Vessel General Permit – BWTS Sampling – PMS INTEGRATION
The purpose of this article is to provide vessel owners/operators with tips and tools for meeting the sample collection and analysis monitoring requirements in the 2013 VGP by integrating the timeline into their existing PMS and reduce administrative burden to already burdened crew.
For vessels with keels laid after December 1st, 2013 we are required to carry out some additional testing as indicated in the table below. This is apart from various tests and calibrations, related to overboard discharge which is already done.
VGP required tests
|
Test
|
Period
|
Remarks
|
1. Bilgewater monitoring *
|
Oil and grease content
|
Yearly
|
- The test must be done by a laboratory.
- OCM readings during sampling must be compared with laboratory results
- Maintain record as per VGP 2013 – Page 189
- If no discharge occurs then no sampling is necessary.
|
2. BWTS effluent biological organism monitoring
|
Measure:
- Total heterotrophic bacteria
- E. coli
- Enterococci
|
2 times per year (from two separate discharge events at least 14 days apart)
|
- For the first year, the first test can be considered the one commissioning test from SY
- Maintain record as required by VGP 2013 – Table on Page 185
|
3. BWTS residual biocide monitoring
|
TRO (chlorite) – less than 100 µg/l (0.1 ppm)
|
Initial:
3 times in the first 10 discharge events (within 180 days)
|
- The life of the sample is 15 minutes. The test must be done on board. Vessel needs to be provided with the necessary equipment
- Maintain record as required by VGP 2013 – Table on Page 185
|
Normal Maintenance:
2 times per year
|
|||
4. Greywater*
|
Measure:
- BOD – biochemical oxygen demand
- Faecal coliform or E. coli
- Suspended solids
- pH
- Total residual chlorine
|
2 times per year
(from two separate discharge events at least 14 days apart)
|
- Maintain record as per VGP 2013 – Page 188
- If no discharge in VGP waters occurred within the year, the monitoring tests are not necessary
|
*As it is not normal to discharge greywater and bilge water within 3 Nm of US Coast, the tests for this will not normally be required and so are not required to be included in your maintenance program.
Depending on your PMS type and set up it would be good to incorporate the ballast water treatment tests within it, following the above table.
Example:
Ballast Water Management System
PERIODICAL CHECKS OF SYSTEM’S APPLIANCES
JOB: EFFLUENT BIO.ORGANISM RES. BIOCIDE MON
INSTRUCTIONS:
a) RISK MANAGEMENT:
The risk assessment must be carried out as per operating procedures if deemed necessary for the specific job.
b) PERMITS: NORMAL WORK
c) MAN-HOURS: 2 person x 3 hours = 6 Man-hours
d) MANUAL:
EPA -VESSEL DISCHARGE SAMPLE COLLECTION & ANALYTICAL MONITORING - A How-To Reference for EPA'S 2013 VGP
e) SAFETY PRECAUTION:
SAFETY PROCEDURE TO BE FOLLOWED AS PER COMPANY AND INDUSTRY STANDARDS. PPE TO BE USED AS PER COMPANY MATRIX. SAMPLING WILL BE DONE BY ATTENDING CHEMIST. SAMPLING AND TESTING SHALL BE CONDUCTED ACCORDING TO 40 CFR PART 136.
f) TOOLS NEEDED:
TEST AND SAMPLING KITS WILL BE PROVIDED BY ATTENDING CHEMIST
g) PROCEDURE:
Request attendance by an approved chemist for carrying following sampling/testing on ballast water treatment system:
1. BWTS effluent biological organism monitoring
Measure: Total heterotrophic bacteria, E. coli, Enterococci.
Maintain record as required by VGP 2013 Table on Page 185
2. BWTS residual biocide monitoring
Measure: TRO (chlorite) - less than 100 μg/l (0.1 ppm)
Maintain record as required by VGP 2013 - Table on Page 185
Note:
Prior arranging for attendance identify required sampling points for BWTS present on board.
Preferred ports are: list the preferred ports
As an alternative to attendance on board, it may be possible to provide sampling equipment for samples to be landed ashore. “
For the initial testing for BWTS effluent biological organisms, the vessels testing should be initiated manually by a person in charge but always recorded within the system. When initial testing is done vessel hast to follow PMS schedule normally.
Initially, it is good for companies to choose one company worldwide to attend the vessel to take samples and carry out the required testing.
As an alternative to attendance on board, it may be possible to provide sampling equipment for samples to be landed ashore. However, due to strict sampling procedure and short lifespan of samples that will not be practical.
For a better understanding of entire sampling and testing process refer to
“VESSEL DISCHARGE SAMPLE COLLECTION & ANALYTICAL MONITORING A How-To Reference for EPA’s 2013 Vessel General Permit (VGP)”,
which can be easily found online.
Bibliography:
1. Stienstra O. & Van Der Vlies A. 2015. THE VESSEL GENERAL PERMIT IN A NUTSHELL - www.lagersmit.com [Online]. [3 October 2018]. Available from: https://www.lagersmit.com/the-vgp-in-a-nutshell/
2. US EPA. 2013 “March 2013 - Final 2013 Vessel General Permit” - www3.epa.gov - [Online]. Available from: < https://www3.epa.gov/npdes/pubs/vgp_overview2013. > [Accessed: 3 October 2018].
3. US EPA (2014). VESSEL DISCHARGE SAMPLE COLLECTION & ANALYTICAL MONITORING - A How-To Reference for EPA's 2013 Vessel General Permit (VGP). (Final Report ed.). Washington DC: United States Environmental Protection Agency.
Disclaimer:
“ Out of Box Maritime Thinker” © 2018 and
Aleksandar Pudar assumes no responsibility or
liability for any errors or omissions in the content of this paper. The
information contained in this paper is provided on an “as is” basis with no
guarantees of completeness, accuracy, usefulness or timeliness or of the results obtained from the use of this
information. The ideas and strategies should never be used without first
assessing your own company situation or system, or without consulting a
consultancy professional.
The content of this paper is intended to be used and must be used for informational purposes only.
