Intent (NOI) for the 2013 VGP. The
ENOI purpose of this document is to certify your intent to comply with the applicable
minimum best management practices required by the VGP.
Enroll and certify vessels for VGP coverage using the EPA’s online eNOI System at least (7)
1 days prior to operating in US waters.

2013 VGP eNOI System: https://cdx.epa.gov/

This only has to be done one time, NOT prior to every voyage to the US and will remain valid for the duration
of the current VGP or until it is terminated.
Maintain a copy of your active Notice of Intent (NOI) on board which is a certification statement
2
that a vessel has implemented appropriate measures to comply with the VGP.
If your vessel name, IMO number, USCG vessel identification number, vessel call sign, flag state,
3 or port of registry changes, the eNOI must be updated, re-certified and an updated copy provided
to the vessel. Updates should also be made to correct any mistakes to the original submission.
When a vessel is transferred out of management or will no longer call US waters a Notice of
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Termination (NOT) should be submitted using the EPA eNOI System.

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Vessels that operate in US waters (0-3 nm) prior to VGP coverage becoming active (within the
7-day window) increase the risk of liability for discharges incidental to the normal operation of
a vessel from non-governmental (environmental) groups.

For a transfer of ownerships, if the vessel was covered under the previous owner activation of
NOTE the new eNOI will be immediate and is not subject to the 7-day window. Please note, and new
eNOI still needs to be submitted for the new owner or operator.

Neither the EPA nor the USCG will restrict operations for not having a valid NOI. However, you
may receive a notice of violation and monetary penalty for not having coverage in place before
arriving in the US.
For more detailed information on accessing and using the EPA eNOI System please see the
• EPA VGP Home Page: https://www.epa.gov/vessels-marinas-and-ports/vessels-vgp
• O’Brien’s Compliance Guide: Enclosure 2 – Electronic Reporting
For assistance in submitting, updating or terminating an eNOI contact your contact your Client Specialist.
ENOI Use the public link below to search and download a copy of the eNOI for your vessel(s):
SEARCH https://vgpenoi.epa.gov/ords/vgpenoi/f?p=vgp:Search

The Vessel Incidental Discharge Act (VIDA) changed how EPA and USCG will regulate
incidental discharges. A Proposed Rule was issued by EPA in October 2020 for public
comment, and a supplemental notice was issued in 2023. The final rule is expected to be
issued by EPA in 2024. Once finalized, the USCG will have 2 years to issue implementing
regulations.

While most requirements will remain the same, the proposal does include alignment on
scrubber washwater and consolidation of other requirements. The EPA’s rule focuses on
VIDA standards and USCG’s rule will be focused on implementation (e.g., reporting, inspections).

Full implementation not likely until at least 2026. Until that time, the 2013 VGP will remain in
effect, including all required analytical monitoring, inspection, and reporting requirements. All
current eNOIs will remain valid and do not need to be resubmitted. New eNOIs are required
for new coverages or transfer in ownership.

More information is available on EPA’s website at - https://www.epa.gov/vessels-marinas-

and-ports/vessel-incidental-discharge-act-vida

SUMMARY OF It is recommended that companies conduct a comprehensive review each of the

discharge types in Section 2 of the VGP. The EPA has updated the descriptions,
SIGNIFICANT definitions, and minimum best management practices for many of the 27 discharge types.
2013 VGP
CHANGES Below is a brief summary of some of the significant changes from the 2008 VGP:
• When deck wash-downs or above water line hull cleaning will result in a discharge, it must be
conducted with "minimally toxic" and "phosphate-free" cleaners and detergents, as defined in
Appendix A of the VGP.
• Vessels greater than 400gt that regularly sail outside of the territorial sea shall not discharge
treated bilgewater within 1nm of shore if technologically feasible.
• "New Build" vessels built after December 19, 2013, greater than 400gt that discharge bilgewater
between 0-3nm must monitor and report their effluent at least once a year.
• Ballast water requirements remain consistent with current U.S. Coast Guard (USCG) regulations,
which were released in 2012. The schedule for implementing ballast water treatment systems
(BWTS) are aligned with the International Maritime Organization (IMO) schedule and
requirements for exchange and flushing remain in place. More information on ballast water
sampling is included below.
• Vessels must use environmentally acceptable lubricants (EAL) in all oil to sea interfaces (i.e.,
mechanical equipment subject to immersion), unless technically infeasible. The terms
"environmentally acceptable lubricants," "technically infeasible," "biodegradable," "minimally
toxic," and "not bioaccumulative" are defined in Appendix A of the VGP.

