December 2009 Presented to: ASTM F25 Environmental Seminar

1. Standardization for Oil Water Separator (OWS) and Oil Content Monitor (OCM) Systems In-Service Engineering Agent Perspective December 2009 Presented to: ASTM F25 Environmental Seminar Presented by: Ray A. Morales US NAVY (NSWCCD)

2. Standardization for Oil Water Separator (OWS) and Oil Content Monitor (OCM) Systems In-Service Engineering Agent Responsibilities Provide technical support to the fleet for the in-service Oil Pollution Abatement (OPA) system including OWS, OCM, and transfer system. Test and Evaluation Equipment Modifications Technical Assistance System Certification and Training Provide support for the acquisition programs Design and Specification reviews

3. Applicable Standards & Regulations for Navy OWS and OCM systems Navy Ships are considered public vessels Department of Defense (DOD 4715.6-R1) Office of Chief of Naval Operations Instruction (OPNAVINST 5090.1C) American Bureau of Shipping (ABS) Naval Vessel Rules (NVR) USCG (Title 46 CFR Part 162.050 - Pollution Prevention Equipment) International Maritime Organization (IMO) ( MEPC.107(49) ) ASTM Standard ASTM F2283 “Standard Specification for Shipboard Oil Pollution Abatement System” Provides general design requirements Refers to MEPC.107(49) for OWS and OCM requirements. Standardization for Oil Water Separator (OWS) and Oil Content Monitor (OCM) Systems December 2009 3

4. Challenges for OWS and OCM systems Performance issues Reliability Maintenance costs Obsolescence issues Capital costs of unique systems Lack of Standards to ensure performance, reliability, and maintainability Standardization for Oil Water Separator (OWS) and Oil Content Monitor (OCM) Systems December 2009 4

5. Testing of MEPC. 107(49) Certified COTS OCMs Case Study – Testing of Commercial off-the-Shelf (COTS) MEPC. 107(49) Certified Oil Content Monitors (OCMs) Objective To conduct laboratory testing of selected IMO MEPC 107(49) certified COTS OCMs to evaluate their performance under various operating conditions and in the presence of contaminants to determine if these units would be suitable for shipboard use in Navy vessels based on direct comparison with the in-service OCM unit. December 2009 5

6. WATER FEED TANK THERMO SCANNER PRESSURE RELIEF VALVE DATA ACQUISITION WATER HEATER PRESSURE GAUGE / TRANSDUCER WATER PUMP FLOW METER P SAMPLE VALVE CONTAMINANT TANK DISPERSER CONTAMINANT INJECTION SYRINGE PUMP OIL INJECTION SYRINGE PUMP DRAIN FUNNEL P RECIRCULATION PUMP PRESSURE GAUGE AIR PUMP WATER PURIFICATION 5 Micron Filter TAP WATER FEED 0.5 Micron Filter Sediment Pre-filter Testing of MEPC. 107(49) Certified COTS OCMs Test Set-up December 2009

7. Testing of MEPC. 107(49) Certified COTS OCMs Screen shot of data acquisition software December 2009

8. Testing of MEPC. 107(49) Certified COTS OCMs Testing Performed Pre-test Checks: General checks to determine installation/ interface requirements and to ensure that OCM and testing equipment are operational Calibration Test: To verify OCM calibration at 0 PPM, 15 PPM and maximum oil concentration that the OCM can measure Oil Droplet Size Distribution Test: To determine deviations of the OCM calibration due to variations in oil droplet size distribution Flow/Pressure Range Test To determine deviations of the OCM calibration within the design Flow rate and Pressure Ratings and to determine if the OCM is fail-safe beyond the design flow/pressure range. Temperature Range Test To determine deviations of the OCM calibration within the design temperature Range. Different Oil Types Test To determine deviations of the OCM calibration in the presence of different types of oils (i.e., the oil mix# components separately; DFM, 9250, 2190, JP-5 and Synthetic oil) Response Time Test To determine time required by the OCM to alarm once high oil content is present. Contaminant / Interferences Tests (color, air, solids, emulsions, salinity) – Decision Making Test To incrementally change each given parameter to determine at which point: (1) The OCM measurements are affected and (2) The OCM decisions are affected (i.e., allows overboard discharge or recycle to the oily waste holding tank) December 2009

