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On December 19, 2013, the revised Vessel General Permit (VGP) was issued by the U.S. Environmental Protection Agency (EPA). This VGP provides coverage under the National Pollutant Discharge Elimination System (NPDES) for incidental discharges into U.S. waters during the normal operation of vessels over 79 feet in length. The permit mandates the use of Environmentally Acceptable Lubricants (EALs) in oil-to-water interfaces such as stern tube seals and thruster seals.

VGP Overview
The VGP sets out specific discharge monitoring requirements for vessels operating in U.S. coastal and inland waters, which are enforced by the U.S. Coast Guard (USCG). General information on the VGP requirements, including the final 2013 VGP, can be accessed via the EPA website.

Which Discharges Must Be Monitored?

• Bilgewater Discharge: Vessels constructed on or after December 19, 2013, and greater than 400 gross tons, must monitor bilgewater discharges into U.S. waters (see Part 2.2.2.1 of the VGP).
• Graywater Discharge: Vessels with a crew capacity of 15 or more, providing overnight accommodation, must monitor graywater discharges if constructed on or after December 19, 2013 (see Part 2.2.15.2 of the VGP). This requirement also applies to non-commercial vessels discharging graywater in the Great Lakes.
• Ballast Water Discharge: Vessels using a ballast water treatment system to meet numeric discharge limitations (Part 2.2.3.5 of the 2013 VGP) must monitor ballast water discharges into U.S. waters (see Part 2.2.3.5.1.1 of the VGP).
• Exhaust Gas Scrubber Discharge: Vessels discharging exhaust gas scrubber wash water into U.S. waters must monitor these discharges (see Part 2.2.26.2 of the VGP).

VGP Testing and Monitoring
The VGP requires vessels to test ballast water discharge twice annually unless two consecutive tests meet permit limits, reducing the frequency to once per year. The EPA oversees the compliance program, while Port State inspectors enforce the regulations. Failure to comply with VGP requirements can result in fines and potentially lead to vessels being denied entry to U.S. ports.

From VGP to VIDA
In December 2018, the Vessel Incidental Discharge Act (VIDA) was signed, creating a unified regulatory framework for incidental discharges from U.S. and foreign-flagged vessels. Although the enforcement of VIDA’s federal discharge limits is expected to begin in autumn 2024, companies must still adhere to the existing VGP requirements to avoid penalties.

ERGONAV GROUP Services
ERGONAV GROUP is your reliable partner for compliance testing, calibration, and servicing across more than 375 ports worldwide, with a daily presence in all ports across the USA, Canada, Central, and South America. We hold certificates from the American Bureau of Shipping and Bureau Veritas for D2 BWTS Commissioning Testing. Our services include:

• Onboard Attendance for Sampling: Conducting sampling in accordance with the Environmental Technology Verification (ETV) Protocol, BWMS code, and Field Testing as per 40 CFR 136.3 methods.
• Sampling Equipment: Providing bottles and containers as required by VGP methods.
• Sample Transportation: Ensuring timely delivery of samples under the required conditions (e.g., preservatives, light, and temperature control).
• Laboratory Testing: Using EPA-designated methods (40 CFR 136.3) in accredited laboratories.
• Regulatory Reporting: Compiling reports in accordance with EPA requirements.
• Guidance and Support: Offering a comprehensive 30-page guide on regulations, along with technical support and customer care.

Consequences of Non-Compliance
Vessels that fail to comply with the VGP ballast water requirements may be subjected to fines, denied port entry, or risk losing cargoes. It is vital that companies review their compliance programs to ensure all protocols are practical for crewmembers to follow and include clear procedures for reporting non-compliance.

For professional compliance testing, calibration, and servicing in all ports across the U.S., Canada, Central, and South America, contact ERGONAV GROUP today.