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• For graywater, vessels must use phosphate-free and minimally toxic soaps and detergents, as
defined in Appendix A of the permit. Additional best management practices to minimize the
production of graywater while in port or not underway are described. All vessels with sufficient
graywater storage capacity must not discharge within 1nm of shore or dispose of graywater
onshore if there are appropriate facilities available and it is economically practicable and
achievable.
• There are semi-annual graywater monitoring requirements for new build vessels that have a
maximum crew capacity of 15 or more and that discharge graywater between 0-3nm. The
information collected is to be included in the Annual Report.
• Vessels with exhaust gas cleaning systems that result in washwater discharges between 0-3nm
must meet the numeric effluent limits found in Section 2.2.26.1 and the monitoring and reporting
requirements found in Section 2.2.26.2 of the permit. (This does NOT include Inert Gas Scrubber
discharges).
• A new discharge category has been added: Fish Hold Effluent (2.2.27) – Reasonable steps must
be taken to prevent discharge of excess fish hold water and ice while a vessel is stationary at the
pier. Large fish pieces may not be discharged unless a physical separation method is used. These
solid fish wastes must be disposed of shoreside or at sea (outside harbors or other protected and
enclosed coastal waters).

All vessels that are discharging ballast water treated with either a USCG type approved
or AMS system in VGP waters must conduct functional and analytical monitoring
required under the VGP.

A summary of the ballast water requirements is included below. Additional monitoring

may also be required for bilgewater, graywater, and scrubber washwater. More
information is included in the 2013 VGP compliance section.

Monthly functional monitoring (all BWTS)

• Carried out on board and measures system functionality for each month the
vessel is operating in VGP waters. Refer to Appendix J of the 2013 VGP for the
specific parameters based on the system type being used.

Biological monitoring (all BWTS)

• Measures levels of E.coli, total heterotrophic bacteria, and enterococci, and is
sent to a laboratory for analysis
BALLAST • Must sample two (2) times within a year of the first discharge. If the samples
come back below the VGP limits, then biological sampling can be reduced to
WATER one (1) sample per year if the vessel is continuing to discharge in VGP waters.
MONITORING If the sample comes back above the limit, you have to go back to two samples.

Biocide monitoring (only systems using chemical treatment)

• The specific tests and limits will be based on the type of the system being used.
See page 33 of the VGP for the list of specific parameters.
• Must carry out “initial monitoring” which includes 3 samples within the first 10
discharges of the system (regardless of the discharge location)
• After that period, you must sample two (2) times per year when the system is
being used in US waters.

Annual Calibration (all BWTS)

• At least once per year (12 months) all applicable sensors and equipment should
be calibrated annually, or more frequently if required by the manufacturer.

The results of all sampling must be included on your Annual Report each year, as
applicable. Failure to complete any required testing should be reported as a “non-
compliance” on your Annual Report.

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Witt O’Brien’s has developed a guide with strategies and template forms to document
2013 VGP compliance with the VGP, it is recommended that you contact your management for
COMPLIANCE company and vessel-specific guidance and instructions on how to satisfy the
requirements of the VGP.

