1
o WINTER 2011
IN THIS ISSUE:
~ MODIFICATIONS	1
United States
Environmental Protection
Agency
~	UPDATE ON SAB	2
~	NEW ETV PROTOCOLS....2
NAVIGATING THE EPA REGULATED VESSELS UNIVERSE
MODIFICATIONS TO IOWA and PENNSYLVANIA 401 CERTIFICATION CONDITIONS
On December 10, 2010, EPA provided notice in the Federal Register of EPA's deletion of specific state section 401
certification conditions from Part 6 of the Vessel General Permit (VGP) for both Pennsylvania and Iowa. EPA may, at
the request of a permittee, modify the VGP based on a modified certification received after final agency action on the
permit "only to the extent necessary to delete any conditions based on a condition in a certification invalidated by a
court of competent jurisdiction or by an appropriate state board or agency," 40 CFR 124.55(b). In accordance with this
provision, EPA has removed these deleted certification conditions from the VGP. EPA's letters notifying the requesting
permittees that their requests to delete the permit conditions were granted, and a copy of the VGP reflecting those
deletions can be found in Docket ID No. EPA-HQ-OW-2008-2005 at http://www.requlations.gov.
To view the Federal Register notice announcing the deletions, please visit
http://cfpub.epa.gov/npdes/vessels/vqpermit.cfm
Spotlight on A.P. Moller - Maersk
A.P. Moller - Maersk, commonly referred to as "Maersk," is a publicly traded
corporation that operates container ships, tankers and supply vessels, many of which
operate in US waters. According to company officials, it has been proactive with
implementing EPA's Vessel General Permit since it came into force in 2008. EPA
asked Jai Alimchandani, Maersk's Deputy Head of Regulatory Affairs, to provide
insight into how one of the world's largest shipping companies is able to effectively
implement the VGP.
According to Mr. Alimchandani, before the VGP came into force in 2008, Maersk was
in full compliance with international and local environmental requirements. As a result,
Maersk already had procedures in place controlling many discharge categories
identified in the VGP, such as bilgewater and ballast water. When EPA released the
final 2008 VGP, the company analyzed each discharge category's requirements
individually and developed an action plan for each discharge. Additionally, the
company read through the VGP Fact Sheet, the frequently asked questions (FAQs),1
and asked for assistance directly from EPA representatives. Maersk found that the
VGP had several overlapping requirements with other regulations, and continued
using several of the procedures they already had in place. For all vessels, Maersk
developed separate procedures specifically for the VGP that cross-reference their
Continued on page 2
To learn more about the NPDES vessels program, please visit httv://www.eva.qov/rwdes/vessels. For questions or
concerns about the VGP, please e-mail CommercialVesselPermit@eipa.aov.
~	OPEN HOUSE MEETING ON
VGP HELD IN HOUSTON TX... 1
~	SPOTLIGHT ON A.P. MOLLER
-MAERSK	1-2
~	VGP LISTENING SESSION
HELD IN DECEMBER	2
Quarterly
OPEN HOUSE MEETING
ON VGP HELD
IN HOUSTON, TX
On November 19, 2010, EPA
was invited to speak and listen
at an industry-sponsored
meeting on the VGP in
Houston, Texas. EPA
presented an overview of the
VGP and answered questions
from meeting participants. Four
speakers from the maritime
industry gave presentations on
the challenges associated with
implementing the VGP. More
than 50 participants
representing numerous groups
attended the meeting.

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UPDATE ON SAB's
EVALUATION OF
SHIPBOARD BALLAST
WATER TREATMENT
PROCESSES
VGP LISTENING SESSION HELD IN DECEMBER AND
EARLY PUBLIC INPUT SOLICITED
Thank you to all the stakeholders who participated in the VGP listening session
held on December 15, 2010, and provided written comments to the accompanying
docket. The listening session served as an additional opportunity for the public to
recommend changes or additions for the development of the next VGP. In total,
between 100-150 people participated in the listening session in person or on the
phone. In addition to comments received at the listening session, EPA received
written comments from approximately 4,000 stakeholders. EPA will use the
comments, which are located in the docket, (available at
http://www.requlations.gov. Docket ID No. EPA-HQ-OW-2010-0828) to inform
decisions for developing the next VGP. The current VGP expires on December 19,
2013.
