VGP Water Testing

Ballast Water - VGP & VIDA Compliance Services

Ensure Your Vessel’s Compliance with U.S. EPA and USCG Regulations

Vessels calling at ports in the United States must comply with regulations established by the US EPA 2013 Vessel General Permit (VGP) and the forthcoming Vessel Incidental Discharge Act (VIDA).

Such vessels are required to have ballast water treatment systems approved by the US Coast Guard (USCG). During the first year of operation, ballast water must be tested two to four times for intestinal Enterococci, Escherichia coli (E. coli), and total heterotrophic bacteria (THB) levels.

If a vessel discharges effluent in US waters, it must obtain discharge authorization and electronically report sampling and analysis results for all waste streams—including ballast water, grey water, bilge water, and scrubber water—to the United States Environmental Protection Agency (EPA).

In summary, any vessel equipped with a Ballast Water Treatment System (BWTS) that calls at US ports is required to have a valid Vessel General Permit. Failure to maintain this permit can result in fines imposed by the USCG.

On December 19, 2013, the US Environmental Protection Agency (EPA) issued a revised Vessel General Permit (VGP), which mandates the use of Environmentally Acceptable Lubricants (EALs) in all oil-to-water interfaces—such as stern tube seals and thruster seals—on all merchant vessels 79 feet or longer operating in US coastal and inland waters.

Under the VGP, vessels operating in these waters must carry a valid permit, which is subject to inspection by the US Coast Guard (USCG).

In 2018, the Vessel Incidental Discharge Act (VIDA) was enacted to streamline federal, state, and local regulations governing vessel discharges within US waters. VIDA is set to replace the 2013 VGP and will fully take effect in 2024. While VIDA currently incorporates the VGP’s requirements, it introduces new obligations for ship operators and masters, including:

Self-assessment and reporting to the USCG
Installation, calibration, and regular maintenance checks of systems like ballast water treatment systems

This legislation aims to simplify compliance while maintaining environmental protection standards for vessels operating in US waters.

Vessels equipped with BWTS using chemical biocide will need to comply with Effluent Biological Organism Monitoring And Residual Biocide and Derivative Monitoring

Vessels with BWTS not using chemical-based treatment methods need only comply with Effluent Biological Organism Monitoring

Biological Indicator Compliance Monitoring:

Type of Monitoring	Devices for Which High Quality Type Approval Data Are Available	Devices for Which High Quality Data Are Not Available
Intial	2 times	4 times per year
Maintenance	1 or 2 times per year (*)	4 times per year

Vessels equipped with ballast water treatment systems must conduct biological indicator monitoring of their ballast water discharge, following these requirements:

For vessels using systems with high-quality type approval data:
- Monitoring must be performed twice during the first year of system installation or use.
- If two consecutive samples are within permit limits, the vessel owner/operator may reduce monitoring to once per year starting in the second year.
- If any sample exceeds permit limits, monitoring must return to twice per year and continue at that frequency until two consecutive samples again fall within permit limits.
For vessels without high-quality type approval data:
- Monitoring is required four times per year, without the option to reduce frequency.
For all vessels:
- One sampling event each year may be conducted during a vessel’s annual or other scheduled survey.
- In the first year, one sample may be collected during system installation to verify proper operation.
- Samples should be small in volume and collected from the ballast water discharge, in accordance with EPA’s Generic Protocol for the Verification of Ballast Water Treatment Technology (ETV Protocol).

Biocides and Residuals Monitoring

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

Many ballast water treatment systems use or generate biocides to reduce the number of living organisms in ballast water tanks.

