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

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.

Monitoring Schedule for Biological Indicators

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

(*)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.

Biological indicator compliance monitoring sampling of ballast water effluent must be conducted 2 times during the first year the system is installed or used for vessels with Devices for Which High Quality Type Approval Data Are Available are available.
For vessels with high quality data, 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.
However, if the vessel owner/operator exceeds a permit limit on any sampling event, they must return to monitoring two times per year until they have two additional results below permit limits.
For vessels for which high quality data are not available, monitoring must be conducted 4 times per year.
For all vessels, one of those samples may be conducted as part a vessel’s annual or other survey, and during the first year, one of those sampling events may be conducted as part of the installation of the system to ensure it is functioning properly.
These samples can be taken by collecting a small volume sample from the ballast water discharge (consistent with the sampling guidance found in EPA’s Generic Protocol for the Verification of Ballast Water Treatment Technology – ETV Protocol).

Biocides and Residuals Monitoring

Many ballast water treatment systems produce or use biocides as an agent to reduce living organisms present in the ballast water tank.
For those vessels, Operator must conduct monitoring of the vessel ballast water discharge for any residual biocides or derivatives used in the treatment process, in part to demonstrate compliance with the permits conditions.
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

Each system, depending on the disinfection method it uses has different monitoring requirements, the table below shows those requirements per Biocide category.

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

* Chorine Dioxide Systems do need to monitor TRO, Chlorine Systems do need to monitor Chlorine Dioxide Content
**Total trihalomethanes is the sum of the concentrations of chloroform, bromodichloromethane, dibromochloromethane, and bromoform.
***Haloacetic acids is the sum of the concentrations of mono-, di-, and trichloroacetic acids and mono- and dibromoacetic acids.

We offer

• 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