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            United States Environmental Protection Agency
       \    Office of Wastewater Management
            Washington, DC 20460
Oily  Bilgewater Separators
                                    EPA800-R-11-007
                                    November 2011

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Oily Bilgewater Separators	CONTENTS


                                    CONTENTS

                                                                              Page

SECTION! INTRODUCTION	1

SECTION 2 REGULATION OF OIL IN BILGEWATER DISCHARGE	3

SECTION 3 TREATMENT TECHNOLOGIES AND COMPONENTS OF BILGEWATER SEPARATORS	7
      3.1    Gravity Oil Water Separators	7
      3.2    Centrifugal Separators	8
      3.3    Polishing Treatment for Bilge Separators	8
             3.3.1  Absorption and Adsorption	9
             3.3.2  Biological Treatment	10
             3.3.3  Coagulation and Flocculation	11
             3.3.4  Flotation	11
             3.3.5  Membrane Technologies (Ultrafiltration)	12
      3.4    Residual Generation	14
      3.5    Oil Content Monitor	14
      3.6    Space Requirements	15

SECTION 4 EFFECTIVENESS OF BILGE SEPARATOR TREATMENT TECHNOLOGIES	17
      4.1    Bilge Separator Treatment System A	18
      4.2    Bilge Separator Treatment System B	18
      4.3    Bilge Separator Treatment System C	19
      4.4    Bilge Separator Treatment System D	19
      4.5    Bilge Separator Treatment System E	20
      4.6    Bilge Separator Treatment System F	20
      4.7    Bilge Separator Treatment System G	20
      4.8    Bilge Separator Treatment System H	21
      4.9    Bilge Separator Treatment System 1	21
      4.10   Bilge Separator Treatment System J	21
      4.11   Bilge Separator Treatment System K	22
      4.12   Bilge Separator Treatment System L	22
      4.13   Bilge Separator Treatment System M	22
      4.14   Summary of Bilge Separator Effectiveness	22
      4.15   Limitations of Certification Test Data	24

SECTION 5 REFERENCES	25

ATTACHMENT A: PUBLISHED LITERATURE FROM VENDOR WEBSITES
ATTACHMENT B: SUMMARIES OF INFORMATION GATHERED IN TELEPHONE CONVERSATIONS
ATTACHMENT C: VENDOR SUBMITTED PERFORMANCE DATA

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Oily Bilgewater Separators	CONTENTS

                                 LIST OF TABLES
                                                                                Page
Table 1: Reverse Osmosis Particle Size and Molecular Weight Ranges	12
Table 2: Residuals Generated From Treatment Technologies	14
Table 3: Performance of Bilge Separator Treatment System on Three Commercial
       Vessels	18
Table 4: Effluent Oil Concentrations for Bilge Treatment Systems	23
                                 LIST OF FIGURES
                                                                                Page
Figure 1: Footprint Required for Various Bilge Separator Treatment Systems	16
The EPA technical contacts for this document are Ryan Albert (202) 564-0763 and Robin Danesi
(202)564-1846.
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Oily Bilgewater Separators	Executive Summary
                               EXECUTIVE SUMMARY

       Oily wastes and waste oils are byproducts of operating ocean-going vessels, which
generate millions of tons of such wastes annually. Oily bilgewater is the mixture of water, oily
fluids, lubricants and grease, cleaning fluids and other wastes that accumulate in the lowest part
of a vessel from a variety of sources including engines (and other parts of the propulsion
system), piping, and other mechanical and operational sources found throughout the machinery
spaces of a vessel. Bilge spaces are periodically pumped out, and the accumulated bilgewater is
transferred into a holding tank. The bilgewater then can be managed by either retaining it
onboard in the holding tank and later discharging it to a reception facility on shore, or treating it
onboard with a bilge separator. Bilge separators, also known as oily water separators (OWS), are
onboard treatment systems designed to remove the oil from vessel bilgewater prior to its
discharge. Bilge  separator technologies have advanced in recent years to improve the
effectiveness of oily bilgewater treatment.

       Current regulations of oily bilgewater discharge from vessels is based on Annex I of the
International Convention for the Prevention of Pollution From Ships, 1973 as modified by the
Protocol of 1978 (MARPOL 73/78). Under MARPOL, all  ships over 400 gross tons (GT) are
required to have  equipment installed onboard that limits the discharge of oil into the oceans to 15
ppm when a ship is en route. All vessels over 400 GT are also required to have an oil content
monitor (OCM), including a bilge alarm, integrated into the piping system to detect whether the
treated bilgewater that is being discharged from the bilge separator meets the discharge
requirements. Canada has bilge discharge requirements that are more strict than the international
15 ppm  standard. The Canadian Regulations for the Prevention  of Pollution from Ships and for
Dangerous Chemicals requires 5 ppm bilge alarms on the Great Lakes.

      EPA's 2008  Vessel General Permit for Discharges Incidental to the Normal Operation  of
Vessels  (VGP) also addresses discharges of oil, including oily mixtures, from ships subject to
MARPOL. Such discharges must have concentrations of oil less than 15 ppm. The VGP also
includes technology-based effluent limits and related requirements for specific discharge
categories,  including bilgewater discharges.

      Bilge separators, oil content meters and bilge  alarms are  certified by the U.S.  Coast
Guard to meet 46 CFR 162, which implements MARPOL Annex I regulations  in the U.S. More
than one hundred bilge separators have been certified by the U.S. Coast Guard to meet the
MARPOL  15 ppm oil discharge standard. All of these bilge separators are treatment systems that
combine a gravity oil-water separator (OWS) or centrifuge with one or more additional unit
operations that "polish" the bilgewater effluent to reduce concentrations of emulsified oil. Unit
operations that are added to OWS/centrifuge-based bilge separator systems include:

       •      Absorption and Adsorption,
       •      Biological Treatment,
       •      Coagulation  and Flocculation,
       •      Flotation, and
       •      Ultrafiltration.

      EPA evaluated the effectiveness of bilge separators by their ability to achieve low
effluent oil concentrations. Certification test data demonstrate that different bilge separators can

                                           iii

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Oily Bilgewater Separators	Executive Summary
achieve 15 ppm and a number of these systems achieved effluent hydrocarbon concentrations
below 5 ppm under controlled conditions. Information about bilge separator treatment systems
and certification test data was gathered from a number of vendors. This information illustrates
that bilge separator treatment systems, based on different treatment technologies and
combinations of unit operations, can achieve and exceed compliance with the U.S. Coast Guard
certification standards.