For vessels using such systems, operators are required to monitor ballast water discharge for any residual biocides or their byproducts. This monitoring helps ensure compliance with permit conditions, confirms that harmful byproducts are not being produced in significant quantities, and provides the EPA with

Analytical Method Details for Residual
Biocides and Biocide Derivative

Biocide	Analyte	Analytical Methods	Minimum Sample Volume	Sample Holding Time	MDL	Effluent Limit or Action	Limit Type
Alkylamines	Alkylamines	EPA Method 8360B and 8270D	25 mL (8260B)	14 days (8260B)	Varies by compound (8260D); 10 μg/L (8270C)	Report	NA
Chlorine or Chlorine Dioxide*	Chlorine Dioxide*	EPA Method 327.0-1; SM 4500 ClO2 E	16 mL (327.0-1)	4 hours (327.0-1); As soon as possible(SM)	Varies (327.0-1); 10 to 100 mg/L (SM)	200 μg/L	Instantaneous Maximum
	Total Residual Oxidizers (TRO) as Cl2*	SM 4500-Cl G; ISO 7393/2	50 mL	15 minutes	10 μg/L, under ideal conditions	100 μg/L	Instantaneous Maximum
	Chlorite	EPA Method 300.1	CFU or 250 mL	14 days	Varies	Report	NA
	Chlorate	EPA Method 300.1	250 mL	28 days	Varies	Report	NA
	Total trihalomethanes**	EPA Method 8260	25 mL	14 days	Varies	Report	NA
	Haloacetic acids***	EPA Method 552.2	40 mL	14 days	Varies by compound	Report	NA
Menadione	Menadione	NA	—	—	—	Report	NA
Ozone	Total Residual Oxidizers (TRO) as Cl2	SM 4500-Cl G; ISO 7393/2	50 mL	15 minutes	10 μg/L, under ideal conditions	100 μg/L	Instantaneous Maximum
	Bromate	EPA Method 317 ; EPA Method 300.1; ASTM D 6581-00	250 mL	28 days (317; 300.1)	Varies (317; 300.1)	Report	NA
	Bromoform	EPA Method 8260	25 mL	14 days	Varies	Report	NA
	Total trihalomethanes**	EPA Method 8260	25 mL	14 days	Varies	Report	NA
	Haloacetic acids***	EPA Method 552.2	40 mL	14 days	Varies by compound	Report	NA
Peracetic acid	pH	SM 4500 H+	25 mL	As soon as possible	NA	6.5 – 9 s.u	Instantaneous Maximum
	Peracetic acid	Photometric analysis(Pinkernell, 1997; EMD Chemicals, 2011; CHEMetrics 2010)	25 mL	As soon as possible	500 μg/L	Report	NA
	Hydrogen peroxide	Titimetric analysis (JIS K 1463:2007; EMD Chemicals, 2011; CHEMetrics 2010))	25 mL	As soon as possible	500 μg/L	1000 μg/L	NA

✅ What We Offer

We provide end-to-end support for vessels operating under the U.S. VGP/VIDA requirements:

Onboard Attendance & Sampling

Sampling in accordance with ETV Protocol and BWMS Code
Field testing using EPA-approved methods (40 CFR 136.3)
Sample collection bottles and containers supplied per VGP standards

Sample Transportation

Transport within regulated timeframes
Adherence to required preservation, temperature, and light conditions

Lab Testing in Accredited Laboratories

Analysis using EPA-designated methods (40 CFR 136.3)
Monitoring for:
- Biological Indicators (E. coli, Enterococci, heterotrophic bacteria)
- Biocides & Residuals (for systems using electrolysis, chemicals, ozone, etc.)

Regulatory Reporting

Submission of sampling and analytical results to the EPA
Reports formatted to meet EPA electronic reporting standandard

🔍 Why Compliance Matters

S. Coast Guard (USCG) enforcement of EPA’s VGP is active and ongoing
Non-compliance may lead to fines, delays, or port entry denial
A valid Vessel General Permit (VGP) is required for ballast water discharges
Accurate and timely monitoring, testing, and reporting is essential

📞 Ready to Stay Compliant?

Whether your BWMS is chemical-based or mechanical, we provide tailored services to ensure you meet all discharge monitoring requirements under VGP and VIDA.

👉 [Contact us] today for a customized compliance plan or to schedule a sampling session.