Guidance on

Monitoring and
Sampling Requirements
for Compliance with
the 2013 VGP
Acknowledgements
INTERTANKO would like to express its thanks and appreciation to Ms. Maria Sotiriou of Minerva
Marine Inc for her invaluable assistance and support in drafting this Guidance document.

ii Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
 Guidance on Monitoring and
Sampling Requirements for
Compliance with the 2013 VGP

All rights reserved. No part of this publication may be reproduced in any material form (including photocopying
or storing it in any medium by electronic means and whether or not transiently or incidentally to some other
use of this publication) without the written permission of INTERTANKO. Applications for INTERTANKO’s written
permission to reproduce any part of this publication should be addressed to the publisher.

© INTERTANKO 2017

While every effort has been made to ensure that the information contained in this publication is correct,
neither the authors nor INTERTANKO can accept any responsibility for any errors or omissions or any
consequences resulting therefrom.

No reliance should be placed on the information or advice contained in this publication

without independent verification.
Acknowledgements

Contents
1. Introduction and purpose 5

2. VGP 2013 Monitoring and Sampling Requirements 7

3. When to sample and monitor 9
3.1. Ballast water 10
3.1.1. Biological indicators 10
3.1.2. Residual biocides indicators 11
3.2. Bilge water 12
3.3. Greywaters 13
3.4. Exhaust Gas Scrubbers 14

4. What to sample and monitor 15

4.1. Ballast water 16
4.1.1. Biological indicators 16
4.1.2. Residual biocides indicators  17
4.2. Bilge water 17
4.3. Greywaters 17
4.4. Exhaust Gas Scrubbers 18

5. Key Points on how to Collect Samples 19

5.1. Finding a sampling collector and/or an analytical laboratory 20
5.2. Sample Preparation 20
5.3. Collecting samples and shipping to the laboratory 21
5.4. Completion of the Chain of C.ustody Form 22

6. Quick Tips for the Selection of the Laboratory 25

7. References 25

iv Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
1. Introduction and
purpose
1. Introduction and purpose

1. Introduction and purpose

While monitoring and sampling requirements for compliance with the 2013 VGP are only applicable
to vessels with a keel laid after December 2013, INTERTANKO’s Environmental Committee encourages
the monitoring and sampling of ballast and bilge. Various reasons were provided by the Committee
as to why sampling and testing was considered useful:

1. In order to undertake testing for ballast water, the BWMS will need to be operated. From
a crewing perspective it is time consuming operating a BWMS and it is therefore useful to
understand how the crew may adapt to operating the BWMS;

2. The actual sampling and testing on board, certainly for VGP compliance purposes, is also difficult
and time consuming. Ensuring those on board are familiar with the procedures before it is
compulsory is worthwhile to reduce the chances of enforcement issues;

3. Due to the operating limitations of some ballast water BWMSs, crew members should know
in which conditions sampling and testing should and should not be undertaken. For example,
brackish water will effect electrolysis system operation while highly turbid waters will affect UV
and electrolysis systems. In this respect the crew will need to plan how and when to undertake
the sampling and testing in order to demonstrate the BWMS’s effectiveness.

4. Using the BWMS in conditions experienced in normal operation will expose any technical or
operational problems as well as any maintenance deficiencies or bad practices that may not have
arisen under the more controlled environment of the sea trial, and;

5. In some cases, laboratories need to send equipment to aid the sampling and testing. It is
worthwhile the company and crew understanding how this works in practice before the
requirements become mandatory.

Vessels owners/operators may conduct part or all of the sampling themselves or contract these
sampling activities to experienced third party or sampling and/or analytical providers.

Due to the complexity of the monitoring and sampling requirements INTERTANKO has produced this
summary with the aim of briefly explaining the minimum requirements for monitoring and sampling
for compliance with the EPA’s 2013 VGP. This should assist those ashore in particular when considering
whether it is useful to contract a third party company to undertake the sampling and provide that
third party company with a clear brief for the sampling and testing that is required as a minimum for
VGP compliance. With various services frequently offered by third party contractors, it is advisable
to understand what is essential and what is not in compliance terms. The full details of the EPA’s
requirements are available in the EPA’s ‘Sampling How-to for the 2013 Vessel General Permit (VGP)’:

https://www.epa.gov/sites/production/files/2015-08/documents/vgp_self_sampling_reference.pdf

This document is referenced throughout this Guide, in particular in relation to the detailed monitoring
parameters for each discharge.

If an owner does not wish to contract the work of sampling on board to a specialist laboratory then
the procedures provided to the crew need to be extremely detailed and precise. The EPA’s guide
provides useful information and illustrations to assist the crew in conducting their own sampling.

