IMO 107(49)/46 CFR 162.050

1. IMO 107(49)/46 CFR 162.050 15 ppm Bilge Separators (Oily Water Separators) and 15 ppm Bilge Alarms (Oil Content Monitors) Matthew D. MacGregor TEi-Testing Services, LLC Salt Lake City, UT - USA Revision 04 December 2009

2. What’s Wrong with the way Pollution Prevention Devices are Tested for Approval • Are the current test methods found in International (IMO 107(49) and National (46 CFR 162.050) Standards inadequate for the Approval of Oily Water Separators and Oil Content Monitors. • What are the deficiencies as found by a Laboratory that conducts testing of these devices. • Is it necessary to develop new Standards to address user, manufacturer and regulators concerns with deficiencies found in the current Standards. • What changes or recommendations does a Laboratory have for improving or replacing the Standards.

3. 15 ppm Oily Water Separator Current IMO/CFR Test Protocol Sections Separation Capability as challenged by three (3) test fluid “A”, “B” and “C” • Test Fluid A is Marine Residual Fuel Oil IAW ISO 8217 type RMG 35 (density at 15°C not less than 980 kg/m3) • Test Fluid B is Marine Distillate Fuel Oil IAW ISO 8217 type RMG DMA (density at 15°C not less than 830 kg/m3) • Test Fluid C is a Mixture of an Oil-in-Fresh water emulsion in the Ratio of • 947.8 g of fresh water • 25.0 g of Test Fluid A • 25.0 g of Test Fluid B • 0.5 g surfactant (sodium salt of dodecylbenzene sulfonic acid) in the form • 1.7 g “iron oxides” (black ferrosoferric oxide (Fe3Of) with a particle size distribution of which 90% is less than 10 microns, the remainder having a maximum particle size of 100 microns.

4. Test Fluid A Challenge • Operation with 100% oil for not less than 5 minutes• Condition with between 0.5 and 1.0% (5 000 – 10 000 ppm) for 2 Volumes of the Test Unit• Operation with between 0.5 and 1.0% for 30 minutes• Condition with 25% oil for 2 Volumes of the Test Unit• Operation with 25% oil for 30 minutes • Operation with 100% oil for not less than 5 minutes • Operation with Fresh Water for 15 minutes • Variable Volume from 0% to 25% in 15 minute durations for 120 minutes

6. Test Fluid B Challenge • Condition with between 0.5 and 1.0% (5 000 – 10 000 ppm) for 2 Volumes of the Test Unit• Operation with between 0.5 and 1.0% for 30 minutes• Condition with 25% oil for 2 Volumes of the Test Unit • Operation with 25% oil for 30 minutes

7. Test Fluid C Challenge • Condition with between 6.0% (at least 3 000 ppm emulsified oil) for 2 Volumes of the Test Unit• Operation with 6.0% for 15 minutes

8. Physical Testing of Device • Vibration test • Temperature test • Humidity test • Inclined Operation test • Reliability of Electrical and Electronic Equipment

9. Oily Water Separator Test Rig

10. Deficiencies Noted by Laboratory • Test fluids are not representative of “True World” bilge contaminants • Test durations do not account for Test Unit capacity beyond test period, meaning that if after the representative 24 hour operation period the used does not know what maintenance is required to keep the Test Unit operating to meet discharge requirements • Inclined operation test should be done on all three test fluids • Test Fluid A Variable Volume testing is difficult to obtain even with a throttling valve • Temperature variation in the test fluids affects influent quality

11. Can an Oil Content Monitor control the Oily Water Separator? NO! An installation practice that has become common in the shipping industry is to plumb the Oil Content Monitor inline with the discharge from the Stage One section (old MEPC 60(33) device) to the Stage Two section (new MEPC 107(49) device) believing that if the Monitor determines that the effluent is less than 15 ppm from the Stage One section it can then be discharged without going through Stage Two, thus saving costs.

12. 15 ppm Oil Content Monitor Current IMO/CFR Test Protocol Sections • Test Fluids are the same as for 15 ppm Oily Water Separator • Calibration Test done with Test Fluid A, B and C at 0, 15 and Full scale ppm (challenged for at least 15 minutes) • Contamination and Color Test (15 minute duration each) • Clean water and 10 ppm Test Fluid B • Contaminated water with 10 ppm Iron Oxide and 10 ppm Test Fluid B • Contaminated water with 50 ppm Iron Oxide and 10 ppm Test Fluid B • Contaminated water with 100 ppm Iron Oxide and 10 ppm Test Fluid B • Clean water and 10 ppm Test Fluid B • Clean water to 6% Salt Water Solution

13. 15 ppm Oil Content Monitor Current IMO/CFR Test Protocol Sections Continued • Sample Pressure and Flow Variation Test • Adjust pressure to Test Unit from 0.5 operational normal to Test Unit • Adjust pressure to operational normal to Test Unit • Adjust pressure to 2.0 operational normal to Test Unit • Adjust flow to Test Unit to 0.5 operational normal to Test Unit • Adjust flow to operational normal to Test Unit • Adjust flow to 2.0 operational normal to Test Unit • Shut off Test • IMO Test Fluid B at 15 ppm then off for 8 hours then on • CFR Test Fluid B at 15 ppm then off for one week then on for 8 hours.

14. 15 ppm Oil Content Monitor Current IMO/CFR Test Protocol Sections Continued • Utilities Supply Variation Test • Adjust electrical input to Test Unit to 90% of operational normal • Adjust electrical input to Test Unit to 110% of operational normal • Adjust pneumatic input to Test Unit to 90% of operational normal • Adjust pneumatic input to Test Unit to 110% of operational normal • Adjust hydraulic input to Test Unit to 90% of operational normal • Adjust hydraulic input to Test Unit to 110% of operational normal

15. 15 ppm Oil Content Monitor Current IMO/CFR Test Protocol Sections Continued • Calibration and Zero Drift Test • Calibration Drift Test • 15 ppm Test Fluid B for Eight (8) hours • Zero • Oil Free Water for Eight (8) hours • Response Time Test • Clean Water to above 15 ppm oil in water using Test Fluid A • Clean Water to above 15 ppm oil in water using Test Fluid B • Clean Water to above 15 ppm oil in water using Test Fluid C Physical Testing of Device Same as for 15 ppm Oily Water Separator

17. Deficiencies Noted by Laboratory • Calibration test wrongly identified. Should be titled Operational test. • Calibration test challenge testing time is insufficient to discover capability of Test Unit to detect oil in water. Test period should be at least 24 hours as with the Oily Water Separator. • Contamination and Color Test challenge testing time is insufficient to discover capability of Test Unit to detect oil in water when contaminates are present in the Test Fluid. • Calibration and Zero test is in violation of International and National Calibration Practices and Procedures

18. Conclusion • Oily Water Separator • The use of additional Test Fluids representing “Real World” bilge contaminants should be used to demonstrate compliance. (Test Fluid “D”, “E” etc?) • Capacity of any Chemical Reactive, Absorbent, Segregation or other type of expendable material should be evaluated and reported. • Inclined operation test should be done on all three test fluids • Oil Content Monitor • Increase the duration of the “Calibration” test to demonstrate that the Oil Content Monitor can correctly detect oil in water for the same period that a Oily Water Separator must operate without user input.

19. Conclusion Continued • Increase the duration of the “Contamination and Color” test to demonstrate that the Oil Content Monitor can correctly detect oil in water for the same period that a Oily Water Separator must operate without user input. • Correctly test the Calibration and Zero Drift susceptibility of the Test Unit in accordance with International and/or National Standards