       Conversely, some type-certified bilge separators have difficulty meeting the 15 ppm
MARPOL discharge standard onboard vessels. Some treatment technologies appear to perform
better than others at sea, for example better able to handle the rolling and pitching motion,
variable bilgewater composition, and periodic solids loading. Certain treatment technologies
appear to require excessive operator attention and/or maintenance to function properly, or
generate excessive quantities of oily residuals requiring handling and disposal. The laboratory
certification tests for these pollution control equipment (i.e., bilge separators, oil content meters,
and bilge alarms) may not be comprehensive enough to reveal these shortcomings.

       Bilge separator manufacturers and vendors, as well as major shipping companies,
indicated that there is an increase in the level  of effort required to meet a 5 ppm oil standard
versus 15 ppm in bilgewater discharges. Vessels that install certified bilge separators currently
on the market, and operate and maintain them conscientiously, should be able to meet a 15 ppm
discharge  standard, notwithstanding the possible difficulties noted above. Meeting 5 ppm oil
standards for bilge discharge is also possible, although it requires an additional commitment to
acquiring and maintaining  effective bilge separators and OCMs, along with adhering to "best
practices" and guidance such as the International Maritime Organization/Marine Environment
Protection Committee (EVIO/MEPC) Integrated Bilgewater Treatment System (IBTS) practices
(IMO/MEPC, 2008).
                                           IV

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Oily Bilgewater Separators	Section 1 - Introduction


                                                                          SECTION 1
	INTRODUCTION

       Oily wastes and waste oils are byproducts of operating ocean-going vessels, which
generate millions of tons of such wastes annually (Karakulski et al., 1995). Oily bilgewater is the
mixture of water, oily fluids, lubricants and grease, cleaning fluids and other wastes that
accumulate in the lowest part of a vessel from a variety of sources including engines (and other
parts of the propulsion system), piping, and other mechanical and operational sources found
throughout the machinery spaces of a vessel (EPA, 2008). Most of these wastes are generated in
the vessel's engine room and end up in the bilge. The types of fluids leaked from these sources
varies, resulting in a complex mixture of fluids in the vessel's bilge. Bilgewater may typically
contain various fuels, greases, antifreeze, hydraulic fluids, cleaning and degreasing solvents,
detergents, metals, catalytic fines, soot, and other solid particles (EPA, 2008). The composition
and physical-chemical characteristics of bilgewater can vary widely, both over time and among
vessels. Oil/hydrocarbon concentrations in vessel bilges commonly fall  in the 100 to 400 ppm1
range (U.S. Navy 1999-2000). Ghidossi et al., (2009) reported a somewhat higher 500 ppm oil
concentration in the bilgewater of a ferry.

       Aside from oil and hydrocarbons, bilgewater contains a variety of other pollutants. These
include "classical" pollutants (oxygen-consuming parameters, suspended solids), metals (arsenic,
copper, cadmium, chromium, lead, mercury, selenium and zinc) and organics (benzene,
chloroform, hexachlorocyclohexane isomers, ethyl benzene, heptachlor, heptachlor epoxide,
naphthalene, phenols, phthalate esters, toluene, trichlorobenzene, trichloroethane, and xylene)
(EPA, 1999). In EPA's recent report to Congress on the Study of Discharges Incidental to
Normal Operation of Commercial Fishing Vessels and Other Non Recreational Vessels less than
79 feet (EPA, 2010), a comprehensive analysis was made of bilgewater discharges from small
commercial vessels including fishing vessels, tow/salvage vessels, water taxis, and tour vessels.
Among the metals detected in bilgewater, dissolved copper, selenium, and zinc, as well as total
arsenic, were consistently measured at concentrations exceeding the most stringent National
Recommended Water Quality Criteria (NRWQC) from several vessel classes. The classical
pollutants BODs, sulfide, TSS, and TRC were found at potentially significant concentrations in
bilgewater from fishing vessels, tow/salvage vessels, water taxis, and tour vessels. Among
several pathogen indicators, enterococcus was present at concentrations exceeding NRWQC in
bilgewater samples collected from fishing boats. Total phosphorus exceeded a screening
benchmark for nutrients.  Concentrations of the semivolatile organic chemical (SVOC) bis (2-
ethylhexyl) phthalate  exceeded NRWQC in the bilgewater discharges of fishing vessels,
tow/salvage vessels, water taxis, and tour vessels. Benzene sampled in bilgewater from
tow/salvage vessels was the only VOC found at concentrations exceeding the most  stringent
NRWQC, while the screening benchmark for nonylphenol was exceeded in a single bilgewater
sample collected from a fishing vessel. However, EPA believes that the design, construction, and
operation of larger vessels not sampled for that study (e.g., cruise ships, ferries, barges, freighters
1 Concentrations of oil in bilgewater are measured by several analytical methods. EPA Method 1664A measures oil
and grease as hexane extractable material (HEM) and petroleum hydrocarbons specifically as silica-gel treated
hexane extractable material (SGT-HEM). The method detection limit for HEM is 1.4 mg/L and the minimum
quantitation level is 5 mg/L. The older EPA Method 418.1 measures total petroleum hydrocarbons (TPH) using
different methods  of solvent extraction and quantification. Consequently, the results of samples analyzed with the
different methods  may not be directly comparable. However, they both indicate whether oil and grease (i.e.,
hydrocarbons) are present in a sample of bilgewater.	
                                             1

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Oily Bilgewater Separators	Section 1 - Introduction
and tankers) differs considerably from that of smaller vessels that were sampled, which could
result in significantly different bilgewater characteristics. Hence, EPA cautions against applying
the limited bilgewater results from that study to all vessels subject to the VGP.

       It is necessary to periodically pump out the bilge spaces into a holding tank to maintain
vessel stability and eliminate potentially hazardous conditions from the accumulation of bilge
waste (EPA, 2008). The bilgewater then can be managed by either retaining it onboard in the
holding tank and later discharging it to a reception facility on shore, or treating it onboard with a
bilge separator. Treatment reduces the volume of oily bilgewater that must be stored aboard the
vessel. The treated bilgewater then can be discharged overboard in accordance with applicable
standards and regulations, while the petroleum products extracted by the bilge separator (i.e.,
oily waste) are retained in a dedicated holding tank onboard (and later could be incinerated
and/or off-loaded in port).