6 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
 2. VGP 2013
Monitoring
and Sampling
Requirements
2. VGP 2013 Monitoring and Sampling Requirements

2. VGP 2013 Monitoring and Sampling

Requirements
If a vessel discharges ballast water through a BWMS within waters covered by the VGP the ballast water
discharges must be monitored. If the vessel has been granted an extension by the USCG and does not
use the BWMS for compliance purposes, then it will not have to undertake the monitoring and sampling.
However, monitoring and sampling must be undertaken even if a vessel has been granted an extension by the
USCG but decides to use the BWMS for the likes of training purposes and testing in readiness for regulation
implementation.

New vessels delivered after 19 December 2013, greater than 400 gross tons, that may discharge bilge water
into water subject to VGP must monitor their bilge water effluent at least once per year for oil and grease.

New build vessels delivered on or after 19 December 2013 that have a maximum crew capacity greater or
equal to 15 and provide overnight accommodation must monitor their greywaters by sending two samples
a year, at least 14 days apart.

Vessels with exhaust gas scrubber systems must collect and analyse two samples in the first year of permit
coverage or system operation, whichever is first, to demonstrate treatment equipment maintenance, probe
accuracy, and compliance with VGP permit.

Vessels that do not discharge ballast water, bilge water, greywaters or exhaust gas scrubber
effluent into the waters covered by VGP permit do not have to comply with VGP 2013
monitoring requirements. The fact that no discharge occurred during the year of permit
coverage should be clearly stated in the vessel’s Annual Report.

8 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
3. When to sample
and monitor
3. When to sample and monitor

3. When to sample and monitor

3.1 Ballast water

3.1.1 Biological indicators

• Two times during the first year the system is installed or used for vessels with devices for which
high quality data are available.

• One time per year after the first year (if sampling results are below permit limits for two
consecutive events)

• 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.

• Four times per year, for vessels for which high-quality data is not available.

Devices with high-quality data are any BWMS type approved by the USCG or type approved by a
foreign administration, or BWMS that has been tested according to ETV protocol and has made the
data available to US EPA.

For example, if the BWMS has been type approved according to the IMO requirements then this
data would be considered high-quality data. An owner with a USCG Alternate Management System
(AMS) installed would therefore qualify as being able to supply high-quality data.

10 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
 3. When to sample and monitor

3.1.2 Residual biocides

Sampling frequency for residual biocides indicators are indicated in Table 1.

Type of Monitoring Devices for Which High
Quality Type Approval Data
Are Available
Initial Monitoring 3 times in the first 10 discharge
events (not to exceed a 180
day period)
Maintenance Monitoring 2 times per year
Devices for Which High
Quality Data Are Not
Available
5 times in the first 10 discharge
events (not to exceed a 180
day period)
4 times per year

Table 1. Sampling frequency for residual biocides indicators

Records of sampling and testing results must be retained onboard for a period of three years in
the vessel’s recordkeeping documentation. Vessels must also submit the testing results to EPA as part
of the vessel’s annual report. Records of monitoring information shall include:

• The BWMS used, any type approval certificate, and records of whether the system meets the
high-quality data criteria;

• The individual(s) who performed the sampling, measurements, and/or inspections;

• The date(s) analyses and/or inspections that were performed;

• Any sensor or other control equipment calibration and functional tests conducted during the
inspection as applicable;

• The techniques or methods used for any sensor or other control equipment calibration and
functional tests as applicable;

• The date and time of all monitoring results;

• The analytical techniques or methods used as applicable, and;

• The results of such analyses.

Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP 11
3. When to sample and monitor

3.2 Bilge water

New build vessels must monitor their bilge water at least once a year. If the analytical results are less than 5
ppm for two consecutive years, you need not sample and analyse subsequent years of permit coverage if:

• Your vessel uses an oily water separator capable of meeting a 5 ppm oil and grease limit, or you use an
alarm which prevents the discharge of oil and grease above 5 ppm whenever you discharge in waters
subject to this permit,

• You calibrate your OCM at least annually (calibrations during a vessel survey meet this requirement),
and

• Your OCM never reads above 5 ppm during discharges into waters subject to this permit. If this
information is recorded in the oil record book, you need not record these data in other recordkeeping
documentation.

The 2013 VGP requires bilge water analysis of oil and grease sampled after the bilge water treatment system.
The 2013 VGP requires that a reading of the OCM be recorded at the time of sample collection so that the
oil content measured by the laboratory can be compared to that measured by the OCM.

