Section 2.10a regarding cooling water discharges should be deleted as it is a minimal impact on surrounding waters. If cooling water is included in the permit, what about the impacts of external heat exchangers (also minimal impact)
If desired, the section could contain a suggestion to limit the operation of main and auxillary engines as practical when a dockside.
Section 3.2: Add provision that vessels laid up (out of service) do not have to have a quaterly inspection during the laid up period.
Comment submitted by Thomas M. Kelly, Inland Seas Education Association
This is comment on Notice
Draft National Pollutant Discharge Elimination System (NPDES) General Permits for Discharges Incidental to the Normal Operation of a Vessel
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