9. Testing of MEPC. 107(49) Certified COTS OCMs Conclusions drawn from this testing The COTS OCMs tested failed to detect free oil, failed to accurately measure oil under the conditions expected in the effluent of a failing OWS treatment system and required highly mechanically dispersed oil for accurate measurements. The COTS units tested produced critical failures (would allow overboard discharge of > 15PPM oil-in water), with and without interferences/contaminants, when tested under the conditions expected from a failing OWS treatment system . COTS units tested did not accurately measured different types of oils (affected calibration) Then COTS units tested required significant routine maintenance to keep operating properly. The sampling cell of the COTS units were cleaned between tests to ensure a zero baseline and prevent drift in the readings. Response time results were not consistent with requirement (e.g., < 5 secs) COTS units tested did not provide for “Fail-safe” design: Continued operation even with no flow allowing “by-passing” the OCM while the data recorded shows acceptable effluent. This could allow continued operation of OWS even with unacceptable overboard discharge while zero (0) oil PPM is recorded. Design does ensure diverter valve default position to recycle during all possible failures modes COTS units tested were designed and calibrated to meet MEPC.107(49) December 2009

10. Testing of Commercial off-the-Shelf (COTS) Oil Content Monitors (OCMs) Test Results/ FindingsOil Droplet Size Distribution Test (Disperser’s settings) December 2009

11. Test Results/ FindingsOil Droplet Size Distribution Test (Disperser’s settings)Oil Droplets Micrographs: 15 PPM oil injection at 8,000 RPM Disperser’s Speed (Standard Conditions) Testing of MEPC. 107(49) Certified COTS OCMs 28µm 6µm 46µm 4µm 6µm 3µm 28µm 25µm 5µm 28µm 6µm 32µm 13µm 6µm 35µm 29µm 14µm 3µm 2µm 8µm 14µm 5µm 13µm 32µm 9µm 5µm 12µm 3µm 6µm 11 December 2009

12. Testing of MEPC. 107(49) Certified COTS OCMs Test Results/ FindingsOil Droplet Size Distribution Test December 2009

13. Different Types of Oils Test 25 20 15 Oil Concentration, PPMv 10 5 0 bilge mix diesel fuel 2190 lube oil 9250 lube oil JP5 synthetic marine Different Types of Oils ET-35N OCM 1 @ 8k RPM OCM 1 @ 12K RPM OCM 2 @ 8k RPM OCM 2 @ 20k RPM OCM 3 @ 8k RPM OCM 3 @ 22K RPM Testing of MEPC. 107(49) Certified COTS OCMs Test Results/ Findings December 2009

14. 43 31 14 11 Target Response Time, 5 secs Required by MEPC.107(49) Testing of MEPC. 107(49) Certified COTS OCMs Test Results/ FindingsResponse time • NOTE : For this test oil was injected at 40 PPM oil at the corresponding optimum disperser’s speed for each OCM: • The calculated time for the oil to travel from the injection point to the OCM was subtracted from the time measurements • The blue columns represent the first time that the OCM detected any oil • The total height of the columns represents the total time for the OCM to alarm December 2009

15. Testing of MEPC. 107(49) Certified COTS OCMs Test Results/ Findings Contaminant/Interference/Salinity Test – Summary December 2009

16. Testing of MEPC. 107(49) Certified COTS OCMs Test Results/ FindingsContaminant/Interference/Salinity Test – Summary The Navy in-service OCM was not affected by the presence of interferences/ contaminants at low concentrations. It produces unnecessary recycle at high concentrations of these interferences/contaminants and “fails safe.” The COTS unit tested produced critical failures with and without interferences/contaminants when tested under the conditions expected from a failing treatment system. The COTS unit tested was not significantly affected by the presence of interferences/contaminants when the sample was conditioned at very high disperser’s speed. December 2009

17. Potential Areas of Standardization for OWS and OCM Systems OWS and OCM Revise ASTM F-2283 Different Type of Oil test Reliability and maintainability OCM Free oil and droplet size distribution tests Fail-safe design Testing of MEPC. 107(49) Certified COTS OCMs December 2009 17