Records of monitoring must be retained onboard for at least 3 years in the vessel’s recordkeeping
documentation and must include:

• The date, exact place, and time of sampling or measurements;

• The individual(s) who performed the sampling or measurements;

• The individual(s) who performed the analyses and any meter recalibration;

• The techniques or methods used for sample analyses, and;

• The results of such analyses and OCM readings.

For those vessels for which monitoring must be conducted, analytical and corresponding OCM monitoring
data must be submitted at least once per calendar year no later than 28 February of the year after the data
are collected. Additionally, if you have met the requirements for waiving the analytical monitoring after two
years, you must note your waiver qualifications on your annual report.

12 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
 3. When to sample and monitor

3.3 Greywater

Vessels with multiple greywater discharge points (e.g., sinks, laundry facilities, showers, galley kitchens, etc),
should collect a sample of each of the discharge points and compose them together for a representative
sample of the vessel’s entire greywater discharge, or sample from an existing combined greywater collection
tank.

Vessels that send greywater samples to the laboratory for analyses should note whether the greywater effluent
is treated or untreated, and also note whether the effluent is greywater alone or if it is mixed with another
effluent type (e.g., greywater mixed with sewage).

Records of monitoring must be retained onboard for at least three years in the vessel’s record keeping
documentation and must include:

• The date, exact place, time, and sampling port location(s) of sampling or measurements;

• The individual(s) who performed the sampling or measurements;

• The date(s) analyses were performed;

• The individual(s) who performed the analyses;

• The analytical techniques or methods used;

• The results of such analyses; and,

• Proportions of waste streams being treated and sampled (such as mixed greywater, mixed greywater
and blackwater, and galley. If actual amounts are not available, the estimated proportions should be
provided).

Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP 13
3. When to sample and monitor

3.4 Scrubbers

Vessel owners/operators must collect and analyse two samples in the first year of permit coverage or system
operation, whichever is first, to demonstrate treatment equipment maintenance, probe accuracy and
compliance with the permit. Samples must not be collected within 14 days of each other. 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.

After the first year, samples must be collected at least once per calendar year for inlet water (for background),
water after the scrubber (but before any treatment system), and discharge water, and may be collected as part
of the vessel’s annual survey as appropriate.

Monitoring data must be submitted at least once per calendar year no later than 28 February of the following
year on the vessel annual report. Data must be submitted to EPA attached to the Annual Report. Records of the
sampling and testing results must be retained onboard for a period of three years in the vessel’s recordkeeping
documentation.

14 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
4. What to sample
and monitor
4. What to sample and monitor

4. What to sample and monitor

4.1 Ballast water

The vessel’s ballast water system must be provided with sampling ports arranged in order
to collect representative samples of the vessel’s ballast water. In addition to the sampling
ports designed and installed in accordance with the specifications in the ETV Protocol
(see http://nepis.epa.gov/Adobe/PDF/P10097A4.pdf).

Sampling ports must be located:

• As close as practicable to the BWMS prior to treatment to determine concentrations of living organisms
upon uptake; and

• As close as practicable to the ballast water management system overboard outlet prior to the discharge
point to determine concentrations of living organisms prior to discharge.

• The 2013 VGP specifies that vessels using a ballast water treatment system must sample and analyse
ballast water discharges for biological indicators and residual biocides indicators:

4.1.1 Biological indicators

Biological indicators are:

• Total heterotrophic bacteria

• E. coli

• Enterococci.

The monitoring parameters for the above biological indicators are included in detail in the EPA’s ‘Sampling
How-to for the 2013 Vessel General Permit’.

Biological sampling is undertaken to assess the effectiveness of the BWMS in destroying living organisms. In
order to properly assess whether the BWMS is destroying the organisms, any living organisms in the sample
will need to be carefully managed so as not to destroy these organisms during the sampling and monitoring
process.

16 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
 4. What to sample and monitor

4.1.2 Residual biocides indicators

Residual biocide indicators depend on the ballast water treatment method with their respective indicators
detailed in the EPA’s Sampling How-to for the 2013 Vessel General Permit and VGP 2013 paragraph
2.2.3.5.1.1.5.2. The most common biocides are listed below:

• Alkylamines

• Chlorine or Chlorine Dioxide

• Menadione

• Ozone

• Peracetic Acid

4.2 Bilge water

Bilge water should be sampled for n-Hexan Extractable Material (HEM) and its Hydrocarbon Oil Index (HOI).
Bilge water must be analysed for oil and grease and the results should indicate that are less than 5ppm. Details
of the method are provided in the EPA’s Sampling How-to for the 2013 Vessel General Permit.