       Oil can be found in bilgewater in several forms: free, dispersed and emulsified (Cheryan
and Rajagopalan, 1998). The differences are based primarily on the size of oil droplets. In an oil-
water mixture, free oil is characterized by droplet  sizes greater than 150 jim. Dispersed oil has a
size range of 20-150 |im and emulsified oil droplets are typically smaller than 20 jim. The form
of oil present in bilgewater is important in determining the effectiveness of treatment.

       Traditionally, ocean-going ships use OWS gravity separation devices to treat oily
bilgewater. However, OWS separators generally cannot comply with increasingly stringent
regulation of oily bilgewater discharge and the greater difficulty of separating oil from
bilgewater in modern vessels. Consequently, the effectiveness of oily bilgewater treatments has
improved beyond that provided by traditional OWS. Bilge separators that meet current U.S. and
international regulations (discussed below) are all treatment systems comprised of a series of unit
operations. These systems also incorporate an effluent OCM, an alarm and an automated shut-off
designed to prevent the discharge of bilgewater exceeding discharge standards for oil.

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Oily Bilgewater Separators	Section 2 - Regulation of Oil in Bilgewater Discharge


                                                                          SECTION 2
	REGULATION OF OIL IN BILGEWATER DISCHARGE

       Current regulations of oily bilgewater discharge from vessels are based on Annex I of the
International Convention for the Prevention of Pollution from Ships, 1973 as modified by the
Protocol of 1978 (MARPOL 73/78). MARPOL aimed to minimize pollution of the seas,
including dumping, oil and exhaust pollution. The United States ratified MARPOL Annex I in
1983. One hundred fifty countries, representing greater than 98% of the world's shipping
tonnage, are parties to the  Convention. MARPOL includes six annexes, covering six categories
of vessel discharges: oil (Annex I), noxious liquid substances (Annex II), harmful packaged
substances (Annex III), sewage (Annex IV), garbage (Annex V), and air emissions (Annex VI).
Annex I establishes requirements for the control of oil pollution from vessels and applies  to all
ships operating in the marine environment, unless expressly provided otherwise. Small to large
amounts of oil can be found in numerous vessel discharges, including bilgewater, deck runoff,
and engine effluent. The requirements of this Annex apply.  Specific to machinery spaces, Annex
I requirements cover all petroleum products, including crude oil, fuel oil, oily waste, oily
mixtures located in the bilge, and petroleum products in cargo spaces of oil tankers.

       Under MARPOL, all ships over 400 gross tons are required to have equipment installed
onboard that limits the discharge of oil into the oceans to 15 ppm when a ship is en route.2
However, the limit for discharge into special areas differs by vessel type and size.3 Such ship
equipment allows for compliance with both international regulations (MARPOL) and U.S. Coast
Guard regulations that require the oil content of the discharged effluent to be less than 15 ppm
and that it not leave a visible sheen on the surface of the water. Regulations also require that all
oil  or oil residues that cannot be discharged in compliance with these regulations be retained
onboard or discharged to a reception facility.

       In 1992, during its 33rd session, the International Maritime Organization (IMO) Marine
Environment Protection Committee adopted a resolution, MEPC.60(33), containing guidelines
and specifications for pollution prevention equipment for machinery space bilges of ships. In
2003, recognizing the advancement of technology since 1992, the Committee adopted resolution
MEPC. 107(49), which contained new guidelines and specifications that superseded those
adopted in 1992. MEPC. 107(49) changed the fluids used to test pollution prevention equipment
so they would more closely represent the bilge wastes encountered on vessels. Test fluid "C",
which contains a surfactant chemical, emulsified oil and fine particulates, was added as a more
realistic synthetic bilgewater. Under MEPC. 107(49), the bilge separator must be capable  of
separating the oil from this emulsion to produce an effluent with an oil content not exceeding 15
ppm. MEPC. 107(49) also  requires that the OCM record data and time, oil content and operating
status, and save this information for 18 months (i.e., Oil Record Book regulations).
2 Ocean-going vessels less than 400 gross tons are not required to have the equipment onboard if they have the
capacity to retain onboard all oily mixtures and can discharge these oily mixtures to a reception facility (33 CFR
155.350). Certain vessels in this category that embark on international voyages, however, are required to have an
International Pollution Prevention Certificate (IOPP) that requires them to have pollution prevention equipment
onboard.
3 A ship of 400 gross tons or over and any oil tanker may not discharge oil or oily mixture within a special area. In
the Antarctic area, discharge into the sea of oil or oily mixture from any ship is prohibited. A ship of less than 400
gross tons other than an oil tanker may not discharge oil or oily mixture within a special area, unless the oil content
of the effluent without dilution does not exceed 15 ppm (MARPOL 73/78 Annex I).	

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Oily Bilgewater Separators	Section 2 - Regulation of Oil in Bilgewater Discharge
       The Act to Prevent Pollution from Ships (APPS; 33 U.S.C. § 1901 et seq.) is the federal
law primarily implementing those provisions of MARPOL that have been ratified by the United
States. With respect to implementation of Annex I, APPS applies to all U.S. flagged ships
anywhere in the world, and to all foreign-flagged vessels operating in the navigable waters of the
United States. Violations of APPS or MARPOL may lead to detention of the vessel in port,
denial of port entry, or the initiation of civil or criminal enforcement proceedings.

       The U.S. Coast Guard generally has the primary responsibility to prescribe and enforce
the regulations necessary to implement APPS in the United States. The U.S. Coast Guard's
requirements for oil discharges from ships other than oil tankers4 are very similar to Annex I's
requirements. U.S. Coast Guard regulations (33 CFR 151.10) provide that, when within 12
nautical miles of the nearest land, any discharge of oil or oily mixtures into the sea from a ship is
prohibited except when all of the following conditions are satisfied:

       •  The oil  or oily mixture does not originate from cargo pump room bilges;
       •  The oil  or oily mixture is not mixed with oil cargo residues;
       •  The oil  content of the effluent without dilution does not exceed 15 ppm;
       •  The ship has in operation oily-water separating equipment, a bilge monitor, bilge
          alarm, or combination thereof, as required by Part 155 Subpart B; and
       •  The oily-water separating equipment is equipped with a U.S. government- or EVIO
          type-approved 15 ppm bilge alarm.

       When vessels are proceeding en route more than 12 nm from the nearest land (and not
within a special area), the conditions allowing for bilgewater discharge according to the U.S.
Coast Guard regulations are somewhat different. Most notably, the last condition from above
(oily-water separating equipment is equipped with a U.S.- or EVIO-approved 15 ppm bilge  alarm)
is not included. The regulations still require the ship to operate oily-water separating equipment,
a bilge monitor, bilge alarm (or combination), and the undiluted oil content of the bilgewater
effluent must still be less than 15 ppm.

