VGP Compliance Annual Program

We are experts in effectively managing all EPA’s VGP requirements

The Vessel General Permit (VGP) is a permit issued by the US Environmental Protection Agency (EPA) that regulates discharge water incidental to the normal operational conditions of commercial vessels greater than 79 feet in length, which are entering and/or operating in all US territorial waters.

The VGP includes general effluent limits applicable to all covered discharges as well as general effluent limits applicable to 27 specific discharge streams in addition to narrative water-quality based effluent limits, inspection, monitoring, recordkeeping, reporting requirements and additional requirements applicable to certain vessel types.

In this light Maritec provides a one-of-kind all-encompassing Annual Program to assist vessels voyaging into US territory waters stay on top of their entire VGP requirements for discharge waters in the areas of Ballast Water Treatment, Scrubber Water treatment, Bilge Water treatment, and Gray Water Treatment.


Maritec’s unique one-stop solution helps you meet your Discharge Water Compliance requirements as per VGP 2013.

Scope of Services:

  • Expert onboard sampling and laboratory testing of Ballast Water, Scrubber Water, Bilge Water and Gray Water at required frequencies stipulated by the VGP regulation
  • Accredited Testing Reports for submission to EPA
  • Voyage tracking for optimal planning of testing at the most economical ports
  • Annual Auditing of monitoring program 
  • Training and advisory services on request
  • Notice of Intent (NOI) review
  • Review of the monthly monitoring records submitted by crew
  • Review the 27 effluents before annual report preparation
  • Preparation & submission of Annual Report with Discharge Monitoring Report (DMR) on the official EPA website

Benefit from:

  • Risk Mitigation: We help clients identify Testing Frequency for each vessel according to VGP requirements.
  • Budget Control and Reduced Superintendent Workload: We help monitor the voyage to find the most economical ports for sampling/testing.
  • Global Reach: We offer testing worldwide for convenient sampling and reporting.
  • Technical Support & Training: We offer Audit & Crew Training and due-diligence support for vessel operational records review.
  • Error Proof Processes: Ensures all layers of requirements are systematically met/submitted to EPA.
  • Quick-response Times: Supports our customer queries on a real-time basis.


Discharge Water Type Parameters Monitoring High Quality Data - HQD
Ballast water – All types of BWMS Biological Testing 1st Year 2 times (consecutive)
2nd Year 1 time (continuous)
Revert to 1st year IF Fail
Ballast Water – Electrolysis
Chemical Injection
Biocides Testing 1st 10 discharges
1st 180 days
3 times
2nd Year 2 times
Scrubber Water 3 Samples per vessel 
(2 times in the first year & 1 time per year thereafter)
Bilge Water 1 sample per year
Gray Water 1 sample per time
(2 times per year)


Ballast Water Testing Parameters as below:

Test Items Method
Biological Testing Total heterotrophic bacteria ISO 6222:1999, APHA 9215 B equiv. to SM 9215 B, ASTM D5465
E.coli ISO 9308-1:2014, EPA 1603, EPA 1103.1, APHA 9223B equiv. To SM 9223B, ASTM D5392 –93, Colilert®
Enterococci ISO 7899-2:2000, EPA 1600, EPA 1106.1, APHA 9230C equiv. To SM 9230C, ASTM D5259 –92(2006), Enterolert®
Residual Biocides Testing TRO (as Cl2) Onboard Field test for Electrolytic type
Or Chemical type (Chlorine based), Ozone type
Chlorine Dioxide Onboard Field test for Chemical type (Chlorine dioxide based)
Halosteric Acid EPA Method 552.2 or EPA 552.3
Total Trihalomethanes EPA Method 8260 
Chlorite EPA Method 300.1 (For Electrolytic and Chemical type)
Chlorate EPA Method 300.1 (For Electrolytic and Chemical type)
Bromate EPA Method 300.1 (For Ozone type only)
Bromoform EPA Method 8260 (For Ozone type only)

Scrubber Water Testing Parameters as below:

Testing Regime Monitoring Parameters Test Methods Sampling Position
VGP pH (Field test by crew) EPA Method 1. Inlet Water (for background)
2. Water after the scrubber (but before any treatment system)
3. Discharge water.
16 PAHs (Polycyclic Aromatic Hydrocarbons)
Dissolved Metals
Volume required: 3+1 Litres, the samples taken by crew during ME 85% MCR and stored in refrigerator after sampling.

Bilge Water Testing Parameters as below:

Test Item Sampling position
Oil and grease content >n-Hexane Extractable Material (HEM; Oil and Grease) Discharge from the vessel after bilgewater treatment system
O&G volume required: 1 litre

Gray Water Testing Parameters as below:

Test Item Sampling position
Biochemical Oxygen Demand (Biochemical tests) All Discharge points (e.g., sinks, laundry facilities, showers, galley kitchens, etc). Can consider collecting a sample of each of the discharge points and compositing them together for a representative sample of the vessel’s entire gray water.
Water discharge, or sampling from an existing combined gray water collection tank.
Faecal Coliform Count, MFC Agar,44.5°C,24h (E-Cultural technique (membrane plate))
Escherichia coli Count, EC-MUG,44.5°C,24h (E-Cultural technique (membrane plate))
Total Suspended Solids (Gravimetry)
pH at 25°C (Electrometry)
Total Residual Chlorine (Spectrophotometry (UV/VIS))

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