To obtain a copy of the 2013 VGP Compliance Guide contact your Client Specialist.
The following actions should be taken by vessel management and crew to ensure
REQUIRED ACTIONS compliance with the 2013 VGP:
Develop a company policy for VGP compliance which includes implementation, monitoring,
1 record-keeping and documentation of vessel-specific best management practices for all
applicable discharges.
Determine the applicability of the 27 discharges for each vessel. This information is also
2 required in order to complete the eNOI.
See Witt O’Brien’s 2013 VGP Compliance Guide: Enclosure 5 – Supplemental Discharge Information
Document or cross reference the minimum best management practices implemented for
each applicable discharge. Many of these practices may already be part of the existing Safety
3 Management System. This information is a key component of demonstrating to inspectors how
a vessel complies with the VGP and should be made available upon request during inspections.
See Witt O’Brien’s 2013 VGP Compliance Guide: Enclosure 1 – Best Management Practices Matrix
Conduct routine visual inspections for all applicable VGP incidental discharges at least once
4
per week or per voyage, whichever is more frequent, when in US waters (0-3 nm).
Document routine visual inspections in the official ship logbook or separately in accordance
5 with Section 4.1.1.1 of the VGP.
See Witt O’Brien’s 2013 VGP Compliance Guide: Enclosure 4 – Documenting VGP Compliance
Conduct and document an annual comprehensive vessel inspection at least one every
6 twelve (12) months in accordance with Section 4.1.3 of the VGP.
See Witt O’Brien’s 2013 VGP Compliance Guide: Enclosure 4 – Documenting VGP Compliance
When VGP non-compliance is discovered, document appropriate corrective actions in
7 accordance with Section 3 of the VGP.
See Witt O’Brien’s 2013 VGP Compliance Guide: Enclosure 3 – Corrective Action Assessments
Conduct analytical monitoring for certain discharges types: bilgewater (section 2.2.2.1),
8 ballast water (section 2.2.3.5.1.1.1-5), graywater (section 2.2.15.2) and exhaust gas scrubber
effluent (section 2.2.26.2) as applicable.
Report analytical monitoring of applicable discharges (see above) at least once per calendar
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year as a part of the annual report.
Complete the annual report electronically using the EPA online reporting system. The report
10
for the previous year must be completed no later than February 28th of the next year.
Ensure that the master, operator, person-in-charge and crew members who actively take part in
the management of incidental discharges or who may affect those discharges are adequately
11 trained in implementing the applicable minimum best management practices required by the VGP.
General training should be part of a company VGP policy, but need not be formal or accredited courses
Recordkeeping: all documentation generated to demonstrate compliance with the VGP should be
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retained on board for a period of three (3) years (section 4.1-2)

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VGP EPA requires a significant amount of information to be submitted as part of the Annual Report.
It is recommended NOT to delay efforts to gather the required information. Owners/Operators
ANNUAL should gather the required information for each vessel that has an eNOI in order to prepare,
REPORT submit and certify the annual report.

Log in to the EPA Central Data Exchange (CDX) and update your password.
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EPA Central Data Exchange (CDX) Login - https://cdx.epa.gov/
REQUIRED The following actions should be taken by vessel management to ensure completion of the
ACTIONS Annual Report no later than February 28th each year:
Is the submission of DMR data applicable to your vessel(s)? Below is a summary of the DMR
applicability:
• The bilge water discharge monitoring requirements only apply to new build vessels with keel
laid dates after December 19, 2013 that have discharged bilge water in US waters (0-3 nm)
during the previous calendar year.
• The graywater discharge monitoring requirements only apply to new build vessels with keel
laid dates after December 19, 2013 that have discharged gray water in US waters (0-3 nm)
during the previous calendar year.
2 • The exhaust gas scrubber discharge monitoring requirements only apply to vessels with
exhaust gas scrubber discharge that has been discharged in US waters (0-3 nm) during the
previous calendar year.
• The ballast water discharge monitoring requirements only apply to vessels that have
installed a ballast water treatment system (BWTS) and have discharged ballast in US
waters (0-3 nm) during the previous calendar year.
For more information, please review the following guidance provided by the EPA:
Discharge Monitoring Report Applicability Summary
Determine which submission method is appropriate for your company:
The choice of submission method is based on a few important factors: 1) the number of vessels
3
in your fleet with VGP coverage, 2) whether or not vessels in your fleet discharged in US waters,
and 3) if you are required to submit Discharge Monitoring Report (DMR) data for your vessels.
A web-based tool to prepare, certify, and submit individual annual reports one at a time. This
approach is suitable for Owners/Operators submitting a few annual reports for vessels NOT
required to provide DMR data as part of those annual reports.
Option 1

When to use Option 1: This approach is most appropriate if you are submitting annual reports
for less than 4 or 5 vessels (without DMR data). It is also recommended for vessels that are
required to submit annual reports but did not discharge in US waters during the reporting year. If
you are preparing annual reports for more than 4 or 5 vessels, it is suggested that you use the
batch upload option and complete these reports using the Microsoft Excel spreadsheet for annual
reports without DMRs.
An Excel spreadsheet-based tool, similar to that used for submitting NOIs for multiple vessels,
to enter and upload annual reports and any required DMR data for one or more vessels at a
time. Two different annual report spreadsheets are available: (1) Batch Upload Spreadsheet –
No DMR; or (2) Batch Upload Spreadsheet with DMR
Option 2

When using Option 2: If you do NOT have any DMR data as part of the Annual Report, please
make sure you use the "Batch Annual Report Spreadsheet (without DMRs)." If you are required
to submit DMR data as part of an annual report, you MUST use the "Batch Annual Report
Spreadsheet (with DMRs)" to submit the annual reports – even if only one of the vessels in your
batch submission has DMR data.

