GMS

Gallagher Marine Systems, LLC.

06 February 2009
Client Advisory #05-09
Vessel General Permit Important Update
Overview:
This Client Advisory is intended to announce important information concerning the Vessel
General Permit (VGP).
1. On 05 February 2009, the US EPA hosted a 2-hour Webcast regarding the Vessel
General Permit. The discussion encompassed the entire VGP and allowed for the
audience to ask a wide variety of questions. GMS recorded the webcast session for
transcription. The Webcast will be available for review on the EPAs website in
approximately 3 weeks, as discussed in Client Advisory 04-09. We will review the
recording carefully and report key discussions and statements in a Client Advisory
which we will distribute early next week. In the interim, slides from the Webcast are
available online at:
http://www.epa.gov/npdes/webcasts/presentations/vessels_webcast_download.pdf
2. The Final VGP has been amended to reflect changes to the State Certifications of New
Jersey, Illinois, and California. All of these changes eased some of the additional
requirements imposed by these states:
EPA Webcast:
One of the most important statements made by the EPA during their Webcast is that they
intend to perform Compliance Assistance for the first few months of the Permit. We believe
this means that, if your vessel is boarded by an EPA Agent or their representative, they will
evaluate your compliance and offer constructive criticism rather than issue citations. If the
vessel has started complying using the GMS VGP Compliance System they should expect
no violations, unless an egregious violation of effluent control is observed.
Although the EPA is offering this short period of assistance versus enforcement, we believe it
best to work towards full compliance.
State Certifications:
Several VGP Part 6 permit conditions (Specific requirements for individual States or Indian
Country Lands) have been deleted.

New Jersey Department of Environmental Protection issued its section 401

certification for the VGP on September 24, 2008, and modified its certification
on February 2, 2009.
This modification deleted certification conditions #1 and #2, which effectively
removes New Jerseys total ban on treated or untreated graywater discharge
in New Jersey waters.
Therefore the graywater discharge limitation in New Jersey is now the same
as the core VGP requirements.

GMS Headquarters
100 Century Parkway Suite 130
Mount Laurel, New Jersey 08054
(T) +1 856 642 2091
(F) +1 856 642 3945
(E) info@chgms.com

Field Offices
Houston, Texas
British Columbia, Canada
Springfield, Virginia
(E) info@chgms.com

Marispond Hellas, Inc.

81 Akti Miaouli, 6th Floor
Piraeus, Greece 185 38
(T) 30 210 428 7713-5
(F) 30 210 428 7716
maris@ath.forthnet.gr

GMS Japan, LLC.

Takeda House, 13-5 Sumiyoshi, 1-chome
Koto-Ku, Tokyo, Japan 135-0002, Japan
(T) 81-3-3846-0066
(F) 81-3-3846-9730
(E) sensui_gms@ybb.ne.jp

GMS
Gallagher Marine Systems, LLC.

06 February 2009
Client Advisory #05-09
Vessel General Permit Important Update
State Certifications: (Continued)

Illinois Environmental Protection Agency issued its section 401 certification

for the VGP on November 21, 2008, and modified its certification on February
4, 2009.
This modification deleted certification condition #9, effectively removes Illinois
total ban on treated or untreated graywater discharge in Illinois Waters.
Therefore the graywater discharge limitation in Illinois is now the same as the
core VGP requirements.

California State Water Resources Control Board issued its section 401
certification for the VGP on December 17, 2008, and modified its certification
on February 4, 2009.
This modification deleted certification conditions #1, #2, #5, #7, #8, #9, #10,
#13, #14, #15, and 7.1 and 7.2 from certification condition #16 and
Attachments 4, 5, and 6 from certification condition #17.

Client Advisory 02-09 listed these specific Conditions, and you are encouraged to
compare the above deletions against our Client Advisory 02-09.
For California, these deletions removed the requirements for extensive effluent sampling
and laboratory analysis. Additional reporting requirements still remain for California, but
the cancellation of the sampling requirements is welcome news and will result in a large
cost savings and minimize potential for inadvertent violations.
State Supplement to the VGP Compliance System:
Given that GMS was advised that State conditions might change, we had postponed
distribution of the VGP Compliance System State Supplement. With the announcement of
the changes above, we will proceed with final draft and distribution. This shortened
document will be distributed electronically in the near term.
Questions regarding this matter should be directed to: info@chgms.com
Page 2 of 2
END OF ADVISORY

GMS Headquarters
100 Century Parkway Suite 130
Mount Laurel, New Jersey 08054
(T) +1 856 642 2091
(F) +1 856 642 3945
(E) info@chgms.com

Field Offices
Houston, Texas
British Columbia, Canada
Springfield, Virginia
(E) info@chgms.com

Marispond Hellas, Inc.

81 Akti Miaouli, 6th Floor
Piraeus, Greece 185 38
(T) 30 210 428 7713-5
(F) 30 210 428 7716
maris@ath.forthnet.gr

GMS Japan, LLC.

Takeda House, 13-5 Sumiyoshi, 1-chome
Koto-Ku, Tokyo, Japan 135-0002, Japan
(T) 81-3-3846-0066
(F) 81-3-3846-9730
(E) sensui_gms@ybb.ne.jp