EPA's Vessel General Permit and Small Vessel General

For vessels covered under the VGP, EPA requires vessel owners/operators to carefully and
thoroughly wash down (i.e., more than a cursory rinse) the anchor chain, as it is being hauled out
of the water to remove sediment and marine organisms. They require vessel owners/operators to
clean chain lockers thoroughly during dry-docking to eliminate accumulated sediments and any
potential accompanying pollutants. For vessels that regularly sail outside waters subject to this
permit (at least once per month), vessel owners/operators are required to periodically clean,
rinse, and/or pump out the space beneath the chain locker prior to entering waters subject to this
permit (preferably mid-ocean) if the anchor has been lowered into any nearshore waters and if
technically feasible. For vessels that leave waters subject to this permit at least once per month,
EPA prohibits vessel owners/operators from rinsing or pumping out chain lockers in waters of
the U.S., unless not emptying them would compromise safety, in which case the safety claim
must be documented in the vessel’s recordkeeping documentation.
Controllable Pitch Propeller and Thruster Hydraulic Fluid and Other Oil-to-Sea Interfaces
Oil to sea interfaces include any part of a vessel where seals or surfaces may discharge oil into
waters of the U.S. These discharges include lubrication discharges from paddle wheel
propulsion, stern tubes, thruster bearings, stabilizers, rudder bearings, azimuth thrusters, and
propulsion pod lubrication, and wire rope and mechanical equipment subject to immersion in
water. Examples include machinery that uses hydraulic oils or has parts that are lubricated with
greases or oils. An additional example is the stern tube. Riggings and cables may also have
surfaces that are lubricated with oils or greases and may cause discharges of these substances
into waters of the U.S. As noted by EPA, these discharges can be substantial.
The EPA does not authorize the discharge of any lubricant in a quantity that may be harmful as
defined in 40 CFR Part 110. For vessels covered under the VGP, EPA requires vessel
owners/operators to maintain protective seals on oil-to-sea interfaces in good operating order to
minimize the leaking of hydraulic oil or other oils. Vessel owners/operators are prohibited from
discharging oil in quantities that may be harmful as defined in 40 CFR Part 110 from any oil-tosea
interface. Vessel owners/operators are required to minimize maintenance activities on stern
tube seals when a vessel is outside of drydock. If maintenance or emergency repair must occur
on stern tubes or other oil-to-sea interfaces which have a potential to release oil in quantities that
may be harmful as defined in 40 CFR Part 110, appropriate spill response equipment (e.g., oil
booms) must be used to contain any oil leakage. The EPA requires operators of the vessel to
have ready access to spill response resources to clean up any oil spills. After applying
lubrication to wire rope and mechanical equipment subject to immersion, wire ropes, and other
equipment must be thoroughly wiped down to remove excess lubricant. For vessels constructed
on or after December 19, 2013, EPA requires the use of an environmentally acceptable lubricant
in all oil-to-sea interfaces. “Environmentally acceptable lubricants” means lubricants that are
“biodegradable” and “non-toxic” and are not “bioaccumulative” as defined in Appendix A of the
VGP. For vessels built before December 19, 2013, unless technically infeasible, EPA requires
owners/operators to use an environmentally acceptable lubricant in all oil to sea interfaces or
document and report why they are unable to do so and which lubricant was used in their annual
report (submitted electronically to EPA).
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