       EPA's 2008 Vessel General Permit for Discharges Incidental to the Normal Operation of
Vessels (VGP) also addresses discharges of oil, including oily mixtures, from ships subject to
MARPOL. For example, discharges must have concentrations of oil less than 15  ppm. The 2008
VGP also includes technology-based effluent limits and related requirements for specific
discharge categories, including bilgewater discharges. These requirements include the following:

       •  Vessel operators may not use dispersants, detergents, emulsifiers, chemicals or  other
          substances to remove the appearance of a visible sheen in their bilgewater discharges.
       •  Except in the case of flocculants or other required additives (excluding any
          dispersants or surfactants) used to enhance oil/water separation during processing
          (after bilgewater has been removed from the bilge), vessel operators may not add
          substances that drain to the bilge that are not produced in the normal operation of a
          vessel.
       •  All vessels must minimize the discharge of bilgewater into waters subject to this
          permit.  This can be done by minimizing the production of bilgewater, disposing of
          bilgewater on shore where adequate facilities exist, or discharging into waters not
4The requirements for oil tankers are found in a separate section of the regulations (33 CFR Part 157).

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Oily Bilgewater Separators	Section 2 - Regulation of Oil in Bilgewater Discharge
           subject to this permit (i.e., more than 3 nautical miles (nm) from shore) for vessels
           that regularly travel into such waters.
       •   Vessels greater than 400 gross tons shall not discharge untreated oily bilgewater into
           waters subject to this permit.
       •   Vessels greater than 400 gross tons that regularly sail outside the territorial sea (at
           least once per month) shall not discharge treated bilgewater within 1 nm of shore if
           technologically feasible.

       Bilge separators, oil content meters and bilge alarms are certified by the U.S. Coast
Guard to meet 46 CFR 162 (implementing MARPOL Annex I regulations). Type approval is
based on testing of manufacturer-supplied oil pollution control equipment by an independent
laboratory, in accordance with test conditions prescribed by the U.S. Coast Guard (33 CFR 155
and 157 and 46 CFR 162). In conformance with EVIO resolution MEPC. 108(49), the analysis of
oil (petroleum products or hydrocarbon, HC) in bilge separator effluent must be by ISO method
9377-2:20005 or equivalent.

       Some  countries have bilge discharge requirements that are more stringent than the
international 15 ppm standard. MARPOL identifies "special areas" which are considered so
vulnerable to pollution by oil that oil discharges within them have been completely prohibited,
with minor and well-defined exceptions. The 1973 Convention identified the Mediterranean Sea,
the Black Sea, and the Baltic Sea, the Red Sea and the Gulfs area as special areas.

       The Canadian Regulations for the Prevention of Pollution from Ships and for Dangerous
Chemicals requires 5 ppm bilge alarms on inland waters6 (Great Lakes), and the Canadian Arctic
Waters Pollution Prevention Act requires zero discharge in Arctic waters (all Canadian waters
north of 60°). Per personal contact with P.  Topping of Transport Canada, when Canada first
introduced the 5 ppm option in their regulations, it included the requirement for vessels on inland
waters to have approved 5 ppm oil filtering equipment  as well as a 5 ppm  oil  content meter and
alarm (see Attachment B). This requirement was found to be unworkable, however, because
foreign administrations were approving only 15 ppm oil filtering equipment. Canada issues
Certificates of Type Approval for bilge alarms that meet the 5 ppm performance standard.

       A number of manufacturers of bilge separators anticipate that a 5 ppm bilgewater oil
discharge standard may become more  common and widespread in the future.  Now, Lloyd's
Register Clean Shipping Index Verification provides a verification service to ship owners and
operators wishing to demonstrate their success in reducing the environmental impact of their
activities beyond current requirements of classification or statutory rules and  regulations,
5 This analytical method is "Water quality — Determination of hydrocarbon oil index — Part 2: Method using solvent extraction
and gas chromatography".
6 Part 2, Subdivision 4 (Oil and Oily Mixture Discharges) of the Regulations for the Prevention of Pollution from Ships and for
Dangerous Chemicals states the following under Authorized Discharge — Section I Waters:
The discharge of an oily mixture from machinery spaces is authorized from any ship in Section I waters if
(c) the discharge is processed through oil filtering equipment that
(i) produces an undiluted effluent that has an oil content of no more than 15 ppm, and
(ii) triggers an alarm and a discharge-stopping device as soon as the oil content in the effluent exceeds
(A) 5 ppm, where discharged in inland waters of Canada, or
(B) 15 ppm, where discharged in fishing zone 1,2 or 3 or in those internal waters of Canada that do not include inland waters of
Canada; (end of citation)

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Oily Bilgewater Separators	Section 2 - Regulation of Oil in Bilgewater Discharge
including verification of bilgewater treatment systems meeting a 5 ppm discharge standard. The
verification service is approved by the Clean Shipping Project, the organization that developed
the Clean Shipping Index. More than 1,000 ships have been entered into their Clean Shipping
Index database. The Index is a tool that takes into account significant environmental impacts of
shipping, such as emissions to air and water, use of chemicals, effects of antifouling, etc. The
index is used to identify ships or shipping companies in a database according to the aspects that
are most relevant to the user.

       Det Norske Veritas (DNV) of Norway requires bilge separators to be equipped with a 5
ppm bilge alarm to fulfill the DNV Guidance for Clean Design (DNV, 2005). These are a set of
rules that state requirements for design of equipment reducing the environmental impact from
emissions to air, discharges to sea, and deliveries to shore from ships. The requirements are in
compliance with or more extensive than those found in international standards currently in force.
The rules aim at attaining a ship with controlled environmental standards of design and
performance. Compliance with the rules is verified through inspection, measurements and
sampling of defined environmental parameters in accordance with the requirements of the rules
and in compliance with identified standards and guidelines. The class notation Clean Design
identifies additional requirements for controlling and limiting operational emissions and
discharges. In addition, this notation specifies design requirements for protection against
accidents and for limiting their consequences.