Copies of the spreadsheets can be downloaded through the CDX website, or please contact
your Client Specialist for a copy.
The EPA has confirmed that there have been no changes to the format or questions for the 2023 Annual
Report, therefore they encourage using and updating the report data collected for 2022 with the information
required for 2023 to streamline the submission process.

For assistance in reviewing your batch upload spreadsheets to submit to the

[email protected]
EPA, please contact us at:

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The EPA requires the use of environmentally acceptable lubricants (EAL) for all oil-to-sea
EALS interfaces, including wire rope and mechanical equipment subject to immersion if there is any
reasonable chance of an operational discharge (absent a catastrophic event).
The EPA does not maintain a list of approved EALs or manufacturers of EALs. They do provide the following
guidance on the choice of an appropriate EAL:

“Environmentally Acceptable Lubricants” means lubricants that are “biodegradable” and “minimally-toxic,”
and that are “not bioaccumulative” as defined in Appendix A of the VGP. For purposes of the VGP, products
meeting the permit’s definitions of being an “Environmentally Acceptable Lubricant” include those labeled
by the following labeling programs: Blue Angel, European Ecolabel, Nordic Swan, the Swedish Standards
SS 155434 and 155470, Convention for the Protection of the Marine Environment of the North-East Atlantic
(OSPAR) requirements, and EPA’s Design for the Environment (DfE).

Additional guidance from the EPA is available in the following document dated November 2011:
• Environmentally Acceptable Lubricants EPA 800-R-11-002
For stern tube systems including protective seals on controllable pitch propellers, azimuth thrusters,
propulsion pods and rudder bearings an operator may elect to use an alternative seal design (i.e. air or
seawater lubricated systems) in lieu of an EAL.

EPA recommends that a vessel operator have third party certification that the seal design is unlikely to leak
during normal operation, and therefore, will no longer function like an oil-to-sea interface.
REQUIRED ACTIONS The following actions are required for all oil-to-sea interfaces:
1 If technically feasible, install and use an EAL in all oil-to-sea interfaces (skip to Step 5).
If not technically feasible to install and use an EAL for a particular oil to sea interface maintain
2 records documenting the reasons for the decision not to use an EAL along with the supplemental
documentation described below based on the reason for technical infeasibility.
TECHNICAL For the installation and use of EALs to be considered technically infeasible one or more of
INFEASIBILITY the following conditions must apply:

• No EAL products are approved for use in a given application that meet manufacturer specifications
for that equipment.
Maintain a certification statement from the manufacturer on board the vessel.
• Products which come pre- lubricated (e.g., wire ropes) have no available alternatives
manufactured with EALs.
Maintain a certification statement from the manufacturer on board the vessel.
• Products meeting a manufacturers specification are not available within any port in which the
vessel calls.
Maintain a certification statement from the company on board the vessel that an appropriate EAL
is not available in the ports the vessel frequently calls.
• Change over and use of an EAL must wait until the vessel’s next scheduled dry docking.
Maintain a company/class/manufacturer certification statement on board the vessel that
installation or switch-over to EALs for a particular system can only be completed in dry dock.
Conduct a corrective action assessment to document non-compliance (technical infeasibility) and
3
appropriate corrective actions (see VGP section 3).
4 Report non-compliance (technical infeasibility) and corrective actions in the annual report.
Be prepared to make all documentation available to USCG/EPA inspectors upon request
5
(Either demonstrating the use of EALs or technical infeasibility as described above).

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VESSEL Section 5 of the VGP outlines additional class-specific requirements for certain
CLASS-SPECIFIC vessels. Below is a brief summary of some of the significant additional requirements
REQUIREMENTS for certain vessels:
Increased graywater management and monitoring requirements including pool and
CRUISE SHIPS
spa discharges as well updates to the educational and training requirements
(LARGE/MEDIUM)
(section 5.1-2).
Additional effluent limits (deck water, graywater) and educational and training
LARGE FERRIES
requirements (section 5.3).
BARGES Additional supplemental inspection requirements and effluent limits (section 5.4).
Additional authorized discharge (Inert Gas Scrubber Effluent), supplemental
OIL OR PETROLEUM
inspection requirements including a visual sheen test as well as updates to the
TANKERS
educational and training requirements (section 5.5).
RESEARCH VESSELS Additional supplemental authorized discharges and effluent limits (section 5.6).
EMERGENCY AND
Additional supplemental authorized discharges and effluent limits (section 5.7).
RESCUE VESSELS