4.3 Graywater

Graywater must be analysed for the following parameters:

• Biochemical Oxygen Demand (BOD)

• Fecal Coliform or E. coli

• Total suspended solids (TSS)

• pH

• Total Residual Chlorine (TRC).

The EPA’s ‘Sampling How-to for the 2013 Vessel General Permit’ provides details the greywaters analytical
methods.

pH and Total Residual Chlorine must be measured within 15 minutes of sample collection and therefore need
to be measured and recorded at the time of sample collection.

Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP 17
4. What to sample and monitor

For vessels with multiple greywater discharge points (eg. sinks, laundry facilities, showers, galley, kitchens etc)
consider collecting a sample of each of the discharge points and compositing them together for a representative
sample of the vessel’s entire greywater discharge or sampling from the existing combined greywater collection tank.

The sampling point must be reported to EPA when submitting the monitoring data. All records of the greywater
sampling must identify the proportions of waste streams being sampled (such as mixed graywater, mixed
greywater and galley, etc).

4.4 Scrubbers

For each sampling event, samples must be collected of each of the following:

• Exhaust gas scrubber inlet water (for background),

• Untreated water leaving the scrubber (but before any treatment system), and

• The discharged water (after any treatment).

VGP 2013 requires that Exhaust Gas Scrubbers samples should be analysed for:

• Dissolved and total metals

• PAHs (polycyclic aromatic hydrocarbons)

• Nitrate-Nitrite

• pH.

The specific compounds that need to be analysed for each analytical group in Exhaust Gas Scrubbers as well as
the sample collection and procedures for analysing the exhaust has scrubbers washwater samples are included
in the EPA’s Sampling How-to for the 2013 Vessel General Permit.

The How-to document notes that pH and total residual chlorine need to be measured within 15 minutes of
sample collection and therefore need to be measured and recorded at the time of sample collection rather
than at a commercial laboratory. Also, while total residual chlorine is not identified in the permit as a required
analyte, it is needed to determine if preservation is needed for PAHs samples.

This monitoring is performed using test meters equipped with the appropriate sensors designed to meet
the analytical method listed. Generally, a 1-litre sample container is filled during sample collection for use
in performing these field measurements. If total residual chlorine is detected, sodium thiosulfate (Na2S2O3)
will need to be added as a preservative for any PAHs sample. (ASTM D7365-09a specifies treatment options
for samples containing chlorine.) Vessel owners/operators should ensure that all equipment used for field
measurements are calibrated following applicable calibration procedures specified by the instrument
manufacturer.

The addition of sodium thiosulfate is applied to ballast water samples (that contain chlorine) and greywaters
analyses as well. In practice though, it is recommended by all laboratories that TRO and chlorine dioxide
are analysed onsite so as to avoid the need to add sodium thiosulfate and increase the accuracy of the
measurement.

18 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
5. Key points on
how to collect
samples
5. Key points on how to collect samples

5. Key points on how to collect samples

5.1 Finding a sampling collector and/or an analytical laboratory

The EPA does not require the use of a “certified” or “accredited” laboratory for sampling and analytical analysis
to comply with the VGP’s monitoring conditions and will accept any laboratory that performs environmental
analyses with the methods proposed in VGP 2013.

However, the Independent Laboratories (IL) that are used for BWMS type approval testing can perform ballast
water sampling and analyses for VGP 2013. The full list of the Independent Laboratories as approved by
the USCG can be found on the Coast Guard Maritime Information Exchange (CGMIX), http://cgmix.uscg.
mil Select “USCG Independent Labs”, select “EQLabs Search”; Select “Ballast Water Management System
162.060” from the “Approval Series Name” drop-down menu.

Laboratories indicated in the USCG website (ballast water, bilge water):

http://nelac-institute.org/lams/search

Since some samples have short holding times, the timing of sample collection to allow sufficient time for
transport to the laboratory for analysis needs to be considered. As such the location of the nearest laboratory
of the company being considered should be considered.

