Does analytical monitoring of graywater required for cruise ships in Parts 5.1. and 5.2 of the VGP need to be done by an approved lab?
For purposes of this permit, analytical monitoring of graywater does not need to be conducted by an approved lab. Discussion EPA allowed this flexibility in the VGP to accommodate vessels engaged in international voyages which rarely frequent U.S. waters or vessels which test to see if their systems meet certain standards before entering waters of the U.S. The analytical monitoring must be done for each of the constituents (biochemical oxygen demand (BOD), fecal coliform, suspended solids, pH, and total residual chlorine), in accordance with methods specified in 40 CFR Part 136.