Monday, February 14, 2011

killing trees at sea:NPDES: we heart redundancy

Note: this is an opinion-based editorial, and does not reflect the views of anyone but myself (and every thinking mariner out there).

Marine Log: USCG and EPA cooperate on NPDES

(That's the National Pollution Discharge Elimination System, to you).

I read this at about 0430, and almost immediately flash-digested my breakfast bagel from the acid that suddenly made itself known in my digestive system.

Some tofu-eating, hairy-footed hippies sued the EPA a few years ago, and created a horrific bureaucratic nightmare whereby the EPA was suddenly forced to get involved in oversight of ship-related pollution, something which the Coast Guard has been dealing with for some time, in fact, and the EPA had not, beyond at least, the legislative level. What followed has been the largest single joke at sea since the MARSEC security program. But the joke is on everyone, you see- this one isn't funny to anybody whatsoever (unlike the MARSEC program, which was a laugh riot to some dockside security guards, whom I remember vividly fantasizing about hitting with a shackle, as they gleefully turned away our incoming and outgoing mail for Christmas a few years ago, effectively canceling Christmas for about a dozen families).

With the advent of the NPDES paperwork nightmare- and it IS a nightmare for shoreside and afloat operations- a foot-thick pile of paper is generated each year for every commercial vessel over 78 feet in length. At the operational level, this translates into two additional items for on-scene staff- look for sources of pollution, and write them down if found. For the manager, this means that it's necessary to track and monitor the fixing of these problems- something that already gets done, in fact, for insurance purposes and also to maintain compliance with safety management systems that are already mandated under international law.

Redundancy is the name of the game. The EPA is running scared that they'll get sued again, so they kick the shitpile downhill. So it goes. In the process, more paperwork is generated.
I'm lucky in that I don't have to worry about whose mandate gets fulfilled first in these games. The Coast Guard are the gatekeepers for the afloat staff in the oil biz, but forget to carry out or log the weekly NPDES inspection, and the EPA throws around a magic money figure of $10,000 penalty for each day you fail to log the inspection. This is neither here nor there, however, as the EPA does not actually exert inspectorate authority over the matter! The devil being in the details, the only way the NPDES penalty could conceivably be levied is after an incident, when the paper trail goes public, and the horse is not only out of the barn, but has jumped the fence, fallen in a ditch, and plugged up the drain running under an overpass.

This isn't to say that the unwieldy NPDES paper train is a paper tiger- no, point in fact it's yet another monster to be appeased by throwing precious sleep hours into a furnace, and another source of indigestion to yours truly (I make a habit of checking the inspection log every other day, fear of missing a date being a source of anxiety that robs me of sleep).

Now, what grinds my gears is that this is another example of performance theatre. Like maritime security in general, the EPA has to be seen as doing something, or they'll take it in the seat and have less money for brainstorming insane carbon-trading schemes (and stifling actual pollution prevention in the process). So now we've got yet another redundancy to deal with, whereby multiple agencies have multiple identical reporting, monitoring and tracking responsibilities, and punitive power. So, instead of the Coast Guard hovering over us and watching our every move- and doing their job in the process, we've got the Coast Guard hovering over us and watching every move like always, plus a hopeful buzzard circling not to high overhead in the form of the EPA, waiting for the Coast guard's activity to wrap up and the opportunity to tear off a piece of whatever scraps are left behind.
This serves no true purpose, in my eyes- the waters are by no means made cleaner by the EPA in this effort- and I make no bones about saying that I enjoy the visibly less-polluted waters that have come to pass in the nearshore in the last 20 years- but, instead we've got a parasitic bureaucratic program that feeds off the blood of the herd, and truly provides no benefit whatsoever in the process. No ship's deck is cleaner than it was before the NPDES regulations were passed- the Coast Guard and assorted state agencies already saw to that; no, through an impossible situation, the EPA had to fend off Environment, Inc, via a wonderful dramatic reenactment of pollution prevention programs already in place, and, as always, everyone else pays.


eastriver said...

"...but forget to carry out or log the weekly NPDES inspection..."

Don't you mean "daily inspection?"

Paul, Dammit! said...

Eastriver- sort of yes, but not always- for brevity purposes, I didn't get into enough depth, I suppose. I sometimes annoy myself by skimming blithely over important procedures in my writing.

Inspections are required at either one week or once-per-voyage intervals, whichever is shortest. (Per sec 4.1.1)in the boilerplate portion of the VGP. So, yes, inspections are often carried out more than once a week, as necessary.

Now, I just deleted a 1-page treatise on our logging procedures, but for sacred brevity's sake (and as a conversation piece), I do keep a separate weekly inspection binder- it prevents log-entry gaps and brain farts in the slow times, and is a wonderful appetizer for ISM inspections- Everyone's invited to hunt and peck for mandated inspection dates and entries in the appropriate logbooks, but there's nothing like having a concrete reference to start from. I've found that by planning for this ONE often-duplicate inspection, it prevents others. I'm a creature of habit.

eastriver said...

Thanks. Our company reads it as a DAILY inspection, and once per voyage if the voyage is 7 days or less. So I guess we're killing even more trees. Not just in this regard, but elsewhere -- the paper chain is wagging our ATB (and then we get attitude when we need paper or printer ink, again.)

Spoke to our port captain as to doing this on, perhaps, a one-page-per-week kind of form, and I was told that it might be coming, maybe, sometime in the future, hopefully, don't-hold-your-breath.