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Oily Bilgewater Separators	Section 3 - Treatment Technologies and components of Bilgewater Separators


                                                                         SECTION 3
          TREATMENT  TECHNOLOGIES AND COMPONENTS OF
	BILGEWATER SEPARATORS

3.1    GRAVITY OIL WATER SEPARATORS

       Traditionally, many ocean-going ships have used gravity OWS separation devices to treat
oily bilgewater. Gravity OWS use parallel plate or filter coalescing technologies to separate oil
from water by using the different specific gravities of the two liquids and their immiscibility with
each other. Bilgewater is commonly heated to approximately 120° F (or higher) prior to OWS
treatment because this improves the separation of oil. The OWS contains a coalescing material,
which is typically polypropylene, an oleophilic polymer, that may be in the form of parallel
plates or loose packed media. Free and dispersed oil droplets in the bilgewater adhere to the
coalescing material as it passes through the OWS. These droplets continue to coalesce and then
break free from the plates or media and rise to the surface of the OWS tank. The OWS contains
sensors that detect the presence of oil and trigger the OWS to automatically pump the collected
oil to a waste oil tank.

       Gravity OWS can be effective when discrete phases of oil and water are present (Koss,
1996). Studies conducted in the 1970s and early 1980s by the U.S. Navy and others
demonstrated that conventional parallel plate gravity OWS could reduce effluent oil
concentrations to 20-100 ppm, if care was taken not to mechanically emulsify the oil in the bilge
(Noyes, 1993). However, the mixture of fluids accumulating in a vessel bilge can be difficult to
separate and often  contain emulsified oil (i.e., oil droplets smaller than 20 jim).  These emulsions
are created through the presence of chemical emulsifiers such as cleaning agents and solvents,
and by mechanical means such as transfer system pumps and the vessel's motion at sea. Gravity
OWS is not intended to separate emulsified oils from water. When emulsification occurs,
buoyancy differences  are too small to be exploited in conventional gravity OWS technology. If
the suspended particles or droplets have effectively neutral buoyancy, gravity OWS ceases to be
effective. Additionally gravity OWS's are ineffective in removing  colloidal metals  and soluble
compounds. Some other bilge contaminants, notably aqueous film-forming foam (AFFF) fire-
fighting agents, have also been singled out as adversely affecting gravity OWS performance
(Koss, 1996). Newer ships also typically have drier bilges, which reduces dilution and results in
higher concentrations of oil, detergent and chemical wastes in the bilgewater.

       For the reasons cited above, gravity OWS separation devices typically cannot meet the 15
ppm standard for treatment of oily bilgewater. Performance tests of parallel plate and coalescing
bead gravity OWS onboard Military Sealift Command (MSC) ships have shown bilgewater
effluent oil concentrations frequently exceeding 15 ppm (Caplan et al., 2000). For example, ERG
documented an average gravity OWS effluent oil concentration of 42 ppm based on sampling of
five Navy vessels (ERG, 2004)7. Maritime organizations in the U.S. and other nations have
encountered similar problems with the efficiency, reliability and maintenance of gravity OWS
equipment. These organizations are often forced to spend large amounts of money to off-load
oil-contaminated water to shore-based facilities for fear of a spill violation. In some cases,
7 The OCMs/bilge alarms on these vessels were set to prevent discharge of bilgewater effluents with oil contents
exceeding 15 ppm.

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Oily Bilgewater Separators	Section 3 - Treatment Technologies and components of Bilgewater Separators
discharges of oil-contaminated water has occurred, leading to environmental damage and, in
some cases, legal action against crew members, the vessel's operating company, and owners
(Penny and Suominen-Yeh, 2006).

3.2    CENTRIFUGAL SEPARATORS

       A number of certified bilge separators use centrifuges instead of gravity OWS, also with
one or more additional polishing unit operations. Centrifugal separators, like gravity OWS,
employ the difference in density between oil and water and coalescence of oil droplets to
separate oil from bilgewater. However, they do so by greatly multiplying gravity using
centrifugal acceleration. In addition, high centrifugal force can mechanically induce flocculation
and coagulation to separate emulsified oil.  Centrifuges are demonstrated for treatment onboard
vessels, having been used for decades for heavy fuel and lube oil cleaning (see Attachment A).
They have also been demonstrated to be an efficient and reliable method for separating oil from
bilgewater. Compared to conventional gravity OWS, centrifugal separators are compact and
highly efficient, do not require large bilgewater holding tanks and generate minimal waste
volume. They run continuously without significant man-hours for operation and supervision and
handle varying bilgewater composition, solids loading and oil content, as well as the rolling and
pitching motion of the ship. Because they are more efficient than gravity OWS, centrifuges
reduce the loading of oil to subsequent (polishing) treatment stages, thereby potentially
lengthening the service life of the polisher. Centrifuges use large horsepower motors that require
regular maintenance. The initial capital outlay for centrifuges is relatively high. Although more
effective than a gravity OWS, the effluent from a centrifuge may still require further treatment to
meet discharge limits lower than 15 ppm under all conditions.

3.3    POLISHING TREATMENT FOR BILGE SEPARATORS

       Due to the difficulty in removing oil from bilgewater by gravity OWS alone, additional
treatment stages (unit operations) are added to bilge separators in order to sufficiently clean and
"polish" bilgewater to comply with current and anticipated vessel discharge standards (Sun  et al.,
2009; Caplan et al., 2000). In addition to providing greater overall reduction in bilge oil
concentrations, the addition of treatment stages makes bilge separators more reliable by
providing some redundancy to withstand problems or failure of individual stages. Including one
or more polishing steps is an added cost to the operation of a ship; however, onboard bilge
separation is typically more economical than holding all oily bilgewater for transfer and
subsequent treatment on shore (Ghidossi et al., 2009).

       More than one hundred bilge separators have been certified by the U.S. Coast Guard to
meet the  MARPOL 15 ppm oil discharge standard.8 All of these bilge separators are treatment
systems that combine a gravity OWS (or centrifuge, as noted below) with one or more additional
unit  operations that polish the bilgewater effluent.  Most certified bilge separators combine
several post-gravity OWS/centrifuge unit operations such as:

       •   Absorption and Adsorption
       •   Biological Treatment
 124 records were returned from a search of "Oil pollution prevention equipment - 162.050" on the US Coast
Guard's Maritime Information Exchange (http://cgmix.uscg.mil/Equipment/EquipmentSearch.aspx, updated
Tuesday, August 10, 2010)

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Oily Bilgewater Separators	Section 3 - Treatment Technologies and components of Bilgewater Separators


       •  Coagulation and Flocculation
       •  Flotation
       •  Membrane Technologies (ultrafiltration)

       Descriptions of these unit operations are provided below. These technologies can all be
considered post-OWS polishers, as gravity OWS (or centrifuge) treatment is a typical first step
for bulk removal of non-aqueous phase components. Although this document focuses on the
capabilities and performance of these unit operations to remove oil, these technologies are also
capable of removing other pollutants (e.g., suspended solids, metals, organic chemicals) from
bilgewater. For example, Tomaszewska et al. (2005) found that ultrafiltration was effective in
removing turbidity and suspended solids, organic carbon, and several trace metals (Al, Fe and
Zn) from bilgewater, in addition to oil. According to a manufacturer, unit operations are
optimized for removal of oil when used in bilge separators, which  may reduce their effectiveness
in treating other pollutants (see Attachment B).

