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Ballast Water - VGP Compliance Monitoring

VGP’s ballast water monitoring requirements apply to ballast water discharges from vessels employing ballast water treatment systems that are used to achieve the effluent limitations.
Biological Indicators Monitoring
  • The 2013 VGP specifies that vessels using a ballast water treatment system (i.e., those subject to Part 2.2.3.5.1.1.1 of the 2013 VGP) must sample and analyze ballast water discharges for the following biological indicators:
    · Total heterotrophic bacteria
    · E. coli
    · Enterococci.
  • Once a ballast water treatment system is required to be installed onboard a vessel, any ballast water discharges from such vessels will be subject to the effluent limitations of this permit. To ascertain compliance with the effluent limitation in that section, EPA is establishing the following biological indicator compliance monitoring.
Parameters Type of Monitoring Devices for Which High Quality Type Approval Data Are Available Devices for Which High Quality Data Are Not Available
Biological Indicators Intial 2 times 4 times per year
Maintenance 1 or 2 times per year (*) 4 times per year
Residual Biocides Intial 3 times in the first 10 discharge events (not to exceed a 180 day period). 5 times in the first 10 discharge events (not to exceed a 180 day period).
Maintenance 2 times per year 4 times per year

(*)if sampling results are below permit limits for two consecutive events, the vessel owner/operator may reduce monitoring to one time per year after the first year.

Monitoring Parameters for Biological Indicators
Measurement Analysis Standard Method VGP Limit
Total heterotrophic bacteria Plate Counts SM 9215 Not Established
E. coli SelectiveSubstrate SM 9223B < 250 CFU / 100mL
Enterococci Selective Substrate SM 9230C < 100 CFU / 100mL
Biocides and Residuals Monitoring
  • Vessels subject to Part 2.2.3.5.1.1.1 of the 2013 VGP must conduct monitoring of the ballast water discharge for any residual biocides or derivatives used in the treatment process to demonstrate that residual biocides or derivatives are in compliance with this permit.
  • In order to demonstrate that residual biocides or derivatives are in compliance with this permit, that substantial quantities of harmful byproducts are not produced, and provide EPA with needed information about system functionality, the vessel operator initially must take samples according to the following:
Monitoring Schedule for Residual Biocides or Derivatives of the Residual Biocide
Type of Monitoring Devices for Which High Quality Type Approval Data Are Available Devices for Which High Quality Type Approval Data Are Not Available
Intial 3 times in the first 10 discharge events (not to exceed a 180 day period). 5 times in the first 10 discharge events (not to exceed a 180 day period).
Maintenance 2 times per year 4 times per year
Analytical Method Details for Residual Biocides and Biocide Derivative
Analyte Methods Biocide Effluent Limit
Chlorine or
Chlorine Dioxide		 Ozone
Chlorine Dioxide SM 4500 ClO2 E ✓ ✓ 200 μg/L
TRO as Cl2 SM 4500-Cl G ✓ ✓ 100 μg/L
Chlorite EPA Method 300.1 ✓ ✓ Report
Chlorate EPA Method 300.1 ✓ ✓ Report
Total trihalomethanes EPA Method 8260 ✓ ✓ Report
Haloacetic acids EPA Method 552.2 ✓ ✓ Report
Bromate EPA Method 300.1 ✓ ✓ Report
Bromoform EPA Method 8260 ✓ ✓ Report
Our Services
  • Onboard Attendance for Sampling acc. to ETV Protocol, as well as BWMS code and Field Testing acc. To 40 CFR 136.3 methods
  • Sampling bottles and containers as per VGP methods’ requirements.
  • Transportation of the samples within the required timeframes.
  • Transportation of the samples with the required conditions (preservatives/light/temperature conditions etc)
  • Lab Testing with EPA designated methods (40 CFR 136.3 methods) in Accredited Laboratories
  • Reporting as per EPA requirements
  • Guidance on Regulations – Provision of 30-page Guide
  • Technical Support and Customer Care