The Maritime Institute of Technology and Graduate Studies (MITAGS) and Pacific Maritime Institure (PMI) announced their upcoming “Introduction to the Maritime Environment and EPA General Permit” Course.
With the introduction of the Vessel General Permit the EPA has captured an estimated 70,000 additional regulated units that have previously been exempt from permitting requirements in U.S. waters. This new universe of permitees, while previously subject to many international, national, State and Local requirements, will be challenged to understand, incorporate and manage a new set of requirements on discharges previously unregulated by the EPA in the brief time granted for implementation by the permit.
A Clean Water Act permit is a unique regulatory tool with which commercial vessel operators have little to no experience. Training will be required not only on the specific requirements of this permit, but also on the environmental aspects of vessel operations, reading and interpretation of the Vessel General Permit, monitoring, recordkeeping and reporting, notification requirements, notice of intent as well as other aspects of permit implementation.
The course is designed in two one-day modules. The first day is an introduction to the environmental aspects of vessel operations and the basic structure of the marine international and federal regulatory environment. This module is intended to give vessel operators a broad perspective on the potential environmental impacts of their operations in order to gain a greater appreciation for why the permit has been required. This section will cover MARPOL and US Coast Guard Act to Prevent Pollution from Ships requirements, focusing principally on bilge water, ballast water, gray and blackwater as well as air pollution prevention requirements under international and federal law. Vessel General Permit requirements for these discharges will be covered; however the more complete discussion on the vessel general permit will be expanded upon in the second day of the class.
Module 2 consists of one day devoted specifically to the permit. Each student will be provided a copy of the vessel general permit, and much of the class will involve discussion and analysis of permit language focusing on how requirements will apply to specific vessels operated by the students. Several classroom exercises will reinforce key learning concepts while catering to the more active learning demands of the adult student. Specific requirements for permit administration will be covered, providing the student with insight into the management systems necessary to assure compliance.
The class will focus on effluent limitations, corrective actions, monitoring recordkeeping and reporting. The importance and implications of certification statements will be emphasized. Classroom discussion and activities will be intended to lead the student through active learning exercises in applying permit concepts to their operations.