EPA's Vessel General Permit and Small Vessel General

� Limiting use of hard brushes and surfaces to the removal of hard growth; and
� When available and feasible, use of vacuum or other control technologies to minimize the
release or dispersion of antifouling hull coatings and fouling organisms into the water
column.
The EPA requires vessel owners/operators to minimize the release of copper-based antifoulant
paints during vessel cleaning operations. They require cleaning of hull surfaces coated with
copper-based antifoulant paint that would not result in any visible cloud or plume of paint in the
water; if a visible cloud or plume of paint develops, they require vessel owners/operators to shift
to a softer brush or less abrasive cleaning technique. A plume or cloud of paint can be noted by
the presence of discoloration or other visible indication that is distinguishable from hull growth
or sediment removal. Production of a plume or cloud of sediment or hull growth is normal in
some cases during vessel hull cleaning, but this plume or cloud must be substantially paint free
(e.g., paint should not be clearly identifiable in the plume or cloud). The EPA requires
owners/operators to minimize the release of fouling organisms and antifouling systems
(including copper-based coatings) into surrounding waters. They require vessel
owners/operators to minimize hull husbandry in critical habitat for aquatic species. Vessels that
use copper-based anti-fouling paint must not clean the hull in copper-impaired waters within the
first 365 days after paint application unless there is a significant visible indication of hull fouling.
EPA maintains a list of copper-impaired waters on its webpage at www.epa.gov/npdes/vessels.
If vessel owners or operators clean before 365 days in copper-impaired waters, they must
document in their recordkeeping documentation why this early cleaning was necessary.
Welldeck Discharges. The welldeck is a platform used for launching or loading boats and cargo.
Discharges from welldecks may include pollutants from equipment washing, and oils and other
materials associated with engines and machinery.
For vessels covered under the VGP, EPA prohibits welldeck discharges from washdown of gas
turbine engines. Welldeck discharges from equipment and vehicle washdowns must be free from
garbage and must not contain oil in quantities that may be harmful as defined in 40 CFR Part
110.
Graywater Mixed with Sewage from Vessels. Except for commercial vessels in the Great Lakes,
discharges of graywater that contain sewage are eligible for coverage under the VGP and must
meet additional effluent limits as described in the permit as well as any additional requirements
applicable to sewage discharges outside of the VGP.
For vessels covered under the VGP, EPA requires that commingled discharge of graywater and
sewage must comply with the effluent limits for graywater discharge and meet the requirements
set forth in section 312 of the CWA.
Exhaust Gas Scrubber Washwater Discharge. Exhaust Gas Scrubber washwater discharges
(EGS washwater discharge) occur from exhaust gas cleaning systems on diesel engines. Some
pollutants are transferred to the vessel’s sludge tank, but the remainder may be discharged into
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