For VGP purposes, “Graywater” is defined as the wastewater of galley, bath, and shower water, as well as wastewater from lavatory sinks, laundry, and water fountains (USEPA, 2008a).
The following monitoring requirements are applicable to vessels which discharge graywater into waters subject to this permit and meet one of the following conditions:
• The vessel is a new build vessel constructed on or after December 19, 2013, has a maximum crew capacity greater or equal to 15, and provides overnight accommodations to those crew; or
• The vessel is subject to Part 2.2.15.1 of VGP permit (contact us for further information on this)
Vessel owners/operators of those vessels, that actually discharge Graywater into the VGP regulated water must collect and analyze 2 samples per year. They should be collected at least 14 days apart, and report the results of those samples as part of their Annual Report. Samples must be taken for Biochemical Oxygen Demand (BOD), fecal coliform or E.Coli, suspended solids, pH, and total residual chlorine. Fecal Coliform or e. coli must only be analyzed once per year if vessels have difficulty analyzing the results within the required holding times. Sampling and testing shall be conducted according to 40 CFR Part 136. If the vessel is subject to Part 2.2.15.1, measured samples must meet the standards specified in that part.
Records of monitoring information shall 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 wastestreams being treated and sampled (such as mixed graywater, mixed graywater and blackwater, and galley. If actual amounts are not available, the estimated proportions should be provided).
Vessels subject to this part must note whether the graywater effluent is treated or untreated, and also note whether the effluent is graywater alone or if it is mixed with another effluent type (e.g., graywater mixed with sewage). Records of the sampling and testing results must be retained onboard for at least 3 years in the vessel’s recordkeeping documentation consistent with Part 4.2.
Vessels which do not enter waters subject to this permit for the calendar year need not conduct monitoring for that year, but must clearly indicate on their Annual Report that they did not enter waters subject to this permit during that year.
Contact Saron Marine to schedule your GrayWater Tests!
VGP 2013 Graywater Discharge Limits

(*) [as defined in CWA section 312(a)(10)]
(**) [means a “ferry” that: a) has a capacity greater than or equal to 100 tons of cargo or b) is authorized by the U.S.C.G. to carry 250 or more people.]
(***) [Large (500+ people for hire) & Medium (100 to 499 people for hire)]
Saron Marine PC
Kifissias Avenue 196,
145 62 Kifissia,
Athens
Greece
E: info@saronmarine.com
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Saron Marine
Shanghai Co Ltd
Room 105, Building C3,
Lane 3188 Xiupu Road,
Pudong New District
Shanghai City,
China
Saron Marine BV
Planet B.io – Van Iterson Building
Alexander Fleminglaan 1
2613 AX Delft
The Netherlands
E: ara@saronmarine.com
T: +31 (0)152062424