ADDITIONAL REFERENCES Below is a list of additional references that are also very useful:
2013 VGP eNOI System Login - https://www.epa.gov/npdes/vessels-vgp

VGP Vessel Discharge Sample Collection and Analytical Monitoring Reference Guide
EPA VGP Frequently Asked Questions –
https://www.epa.gov/npdes/vessels-frequent-questions
VGP Additional Resources –
https://www.epa.gov/npdes/vessels-additional-resources

COMPLIANCE WITH ADDITIONAL STATE REQUIREMENTS FOR THE VGP

California certified the EPA Vessel General Permit (VGP) with the following
CALIFORNIA additional permit conditions/requirements when operating in state waters:

Large passenger vessel and cruise ship graywater discharges are prohibited in state waters.
1 Graywater discharges from vessels that weigh 300 gross tons, or more are also prohibited if such
vessels have sufficient holding capacity.
A copy of the NOI must be sent to the State Water Resources Control Board via email at
2
[email protected].
For more information regarding compliance in California see the California checklist.

Connecticut certified the EPA Vessel General Permit (VGP) with the
CONNECTICUT following additional permit conditions/requirements when operating in
state waters:
Discharge of treated/untreated bilge water and graywater, exhaust gas scrubber washwater, and
1
fish hold effluent into Connecticut waters from any vessel is prohibited.
A copy of the NOI must be sent to the Department of Energy and Environmental Protection (DEEP)
2
via email at [email protected].
All vessels must maintain the ability to measure salinity levels in each ballast water tank on board
3
the vessel to ensure ballast exchange in marine waters with salinities between 20 and 25ppt.

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Hawaii certified the EPA Vessel General Permit (VGP) with the following
HAWAII additional permit conditions/requirements when operating in state waters:

Submit a VGP DOH Notification Form online via the Hawaii Department of Health DOH-CWB
website at: https://eha-cloud.doh.hawaii.gov/epermit/

If this is the first submission for your company, you will need to register an account. Once that is
completed or if you already have a company account, select “Form Finder” and enter “Electronic
VGP DOH Notification Form”.
1
Select the applicable form and proceed with the submission. This is only required to be submitted
once while the vessel is covered under the 2013 VGP and does not need to be submitted prior to
each arrival.

More information on the program is available at https://health.hawaii.gov/cwb/permitting/section-

401-wqc/vessel-general-permit-vgp/).
Submit all non-compliance in state waters on a non-compliance reporting form available via the
2
DOH-CWB website: https://eha-cloud.doh.hawaii.gov/epermit.
For more information regarding compliance in Hawaii see the Hawaii checklist.

Maine certified the EPA Vessel General Permit (VGP) with the following additional
MAINE permit conditions/requirements when operating in state waters:

Large passenger vessels are prohibited from discharging graywater into no discharge zones
1
(NDZ).
All vessels entering Maine waters must maintain the ability to measure salinity levels in each
2
ballast tank onboard to ensure salinity of 30ppt.

Michigan certified the EPA Vessel General Permit (VGP) with the following
MICHIGAN additional permit conditions/requirements when operating in state waters:

Discharges of blackwater (sewage) and graywater from vessels covered by the VGP are prohibited
1
in Michigan waters as it is designated as an EPA No Discharge Zone (NDZ).
Oceangoing vessels covered by the VGP are prohibited from discharging ballast water in
2 Michigan's waters unless the vessel has obtained a Certificate of Coverage under the Ballast Water
Control General Permit (Permit No. MIG140000).
Oceangoing vessels that discharge ballast in Michigan waters must monitor ballast water
3 discharge at least once each year for living organisms and report a summary of the results to
Michigan Department Environmental Quality (MDEQ) no later than December 31 each year.
Michigan issued an updated Permit in January 2022. For more information see the Great Lakes Checklist

Minnesota certified the EPA Vessel General Permit (VGP) with the following
MINNESOTA additional permit conditions/requirements when operating in state waters:

Vessel must obtain and comply with the existing Minnesota ballast water general permit
1
(MNG300000) detailed above or subsequent modifications of that permit issued by MPCA.
Vessels are required to conduct ballast water exchange for voyages originating outside the US
EEZ in water at least 200 nautical miles from any shore, in waters at least 2,000 meters in depth
2
which result in a salinity level of at least 30 parts per thousand prior to entering Minnesota waters
regardless of the installation of treatment systems.
For more information on the MN Ballast Water Control General Permit see the Great Lakes checklist.