18. (BACK UP SLIDES) Testing of MEPC. 107(49) Certified COTS OCMs END December 2009 18

19. Testing of MEPC. 107(49) Certified COTS OCMs Test Approach Test Set-up is shown in next figure Baseline - Navy OCM calibration standard conditions: Oil type: Mixture by vol 50% diesel fuel, 25% 2190 lube oil, 25% 9250 lube oil (used for years as standard in all Navy testing) Sample conditioning: In-line disperser set at 8,000 rpm to produce approximately 20% oil droplets above 20 um diameter (expected in the effluent of a failing parallel plates OWS) Performance results from the in-service OCM unit OCMs tested within a range of various operating conditions, oil types and contaminants/ interferences Oil concentration was determined by mass balance of oil injected into the water stream December 2009

20. Testing of MEPC. 107(49) Certified COTS OCMs Test Results/ Findings Calibration Test Notes: (1) Standard disperser’s speed (8k RPM). (2) maximum disperser’s speed (3) OEM of COTS units indicated that their units were calibrated to meet the MEPC. 107(49) and that recalibration will invalidate this certification December 2009

21. Testing of MEPC. 107(49) Certified COTS OCMs Test Results/ FindingsOil Droplet Size Distribution Test: Acceptable Region Critical Failure - >15 PPM Overboard Discharge December 2009

22. Testing of MEPC. 107(49) Certified COTS OCMs Conclusions Summary The COTS OCMs tested failed to detect free oil, failed to accurately measure oil under the conditions expected in the effluent of a failing parallel plate OWS, and required highly mechanically dispersed oil for accurate measurements These OCMs were not designed to condition the sample The accuracy of these units will depend on the sample conditioning of the secondary treatment effluent These units may produce unacceptable overboard discharge if the failure of the treatment systems produces large oil droplets (e.g., cracked membrane, etc.) The measurements of the OCMs tested were not significantly affected by variations in pressure or temperatures The measurements of all the units tested, including the In-service OCM, are dependent on the type of oil present. December 2009

23. Testing of MEPC. 107(49) Certified COTS OCMs Conclusions Summary(Cont.) The response times of all the MEPC. 107(49) Certified OCMs tested exceeded the maximum of 5 seconds required for this certification (e.g., 11 to 43 seconds) The ET-35N was not affected by the presence of interferences/ contaminants at low concentrations. It produces unnecessary recycle at high concentrations of these interferences/contaminants and “fails safe.” The COTS unit tested produces critical failures with and without interferences/contaminants when tested under the conditions expected from a failing parallel plate OWS The COTS units tested were not significantly affected by the presence of interferences/contaminants when the sample was conditioned at very high disperser speeds. OEM of COTS units indicated that their units were calibrated to meet the MEPC.107(49) and that recalibration will invalidate this certification. December 2009

24. Testing of MEPC. 107(49) Certified COTS OCMs Conclusions Summary (Cont.) The sampling cell of the COTS units were cleaned between tests to ensure a zero baseline. These units may require self-cleaning capabilities for proper operation. COTS units continued operation even with no flow allowing “by-passing” the OCM while the data recorded shows acceptable effluent. COTS units do not provide signal output to energize the diverter valve when the OCM is operational and readings below 15 ppm as required for a “fail-safe” installation. December 2009

25. Testing of MEPC. 107(49) Certified COTS OCMs Recommendations Summary Performance and reliability shipboard demonstration should be conducted prior to considering these units for shipboard installation. Integration requirements should be developed to ensure that the “fail- safe” intent is met if these units are considered by the Navy for shipboard use: Diverter valve “Fail-safe” requirements Diverter valve position to overboard only when received signal from OCM. Default position of the diverter valve shall be to the OWHT when Normal de-energized position No signal input from the OCM Actuator failure Electrical power supply failure OCM signal output “Fail-safe” requirements: OCM shall have consecutives acceptable readings for at least 1 minute prior to send signal to the diverter valve to: Verify that the effluent is acceptable prior to being sent overboard. To avoid constant cycling of the diverter valve that can result in unacceptable overboard discharge and valve failure. OCM signal shall be immediately interrupted if any reading is unacceptable The units tested use some variation of light scattering technology. Other available technologies such as UV fluorescence should be evaluated. December 2009