5.2 Sample Preparation

In cases when crew members perform the sampling, below is an indicative list of sampling equipment they
should have onboard (each laboratory may provide its own list):

• Sampling Pole (to access sample ports in hard to reach locations)

• Sample Bottles (plastic, glass, etc.) (to collect samples)

• Field Test Equipment (for pH, chlorine)

• Buckets and Disposable Bucket Liners (if taking a large volume of sample)

• Bottle Labels

• Pens

• Disposable Gloves

• Preservation Chemicals

• Zip Ties

20 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
 5. Key points on how to collect samples

• Log Book

• Bubble Wrap/Bubble Bags (to protect the samples during shipping)

• Shipping Paperwork/Traffic Reports

• Garbage Bags (to wrap the samples in shipping)

• Clear and Strapping Tape

• 0.45 µm Filters and Other Filtering Equipment (if needed for dissolved metals)

• Ice/Refrigeration/Coolers (some samples need to be chilled until reaching the lab)

• Zipper Storage Bags

• Chain of Custody Forms

• Peristaltic Pump/Tubing (if needed)

• Custody Seals.

Vessels that perform analyses of total residual chlorine and chlorine dioxide should have onboard field test
equipment such as photometer and the respective reagents. Ensure proper use and maintenance of the
photometer according to the instructions of its maker.

5.3 Collecting samples and shipping to the lab

General steps for sample collection:

1. Assemble all the necessary sampling equipment and materials

2. Ensure that bottles are appropriately labeled (see sample below)

3. Ensure that the vessel discharge system is fully operational and has adequate flow

4. Wear the disposable gloves and use only clean equipment to avoid cross contamination

5. Collect a discharge sample to perform the necessary field measurements

6. Determine whether NA2S2O3, HCL or H2SO4 are required for preservation

7. Fill the bottle samples

8. Cool the samples on ice and keep them in coolers

9. Fill in the Chain of Custody Form.

Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP 21
5. Key points on how to collect samples

Example of bottle label:

Vessel Name/Number: Tanker Vessel 1234

Sampling Point Description: Ballast Water Treat System Sample Port

Day and Time of Sample Collection: 10/10/2016 4:30 PM EST

Analysis to be Performed: E. Coli

Sample Bottle Type: 100ml Plastic Bottle

Preservation used: Ice box

Sample Initials: EC

5.4 Completion of the Chain of Custody form

All of the information on the sample label should be identical to the information on the Chain of Custody
(COC) form. To facilitate sample collection activities and ensure proper labelling, sample containers should
be pre-labelled as much as is practical prior to sample collection. The COC form should include any available
information regarding the potential hazards associated with the sample, handling procedures required for the
samples, sample identification number, sample concentration, if known, sampling location, sample date and
time, sample matrix, names and signatures of the samplers, and signatures of all individuals who had custody
of the samples.

A COC form should remain with the samples from collection to laboratory receipt. If samples are split into
two or more shipping containers, copies of the COC form should be placed with each container and directly
indicate the contents. Although COC forms used by different laboratories may vary in style, format, and detail,
the forms should contain the same minimal information required to identify the sample.

Consult with the laboratory service to see if they have existing COC templates and whether they can prefill
some of the known information.

22 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
 5. Key points on how to collect samples

Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP 23
24 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
 6. Quick Tips for
the selection of the
laboratory
—
7. References
6. Quick Tips for the selection of the laboratory & 7. References

6. Quick Tips for the selection of the laboratory

If the selection of an Independent Laboratory is not possible, owners /operators should select laboratories that
are able to fulfill the following requirements:

• The laboratory and the port should be in close proximity (biological samples must be in the lab within
8hrs, including the sampling time)

• The laboratory should use the analytical methods specified by EPA for each parameter and for each
effluent, as described in detail in the EPA’s Sampling How-to for the 2013 Vessel General Permit.

• The laboratory must be able to do the sampling onboard the vessels (at least for the first monitoring
efforts).

• The laboratory should be able to perform the field tests of the parameters that need instantaneous
monitoring, in case the vessel doesn’t possess the required equipment.

• The laboratory should provide the test report in a form that includes the data required by EPA for each
effluent as described in paragraph 3.

7. References
• VGP 2013 Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels
(https://www3.epa.gov/npdes/pubs/vgp_permit2013.pdf)

• Vessel Discharge Sample Collection & Analytical Monitoring-A-How To Reference for EPA’s 2013 Vessel
General Permit (VGP), EPA 800-B-14-001
(https://www.epa.gov/sites/production/files/2015-08/documents/vgp_self_sampling_reference.pdf)

• Ballast Water Self-Monitoring EPA, 800‐R‐11‐003 November 2011

(https://www3.epa.gov/npdes/pubs/vgp_ballast_water.pdf)

• INTERTANKO Guide to the US EPA VGP requirements for 2013 (VGP 2013)
(http://www.INTERTANKO.com/Global/Environment/IO_Guide_for_implementing_EPA_2013_VGP.pdf)

26 Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP
Guidance on Monitoring and Sampling Requirements for Compliance with the 2013 VGP 27
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