3.3.1   Absorption and Adsorption

       Absorption and adsorption are both physicochemical sorption processes that can be used
to separate oil from bilgewater. Absorption is the incorporation of  a substance from one physical
state into another physical state (e.g., a liquid absorbed by a solid). Adsorption is the physical
adherence or bonding of molecules onto the  surface of another phase (e.g., reagents adsorbed
from water only a solid surface). For both processes, bilgewater is  pumped through the sorption
media in a reactor vessel or contactor, and the oil  is removed from the media. Once the capacity
of the sorption media is exhausted, the reactor or contactor is removed from service, and the
media is replaced. For all sorption processes, the spent media is an oily solid waste residual.
Certain spent media can be regenerated aboard ship while others may be regenerated or disposed
of on shore.

       Oil can be absorbed from bilgewater using granular substrates and absorbents or cartridge
filters with surfaces modified to have a high affinity for emulsified droplets (Alper, 2003). Two
such modified surfaces used to absorb emulsified oil are organoclay and curable polymeric
surfactant (PS). Organoclay is widely used to absorb oil from water. When bentonite or other
clays and zeolites are organically modified with quaternary amines, they become organophilic
(Alther, 1995). This property of the surface of modified clays enables them to remove oil and
other organic compounds of low polarity.  When organoclays are placed into water containing
mechanically emulsified oil, greases and large chlorinated hydrocarbons, the organophilic clay
will remove  these compounds by a partitioning process. Therefore, organoclay can be used to
remove emulsified oil and grease and other sparingly soluble organics. Disposal options for spent
media are cement kilns, landfills, bioremediation through land farming, cement encapsulation or
incineration. Based on personal communication with the manufacturer, the usage rate for
organoclay is typically about 10 kg/100 m3 of oily bilgewater treated (see Attachment B).

       Curable PS is an oleophilic compound that is infused in standard filter materials such as
polypropylene fabric. Once cured, the properties of PS are transferred into the substrate, thereby
greatly enhancing its ability to attach organic compounds to the filter substrate (Alper, 2003). PS
technology works by chemically immobilizing the pollutants into the filter matrix.  According to
personal communication with the manufacturer, usage rates for PS absorbers are based on
replacement of the filters 3-4 times per year  (see Attachment B). PS absorbers have affinity for

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Oily Bilgewater Separators	Section 3 - Treatment Technologies and components of Bilgewater Separators
organic compounds and do not develop additional differential pressure in the presence of very
thick oils or under high loading conditions. This property enables PS to capture concentrated
slugs of oil without clogging, making them useful as pre-filters for more sensitive and therefore
easily fouled filtration methods.

       A number of bilge separator treatment systems use adsorption. Granular activated carbon
(GAC) is the most popular adsorption media and can effectively remove dissolved oil and
hydrophobic organic chemicals from water. Initial capital costs for GAC adsorbers are relatively
low. However, based on personal communication with a manufacturer, activated carbon has a
low capacity for emulsified oil (5-7 times less than organoclay; Alther, 1995) and becomes
saturated once it adsorbs 10-20% oil by weight (see Attachment B). GAC is vulnerable to high
suspended solids and oil loading; these can foul or bind the adsorber and require frequent
backwashing or media replacement.9 In this situation, the capacity of the activated carbon is
significantly reduced, requiring frequent replacement of the sorbent media at greatly increased
cost and liability of solid waste generation.

       Based on personal contact with a manufacturer,  sorption processes are well suited for
smaller (<400 GT) vessels because they are relatively compact, have relatively low capital cost
and cost of operation for treating modest volumes of bilgewater, and require relatively low
maintenance other than media replacement (see Attachment B). Replacement is straight forward
if the sorbent media is configured as modular cartridges, similar to under-sink water treatment
devices.

3.3.2  Biological Treatment

       Biological treatment employs microorganisms to convert the substrate (oil and other
organic compounds) to carbon dioxide, cell components, and products typical of the usual
catabolic pathways. The microorganisms are grown as a film attached to a synthetic support
media in a bioreactor (see Attachment A). Oil and related contaminants are degraded in this bio-
layer as the bacteria oxidize the hydrocarbons. Aerators, located beneath the media, provide the
oxygen required to support bacterial growth and oxidation of the targeted organic contaminants.
Nutrient addition and pH adjustment of bilgewater is also usually necessary. Biological treatment
of oily bilgewater typically consists of an OWS, the bioreactor, and a final clarifier, which
removes microorganisms (biomass).

       Biological treatment can degrade organic pollutants (i.e., bilge oil) to low concentrations,
even in the presence of detergents and other bilge contaminants. Emulsified oil, which can be
difficult to treat by physical/chemical treatment processes, is readily degraded by
microorganisms in biological treatment since small oil droplets are processed quickly (Caplan et
al. 2000). Furthermore, biological treatment is effective at removing other organic pollutants that
may be of concern such as glycols, solvents, jet fuel, surfactants, detergents, nitrogen and
phosphates. Biological treatment produces essentially no waste oil, which can be a significant
advantage of this technology. Biological treatment is also mechanically simple and functions
well under conditions of moderate throughput with controlled loading.  Loading spikes can
overwhelm and upset biological units, and the microorganisms upon which they rely are
9 Activated carbon is a porous material with adsorption of organic molecules occurring within micropores. Oil
droplets larger than the micropore diameter (10-1,000 angstroms) may cover the pore, thereby preventing any
further adsorption.
                                            10

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Oily Bilgewater Separators	Section 3 - Treatment Technologies and components of Bilgewater Separators
sensitive to temperature, pH and nutrient concentrations (Alper, 2003). Capital costs are
relatively high, although operating costs are relatively low. The degree of operator skill
necessary for the proper function of biological treatment may be higher than that required for
other polishing processes.

