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Ballast water included in the revised US Vessel General Permit (VGP)

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In the last week of March 2013, the US Environmental Protection Agency (EPA) issued a final Vessel General Permit regulating discharges from commercial vessels, including ballast water, to protect the nation’s water from ship-borne pollutants and reduce invasive species in US waters. The VGP will enter into force on 19 December 2013 and replace the current VGP (2008 VGP).

The 2013 final VGP will continue to regulate 26 specific discharge categories  that were contained in the 2008 VGP. In addition, the 2013 VGP contains new numeric ballast water discharge limits for most vessels.

The VGP applies to most vessels trading in US waters and each vessel has to document that it fulfils the requirements stated in the Vessel General Permit.

The VGP requirements issued by EPA generally align with the US Coast Guard ballast water requirements. However, the VGP contains some additional requirements to ensure ballast water treatment systems (BWTS) are functioning correctly. The following are considered most essential and apply once a BWTS is required to be installed on board.

Calibration of sensors

All applicable sensors and other control equipment must be calibrated annually (or more frequently if warranted or recommended by the maker). EPA expects that many sensor types (e.g. pH probes, TRO sensors, turbidity sensors) will need to be calibrated more frequently. This can be done aboard or ashore but the vessel must not discharge ballast water when the sensors are inoperable.

Sampling of biological indicators

The VGP requires biological indicator compliance monitoring of the effluent from the BWTS. Samples of the ballast water discharge must be taken and analysed to find the concentration of certain biological indicators (Heterotrophic bacteria, E.coli and Enterococci). These samples to monitor biological indicator compliance must be taken twice during the first year that the BWTS is installed and then 1-2 times per year depending on the results.

Sampling of residual biocides

DNV logo_GOULOGOFor BWTS using active substances, the master of the vessel must examine the ballast water discharge for any residual biocides or derivatives used in the treatment process. The VGP includes effluent limits for chlorine dioxide, chlorine, ozone, peracetic acid and hydrogen peroxide but only the substances relevant for a particular BWTS shall be monitored. The vessel must take samples three times during the first 10 discharge events, as initial monitoring, and twice per year as maintenance monitoring. It is our best understanding that this required sampling is the same as the control and monitoring system built into the BWTS.

Records of the sampling and testing results (e.g. sensors, biological indicators and residual biocides) must be retained on board for a period of three years. The vessel must also submit the test results to EPA as part of the vessel’s annual report. Details on the 2013 VGP can be found at the EPA website.

As stated above, the EPA VGP and USCG implementation schedules for BWTS are identical. For the sake of completeness the dates are repeated below:

Implementation schedule for the USCG ballast water treatment standard

Vessel’s ballast water capacity Date constructed Vessel’s compliance date
New vessels All On or after 1 December 2013 On delivery
Existing vessels Less than 1500 m3 Before 1 December 2013 First scheduled drydocking after 1 January 2016
1500 – 5000 m3 Before 1 December 2013 First scheduled drydocking after 1 January 2014
Greater than 5000 m3 Before 1 December 2013 First scheduled drydocking after 1 January 2016

See also our Technical eNewsletter April 2012 ‘New US ballast water management requirements’.

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