INTERTANKO GUIDE TO GRAYWATER DISCHARGE REQUIREMENTS IN THE US

Transcription

1 INTERTANKO GUIDE TO GRAYWATER DISCHARGE REQUIREMENTS IN THE US

2 Summary Graywater discharge requirements in the US Graywater is considered an operational waste necessary for the operation of a vessel but its discharge is restricted in certain situations according to the US Environmental Protection Agency s Vessel General Permit (VGP) scheme. Graywater discharge is not prohibited by the United States Coast Guard (USCG) but the waste streams listed in the USCG definition of graywater are important to know due to restrictions when graywater is mixed with other waste streams. The following decision diagram should assist in ensuring that tankers over 400gt remain compliant with US graywater legislation. The diagram reflects the VGP requirements but due consideration should be given to the additional notes and guidance provided on pages 2 and 3 of this document. Does the vessel have the capacity to store graywater for the period it is within 1nm of shore? NO Was the vessel constructed before or after 19/12/2013? AFTER BEFORE Discharge of graywater within 1nm of shore is permitted BUT the vessel must minimise production and discharge of graywater while it is within 1nm of shore. Box 3 Box 1 YES Vessel must NOT discharge graywater within 1nm of shore. Box 2 Discharge of graywater within 1nm of shore is permitted BUT: 1. Vessel must minimise production and discharge of graywater while it is within 1nm of shore and; 2. Operator/owner must undertake monitoring, analysis and reporting in accordance with the VGP. Page 1

3 Discharge requirements 1. EPA The EPA s VGP does not specifically prohibit the discharge of graywater in US waters. Instead, the VGP regulates the discharge of graywater from vessels under certain circumstances, as follows. For tankers over 400gt that regularly travel more than 1nm from shore and have the capacity to store graywater for a sufficient period, graywater must be discharged greater than 1nm from shore while the vessel is underway (Box 1). For those tankers that do not have the capacity to store graywater for the period they are within 1nm of shore or they exceed the capacity for graywater storage having minimised its production, they are permitted to discharge. This discharge must however be minimised. This requirements also applies to tankers operating within marine sanctuaries, units of the National Park System, units of the National Wildlife Refuge System, National Wilderness areas, and national wild and scenic rivers system components as specified in Appendix G of the VGP. If the tanker discharges graywater within 3nm of shore then, depending on when it was constructed, monitoring, analysis and reporting requirements may apply to that vessel (Box 2 or Box 3). The VGP lists the monitoring, analysis and reporting requirements for vessels constructed after 19 December 2013 and are included in the Annex to this document. The EPA has confirmed to INTERTANKO that if the vessel does not discharge graywater in waters covered by the permit (Box 1) then the monitoring and analysis requirements do not apply. However, a vessel owner/operator needs to indicate in their Annual Report that they are not discharging the particular waste stream while in waters subject to the VGP. Discharge of graywater is prohibited when the tanker is: i. not using phosphate free and minimally toxic soaps. It is considered good practice to only procure phosphate free and minimally toxic soaps for all vessels trading to the US. ii. operating within the no discharge zones of the Great Lakes. 2. USCG The USCG does not prohibit the discharge of graywater in US ports or waters. However, discharge of graywater is prohibited in US waters if it is mixed with sewage or any other waste stream. Page 2

4 Definitions of Graywater EPA CWA VGP 2013 Graywater means galley, bath, and shower water, as well as wastewater from lavatory sinks, laundry, and water fountains. USCG CFR33 and CFR40 Graywater means drainage from dishwasher, galley, laundry, bath, and washbasin drains. It does not include drainage from other waste streams such as toilets, urinals, hospitals, and cargo spaces. Comments 1nm and 3nm references The requirements for graywater in accordance with section of the VGP specify discharges within or outside 1nm from shore. However, the waters subject to the permit are 3nm from shore. This is important to note as any vessel discharging graywater within the waters subject to the permit (3 nm) and constructed after 19 th December 2013 will have to meet the monitoring, analysis and reporting requirements, as specified, i.e. discharging graywater outside of the 1nm does not exclude new vessels from the graywater monitoring requirements. Ballast Water Treatment Systems If a vessel has a ballast water treatment system installed and the aft peak tank forms part of the ballast water system of the vessel then this tank cannot be used for the storage of graywater. Graywater Holding Tanks on Newbuilds While not currently a mandatory requirement, consideration should be given to the installation of a dedicated graywater holding tank(s) on newbuilds as this can allow the vessel to store graywater while within US waters and therefore remove the burden of monitoring and analysis in accordance with the EPA s VGP (see Annex). Additional more stringent graywater discharge limitations may be introduced in the future and may also necessitate additional storage capacity while ships are in ports and coastal waters worldwide. Page 3

5 Annex Extract from INTERTANKO s Guide to the VGP 2013: Graywater (2.2.15) Graywater Monitoring The following monitoring requirements are applicable to vessels which discharge graywater into waters subject to the VGP and are constructed after 19 December Vessel owners/operators must collect and analyze two samples per year, collected at least 14 days apart, and report the results of those samples as part of their Annual Report. Records of monitoring information shall include: The date, exact place, time, and sampling port location(s) of sampling or measurements; The date(s) analyses were performed; The individual(s) who performed the analyses; The analytical techniques or methods used; The results of such analyses; and Proportions of wastestreams being treated and sampled (such as mixed graywater, mixed graywater and blackwater, and galley. If actual amounts are not available, the estimated proportions should be provided). Vessels subject to this part must note whether the graywater effluent is treated or untreated, and also note whether the effluent is graywater alone or if it is mixed with another effluent type (e.g., graywater mixed with sewage). The Graywater Discharge Monitoring Report form is provided in Appendix H of the VGP. Vessels which do not enter waters subject to this permit for the calendar year need not conduct monitoring for that year, but must clearly indicate on their Annual Report that they did not enter waters subject to this permit during that year. Page 4