3.3.3  Coagulation and Flocculation

       Coagulation and flocculation are associated processes used to aggregate particles too
small for gravitational settling into larger, more readily settlable aggregates. In the case of oil
(especially emulsified oil), the separation of the aggregated particles may also be accomplished
by flotation. In oily bilgewater treatment, coagulation and flocculation are often referred to as
"emulsion breaking". Following the separation of free oil in an OWS, the remaining emulsified
bilgewater is directed to a circulation tank where a flocculent chemical and, in the case of
flotation, air are added to the water. Tank mixing is provided by a circulation pump or
mechanical stirrers. The aggregation of colloidal particles involves two separate and distinct
steps (Weber,  1972): particle transport to effect interparticle contact and particle destabilization
to permit attachment when contact occurs. The aggregated flocks that form with the oil are then
skimmed off, and the remaining water may undergo through a number of filtering steps.
Flocculation can also be used in conjunction with high performance gravity separation devices
(generally a centrifuge).

       Coagulation and flocculation is effective if properly applied, although it can suffer from
several shortcomings (Cheryan  and Rajagopalan, 1998). These include:

       •  High susceptibility to changes in influent quality,
       •  Optimization aboard each vessel to determine the type and quantity of chemicals
          required,  and
       •  Skilled operators and careful control (or sophisticated automation) to optimize
          performance.

       Chemical addition is a daily or hourly process and a significant operating cost.
Coagulation and flocculation can generate considerable quantities of sludge requiring disposal.
According to manufacturers, as  much as 5 to 25% of the volume of oily water treated by
flocculation chemicals can become residual waste for onshore disposal (Zhu et al.,  1997;
Attachment  B).

3.3.4  Flotation

       Air or gas flotation can be used to enhance gravity separation. Flotation uses the
differential density between the air or gas bubbles to which the oil droplets and small solid
particles become attached and the water to effect separation. Since the agglomerates have a
lower density than the medium in which they  are immersed, they rise to the surface where they
are removed by skimming.

       Flotation has been used to treat oil-bearing effluents from a wide variety of sources,
including bilge and ballast waste aboard vessels (Bennett and Peters, 1988). There are different
types of flotation systems classified based on their method of bubble formation. Dissolved air
flotation (DAF), for example, relies upon gas  released from a supersaturated solution as a result
of pressure reduction. As mentioned above, the flotation step is often augmented by the addition
                                            n

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Oily Bilgewater Separators
Section 3 - Treatment Technologies and components of Bilgewater Separators
of flocculating agent and may be followed by additional gravity separation as a safety precaution
(Lysyj and Russell,  1979).

3.3.5   Membrane Technologies (Ultrafiltration)

       Membrane technologies, in essence molecular sieves, have been used to produce purified
water in numerous municipal and industrial applications. Membrane processes have been found
to be an effective method for the treatment of oily effluents due to high efficiency in
hydrocarbon removal, relatively low energy requirements, no chemical addition and relatively
low space requirement (Cheryan and Rajagopalan, 1998). Membrane operations typically fall
into three categories: ultrafiltration (UF), nanofiltration (NF) and reverse osmosis (RO) with the
following particle size and molecular weight (MW) ranges resented in Table 1.

          Table 1: Reverse Osmosis Particle Size and Molecular Weight Ranges
Membrane
Technology
Ultrafiltration
Nanofiltration
Reverse
Osmosis
Particle Size Cutoff
0.01 to 0.1 urn
0.001 to 0.008 urn
( 10 to 80 angstroms)
0.0005 to 0.0015 urn
(5 to 15 angstroms)
Molecular Weight
(MW) Ranges
1,000 - 100,000
200 - 10,000
100 - 300
Components
Retained
most organics over
1000 MW
95% divalent ions,
40% monovalent
ions, organics
greater than 150-300
MW
99% of most ions,
most organics over
150 MW
        Source: (Cheryan and Rajagopalan, 1998)

       Membrane processes have gained wide acceptance because they consistently produce
effluents of acceptable discharge quality, and they are perceived to be a simple process from an
operational viewpoint (Cheryan and Rajagopalan, 1998). Membranes act as positive barriers to
rejected components, so the quality of the treated water tends to be uniform regardless of influent
variations. These variations may decrease the permeate flux, but generally do not affect quality
of its output.

       Ultrafiltration (UF) has been the primary membrane technology used for post OWS
bilgewater polishing. UF devices separate high molecular weight constituents and solids from
fluids by forcing the fluid through the very small pores of a polymeric or inorganic membrane.
UF membranes allow the passage of water, ions, or small molecules, but prohibit the passage of
oil and other larger molecules10. UF operates at relatively low pressure (0.7-7 bar) because the
osmotic pressure exerted by the high molecular weight solutes is negligible, and the membranes
are designed to separate such solutes (Bodzek and Konieczny, 1992; Karakulski et al., 1995).
Membrane  systems produce two output streams: the permeate, which is the treated water, and the
concentrate, which may contain up to 50% oil. The concentrate is typically recycled back to the
bilgewater holding tank. As the oil recovered with the concentrate is usually de-emulsified, it can
be readily separated by the OWS upon its subsequent pass through the treatment system. Based
  Based on personal communication with Coffin World Water Systems, Oil typically occurs as macromolecules in
water, not as discrete molecules (see Attachment B).
                                           12

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Oily Bilgewater Separators	Section 3 - Treatment Technologies and components of Bilgewater Separators
on personal communication with a manufacturer, experience has shown that bilge separators
incorporating UF generate waste oil at a rate of less than 15% of the treated bilgewater flow rate
(see Attachment B).

       The treatment of bilgewater by UF has been demonstrated to substantially reduce the
content of oil to less than 5 ppm (Gryta et al., 2001). Ceramic module UF systems have been
tested and used on U.S. Navy ships for treatment of oily bilgewater with generally good results.
The systems are able to reduce oil concentrations from approximately 232 ppm to less than 5
ppm at flows of about 1 m3/hr.

       The Discharge Assessment Report (DAR) prepared by the U.S. Department of the Navy's
Naval Sea Systems Command and the EPA's Office of Water (Navy and EPA, 2003) included
technical analyses of surface vessel bilgewater discharges. The DAR concluded that membrane
filtration passes as a Marine Pollution Control Device (MPCD) option for treating bilgewater,
and that membrane filtration is successfully used onboard Armed Forces surface vessels to treat
bilgewater. In the companion Characterization Analysis Report (ChAR) (Navy and EPA, 2002),
the Navy conducted an evaluation of a membrane filtration system to determine its ability to
consistently produce an effluent that would  conform to local and worldwide environmental
standards regardless of influent concentrations. The test results indicated that membrane
filtration is capable of conforming to these standards while operating over a wide  range of pH
and is resistant to chemical attack. High concentrations of inorganic and organic compounds led
to reduced membrane performance;  however, most membranes recovered significantly when
flushed with water for 15 minutes.