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New Hampshire certified the EPA Vessel General Permit (VGP) with the
NEW
following additional permit conditions/requirements when operating in state
HAMPSHIRE waters:
New Hampshire waters have been designated an NDZ, all sewage discharge including graywater
1
containing sewage, whether treated or untreated, is prohibited.
Graywater without sewage should be discharged at pump-out facilities or beyond three nautical
miles of the New Hampshire shoreline and the Isles of Shoals wherever feasible.
2
This is infeasible at this time for vessels without holding tanks for graywater, but these vessels
should plan to install such holding tanks during one of the next two scheduled dry-docking events
if such installation is technically feasible and would not jeopardize the safety of the vessel.

New York certified the EPA Vessel General Permit (VGP) with the following
NEW YORK additional permit conditions/requirements when operating in state waters:

1 Discharge of bilge water is prohibited in New York waters.

Existing ballast water exchange and flushing requirements for voyages originating outside the
2 exclusive economic zone (EEZ) remain in effect regardless of whether the vessel is equipped with
a BWTS.
3 Annual monitoring and reporting of living organisms after a BWTS is installed.
Additional best management practices for Confined Laker vessels that operate exclusively in the
4
Great Lakes (see section 6.19.4).

Ohio certified the EPA Vessel General Permit (VGP) with the following additional
OHIO permit conditions/requirements when operating in state waters:

Vessels that operate outside the EEZ and more than 200 nautical miles from shore, and then enter
1 the Great Lakes via the St. Lawrence Seaway System must conduct saltwater flushing of ballast
tanks. This condition applies both before and after treatment system deadlines in the VGP.
2 Vessels are prohibited from discharging ballast water sediment in Ohio waters.

RHODE Rhode Island certified the EPA Vessel General Permit (VGP) with the following
ISLAND additional permit conditions/requirements when operating in state waters:

The discharge of bilge water from any vessel covered under the VGP whose voyage originates
outside the EEZ shall discharge all existing bilge water prior to entering Rhode Island waters. If
1
the vessel is unable to discharge their bilge water prior to entering Rhode Island waters, the
operator is prohibited from discharging bilge water within Rhode Island waters.
Existing ballast water exchange and flushing requirements for voyages originating outside the EEZ
2
remain in effect regardless of whether the vessel is equipped with a BWTS.
3 Annual monitoring and reporting of living organisms after a BWTS is installed.

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Washington certified the EPA Vessel General Permit (VGP) with the
WASHINGTON following additional permit conditions/requirements when operating in
state waters:
In order to minimize the generation and release of wastewater, vessel operators shall use best
management practices that include mechanical methods to thoroughly clean bulk and break-bulk
cargo holds. Unless flammable or explosive vapor concentrations make the risk too great, hold
1
cleanliness shall be documented photographically before washing with water. Solid wastes from
hold cleaning must be transferred onshore for disposal in an approved landfill. This includes
agricultural products such as grains.
The discharge of wash down water from holds containing metal ores, prilled coal tar (pencil pitch),
2
coal, and petroleum coke is prohibited.
The discharge of tank cleaning and wash down water from petroleum and chemical tank ships is
3
prohibited.
Discharge of wash water from holds that contained concrete, sand, gravel, and other similar
4 inorganic products shall be allowed as long as it is managed in such a way as to prevent a visible
increase in turbidity or raising receiving water pH more than 0.5 units or above 8.5.
5 The discharge of fish hold effluent while at a dock, pier, or mooring is prohibited.
Notification to the Washington State Department of Health (WDOH) within 24 hours is required for
6 graywater discharges in violation of VGP 2.2.15, 5.1 or 5.2 or untreated sewage discharges at +1
360 236 3330 or +1 360 789 8962 (after hours).
For more information regarding compliance in Washington see the Pacific NW checklist.

Wisconsin certified the EPA Vessel General Permit (VGP) with the following
WISCONSIN additional permit conditions/requirements when operating in state waters:

Vessels must obtain any permits required by the State of Wisconsin for vessel discharges
1
(WDNR's ballast water discharge general permit WI- 0063835-03).
Vessels that operate outside the EEZ and more than 200 nautical miles from shore, and then enter
2 the Great Lakes via the St. Lawrence Seaway System must conduct saltwater flushing of ballast
tanks.
3 Discharges of graywater or sewage into Lake Michigan, a NDZ, are subject to penalties.
For more information on the WI Ballast Water Discharge General Permit see the Great Lakes checklist.

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