b'tions, record keeping, and an annual report.ing. These modifications are being proposed toto further prevent or reduce the discharge of pol-Review your VGP efforts and correct deficien- address specific VIDA requirements as well aslutants into these waterbodies that may contain cies as soon as possible. Vessels have been oper- incorporate new information that has becomeunique ecosystems, support distinctive species of ated under the VGP since 2013 so your com- available since the issuance of the VGP. aquatic flora and fauna, contend with more pliance practices should be readily identifiablesensitive water quality issues, or otherwise re-and a matter of routine.CWASection312(p)alsodirectsEPAtoes- quire greater protection. tablish additional discharge requirements for While we have not seen any EPA work productvessels operating in certain bodies of water, toThe complete 84 pages of the docket discus-as a result of public comments to the NPRM,include: The Great Lakes, the Pacific Re- sionwithadditionalsupportingmaterial we can get a sense of the expected end resultgion, and waters subject to Federal protection,andthe28,701publiccommentsreceived from the Executive Summary section of thein whole or in part, for conservation purposestodatecanbefoundatregulations.govby NPRM that follows: (federally-protectedwaters).TheproposedusingthedocketidentificationEPA-HQ-rule would establish place-based requirementsOW-2019-0482. Pursuant to the VIDA, the proposed discharge standards of performance are proposed to be at least as stringent as the VGP, with some exceptions discussed below. However, the pro-posed standards do not incorporate the VGP requirementsverbatim.EPAisproposing changes to the VGP requirements to transi- The Trusted Source for tionthepermitrequirementsintonational technology-basedstandardsofperformance,Quality Systemsimproveclarity,enhanceenforceabilityand implementation,orincorporatenewinfor-mation and technology. In some cases, this re-sulted in EPA consolidating or renaming the VGP requirements to comport with the VIDA. Asproposed,thesimilaritiesanddifferenc-es between the requirements in the proposed discharge standards of performance and the requirements in the VGP can be sorted into three distinct groups. The first group consists of 13 proposed discharge standards that are sub-stantially the same as the requirements of the VGP: Boilers, cathodic protection, chain lock-ers, decks, elevator pits, fire protection equip-ment, gas turbines, inert gas systems, motor gasoline and compensating systems, non-oily machinery, pools and spas, refrigeration and air conditioning, and sonar domes. These 13 proposed discharge standards encompass the intent and stringency of the VGP but include other changes in response to the VIDA (e.g., extent of regulated waters, consistency across discharge standards, enforceability and legal precision, as well as minor clarifications). The second group consists of two proposed discharge standardsthatareconsistentbutslightly modified from the VGP to expand controls or provide greater language clarifications: Bilg-es and desalination and purification systems. The third group consists of five proposed dis-charge standards which contain the greatest modifications from the VGP: Ballast tanks, exhaust gas emission control systems, graywa- THRUSTERSLIGHTINGSEATINGDOORSTRIM CONTROLWIPERSCONTROLSter, hulls and associated niche areas, and sea-water piping. In addition, EPA is proposing to modify slightly the requirements as they apply in federally-protected waters for five discharg-es: Chain lockers, decks, hulls and associatedwww.imtra.com 508.995.7000niche areas, pools and spas, and seawater pip-27 APRIL 2023'