Spotlight on A.P. Moller - Maersk (continued)
Continued from page 1
original internal procedures. This way,
prior to calling on the United States,
all the vessel had to do was
implement the requirements.
Although the VGP had many
requirements that Maersk vessels
were already implementing, the
company did have to adopt some new
procedures. Maersk adopted new
best management practices for chain
locker effluent, elevator pit effluent,
and refrigeration and air condensate
discharge, amongst others. Initially,
the company also had difficulty
interpreting the routine, quarterly and
annual inspections required by the
VGP for vessels infrequently calling
on the US. After reviewing certain
answers found in EPA's Response to
Comments document to the proposed
2008 VGP2, Maersk instructed their
ships to perform, as a minimum, one
each of these inspections prior to
entering US waters. Additionally,
Maersk, like many other shipping
companies, has found the Clean
Water Act Section 401 certification
requirements to be challenging since
they allow different
states to impose more stringent
conditions for vessel discharges,
thereby resulting in a lack of national
consistency for discharges incidental to
the normal operation of vessels.
When EPA asked Mr. Alimchandani
how he would advise other ship
owner/operators to comply with the
VGP, Mr. Alimchandani imparted the
following advice: "The program does
seem daunting at first when taken as a
whole and there are aspects that can
prove onerous and challenging.
However, it does make it easier dealing
with each discharge category
individually and then consolidating the
result in a 'NPDES VGP Manual,' a
copy of which may be maintained
onboard."
Jai Alimchandani, a Marine Engineer by
training, has worked for A. P. Moller -
Maersk since 1981. In the past, he has
worked as chief engineer and inspector.
He currently works in Maersk's Head
Office in the Regulatory Affairs
Department ensuring regulatory
compliance of all company vessels.
1.	located on the right hand bar on EPA's vessel
discharges website
('http://www.epa.aov/npdes/vessels')
2.	can be found at http://www.reaulations.aov
under docket number EPA-HQ-OW-2008-0055
NEW ENVIRONMENTAL TECHNOLOGY VERIFICATION (ETV)
PROTOCOLS FOR SAMPLING BALLAST WATER DISCHARGES
On October 26, 2010, and
November 4, 2010, EPA's
Science Advisory Board (SAB)
held teleconferences
discussing their preliminary
advice on the status of existing
and future ballast water
treatment technologies. During
the calls, SAB committee
members presented draft text
for committee deliberation in
preparation of developing a
draft report on shipboard
ballast water treatment
processes.
The next SAB meeting is
scheduled for January 25 and
26, 2011, in Washington, DC,
and its purpose will be to
discuss the first draft of the
SAB's report. The draft report
will be made available on the
SAB website one week before
the meeting. The meeting is
open to the public, and a
phone line will be provided for
those who cannot attend in
person.
For more information and to view a
copy of the SAB's draft text, please
visit
http://vosemite. epa. gov/sab/sabprod
uct.nsf/fedrgstr activites/BW%20dis
charae?QpenDocument
EPA recently finalized new ETV protocols for sampling ballast water discharges
from land-based testing facilities titled, "Generic Protocol for the Verification of
Ballast Water Treatment Technology." The ETV program verifies the performance
of innovative technologies that have the potential to improve protection of human
health and the environment. This protocol was developed through a collaboration
between EPA and the United States Coast Guard. To view a copy of the ETV
protocol, please visit http://www.epa.gov/nrmrl/pubs/600r10146/600r10146.pdf.
EPA's SAB is charged with
evaluating the effectiveness of
shipboard ballast water treatment
processes to minimize the potential
spread of invasive species through
ballast water discharges from
vessels. Conclusions from the panel
will help inform EPA in developing
ballast water effluent limits and
related requirements for the next
VGP. EPA expects a final report
from the SAB in late spring 2011.

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