Maritime Compliance Report
Welcome. Staying in compliance takes dedication, diligence and strong leadership skills to stay on top of all the requirements which seem to keep coming at a rapid pace. With this blog I hope to provide visitors with content that will help them in their daily work of staying in compliance. I hope you find it a resource worthy of your time and I look forward to your feedback, questions, comments and concerns. Thanks for stopping by.
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EPA VGP One-Time Reports Due
At our last professional development workshop on EPA VGP and MARPOL Annex VI there was lots of concern about the EPA VGP one-time report which is currently coming due. My excellent contact at the EPA has provided some very specific and detailed information about the 30-36 month window. Below are his comments on the matter: First, EPA HQ has updated the electronic reporting page FAQ with many answers that address when one time reports are due for different scenarios. The FAQ can be found at http://cfpub.epa.gov/npdes/vessels/vesselsreporting.cfm#submit
Additionally, below are the scenarios posed to HQ and the answers received back:
Existing non-NOI vessels: The 30-36 month clock started on the permit effective date: December 19, 2008.
Existing NOI vessels: The 30-36 month clock started on the date permit authorization was granted after the submission of a NOI (can assume Sept. 19, 2009 as the date the NOI grace period ended).
Newly built non-NOI vessels: The 30-36 month clock starts the day sea-trials begin (or the vessel starts discharging waste streams covered by the permit)
Newly built NOI vessels: The 30-36 month clock starts the date permit authorization was granted after the submission of a NOI (normally before sea trials)
Existing non-NOI vessels where ownership was transferred: The 30-36 month clock started on the permit effective date of December 19, 2008.
Existing NOI vessels where ownership was transferred: The 30-36 month clock started on the date of original NOI (vessels first NOI coverage date)
Additionally, below are the scenarios posed to HQ and the answers received back:
Existing non-NOI vessels: The 30-36 month clock started on the permit effective date: December 19, 2008.
Existing NOI vessels: The 30-36 month clock started on the date permit authorization was granted after the submission of a NOI (can assume Sept. 19, 2009 as the date the NOI grace period ended).
Newly built non-NOI vessels: The 30-36 month clock starts the day sea-trials begin (or the vessel starts discharging waste streams covered by the permit)
Newly built NOI vessels: The 30-36 month clock starts the date permit authorization was granted after the submission of a NOI (normally before sea trials)
Existing non-NOI vessels where ownership was transferred: The 30-36 month clock started on the permit effective date of December 19, 2008.
Existing NOI vessels where ownership was transferred: The 30-36 month clock started on the date of original NOI (vessels first NOI coverage date)
**NOTE: For vessels where the 30-36 month time frame falls after December 19, 2013, a one time report is not required to be submitted. See the last FAQ on the above referenced website
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