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EPA's Vessel General Permit and Small Vessel General

EPA's Vessel General Permit and Small Vessel General

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quantify the annual number of newly documented ballast water ANS. It should be noted that this<br />

database does not include all ANS that were introduced by ballast water; rather, it represents the<br />

number of ballast-water-mediated ANS documented nationwide. Therefore, in using this<br />

database, we expect considerable ascertainment bias, i.e., greater effort is likely to increase the<br />

number of ANS detected. The number of documented ANS grossly underestimates the total<br />

number of invasions because there are no monitoring programs throughout most waters of the<br />

U.S. Still, these data provide a qualitative measure of exposure of listed resources to<br />

documented ballast-water-mediated ANS.<br />

In querying the database (http://invasions.si.edu/nemesis/browseDB/searchQuery.jsp), we<br />

limited our search criteria to only include ballast water ANS documented in a single calendar<br />

year. We performed this search for each year between 2008 <strong>and</strong> 2011 (years covered under the<br />

previously issued VGP). The annual number of newly documented ballast-water-mediated ANS<br />

in waters of the U.S. ranged from 2 to 8 species, with a mean of 5.75 (95% CI: 4.5 – 7.0).<br />

The numeric st<strong>and</strong>ards in the VGP are likely to reduce ballast-water-mediated ANS invasion<br />

rates; therefore, we expect that the number of documented ANS invasions is likely to be reduced<br />

over the life of the permit. Under the sVGP, however, equivalent st<strong>and</strong>ards are not required, <strong>and</strong><br />

the only sVGP requirement that would substantially reduce exposure of listed species to ballastwater<br />

ANS is “minimize or avoid ballast water discharge <strong>and</strong> update in critical habitat.” Thus,<br />

there remains a small likelihood that listed resources would be exposed to ANS invasions as a<br />

result of ballast water discharges authorized by the VGPs.<br />

Other Vectors<br />

Several other discharges incidental to the normal operation of a vessel serve as potential vectors<br />

for ANS. These include effluent from chain lockers, seawater cooling systems, <strong>and</strong> use <strong>and</strong><br />

disposal of live bait. Less is known about these discharges <strong>and</strong> their potential to serve as ANS<br />

vectors; however, they are generally considered to be significantly less important than hull<br />

fouling <strong>and</strong> ballast water.<br />

Chain locker effluent is water that collects in the below-deck storage area during anchor<br />

retrieval. A sump collects the liquids <strong>and</strong> materials that enter the chain locker <strong>and</strong> discharges it<br />

overboard or into the bilge. Chain locker effluent may contain marine organisms including ANS.<br />

The sVGP does not require any actions to minimize ANS transfer in chain locker effluent. To<br />

minimize the number of ANS in chain locker effluent, EPA has included the following<br />

requirements in the VGP:<br />

� The anchor chain must be carefully <strong>and</strong> thoroughly washed down (i.e., more than a<br />

cursory rinse) as it is being hauled out of the water to remove sediment <strong>and</strong> marine<br />

organisms.<br />

� Chain lockers must be thoroughly cleaned during dry-docking<br />

The surfaces of seawater cooling systems, especially sea chest intakes <strong>and</strong> seawater piping, can<br />

support the growth of fouling organisms including ANS. In vessel sea chests, Coutts et al.<br />

230

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