       The effectiveness of several bilge  separators with UF polishers installed in U.S.  Naval
vessels was studied in 1999 and 2000 (ERG, 2004). These were real-world tests conducted
onboard vessels, with bilge separators treating actual (not synthetic) bilgewater. The oil
concentrations in untreated and treated bilgewater were measured using approved analytical
methods, and the data were fully quality assured. The UF-polished effluent oil concentrations
were almost always less than or equal to the SGT-HEM 5 ppm detection limit. The average
OWS/UF effluent oil concentration was 5.5  ppm SGT-HEM u when the OCM set point was 15
ppm. The OWS/UF systems had a much higher percent removal of oil (80%) than the bilge
separators with only gravity OWS (9%).

       The inherent tendency of membranes to catch all but the smallest particle sizes renders
them susceptible to the accumulation of fouling by organic, inorganic and biological materials on
the membrane surface, referred to as membrane fouling. Fouling causes the permeate flux in UF
to decrease over time. Because of fouling, UF processes must be stopped regularly for membrane
cleaning to restore membrane permeability (Lee et al., 2002). Membrane cleaning, as well as
other measures for fouling control, increases cost and complexity of the processes significantly
and makes membrane processes less competitive in many application (Lee et al., 2002).

       The advantages of treatment using membrane technologies are consistently high
efficiency of the separation, a low rate of residual waste oil generation, and reasonably low
operating cost (Gryta et al., 2001). Disadvantages of UF include high capital and maintenance
costs, if fouling becomes a recurring problem. According to personal communication with a
nNon-detect oil concentrations were set equal to the detection limit for this analysis.

                                           13

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Oily Bilgewater Separators
Section 3 - Treatment Technologies and components of Bilgewater Separators
manufacturer and as described in system documentation, membranes must be replaced when
fouled, approximately every 3 to 5 years (see Attachments A and B).

3.4    RESIDUAL GENERATION

       All bilge separator treatment systems generate oily residuals and sludge. At a minimum,
the effective treatment of 1,000 gallons of bilgewater containing 500 ppm of oil will generate 0.5
gallons of oily waste. Actual residual generation varies based on the characteristics of the
bilgewater and the specific treatment technologies used in the bilge separator. Residuals
generated by treatment technology are summarized in Table 4.

               Table 2: Residuals Generated From Treatment Technologies
Treatment Technology
OWS gravity separator
Centrifugal separator
Organoclay absoption
GAC adsorption
Biological treatment
Coagulation and flocculation
Flotation
Ultrafiltration
Residual Generated
Oily (free) waste and sludge
Oily (free & emulsified) waste and sludge
Oily solid waste (spent clay)
Oily solid waste (spent GAC)
Sludge and biosolids
Oily sludge
Oily sludge
Oily (free & emulsified) waste
3.5    OIL CONTENT MONITOR

       All vessels over 400 GT are required to have an oil content monitor (OCM), including a
bilge alarm, integrated into the piping system to detect whether the treated bilgewater that is
being discharged from the bilge separator meets the discharge requirements. Standards for type
approval of OCMs are defined under 46 CFR 162.050 and MARPOL 73/78 Annex I (see Section
2). When the oil content in the effluent is detected to exceed these limits, an alarm and discharge
stopping device (typically a valve that diverts the noncompliant effluent back to the bilge
separator to be reprocessed) is activated. Given that the OCM plays a primary role in the
operation of the bilge separator treatment system, and is usually the only means of preventing the
discharge of oil from vessels in the case of failure of the bilge separator, the accuracy and
reliability of the OCM is an important consideration in the overall evaluation of the effectiveness
of bilge separators.

       The mixture of fluids accumulating in a vessel bilge can be difficult to monitor, even with
the best OCM equipment (EPA, 2008). OCMs measure the oil content in the effluent by
increasing the turbidity of a sample using ultrasonic emulsification. The turbidity increase of the
sample is proportional to the oil concentration, which is electronically converted to ppm.
However, bilge contaminants other than oil that contribute turbidity (e.g., suspended solids, soot)
can interfere with these measurements. Unfortunately, this means that most OCMs  are unable to
differentiate between oil and other bilgewater contaminants. Automated measurement of oil
concentrations as low  as 5-15 ppm is difficult due to the variation of oil constituents, other
contaminants and emulsifying detergents (EPA, 2008).
                                           14

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Oily Bilgewater Separators	Section 3 - Treatment Technologies and components of Bilgewater Separators
       OCMs require continuous maintenance and cleaning to avoid malfunctions and erroneous
readings due to interferences with the turbidity they monitor. For example, personal
communication with a manufacturer indicated that more than half of the OCM readings above 5
ppm aboard one Great Lakes shipping company's vessels were suspected to be erroneous (see
Attachment B). This is problematic because (1) it causes the bilge separators to recirculate
instead of discharging clean effluent and (2) these readings are recorded and saved for 18 months
for regulatory review. The accuracy of the OCMs this company uses aboard their vessels is
reportedly ± 5 ppm, hence the OCM readings in this concentration range are questionable.

       ERG (2004) assessed available data published by the U.S. Navy to determine whether
bilge separators with OCMs set at 15 ppm actually achieve effluent oil concentrations below 15
ppm SGT-HEM. ERG analyzed  125 OCM readings and the corresponding actual effluent oil
concentrations and found no correlation (coefficient of determination, r =0.0012) between them.
In other words, the OCM readings bore no relationship to the SGT-HEM concentrations they
were supposed to monitor. A more detailed evaluation of shipboard  sampling of bilgewater on
seven Navy vessels during eight sampling episodes (i.e., one vessel was sampled twice) was also
presented. In several cases on  one Navy vessel, the OCM reading following the OWS was zero
while the SGT-HEM effluent concentration was in the 15 to 50 ppm range. At least two of the
Navy vessels that were sampled  possibly discharged bilgewater overboard that had SGT-HEM
concentrations greater than 15 ppm, due to inaccuracy in the OCM readings. Inaccurate and
unreliable OCMs make it more likely that oil will be inadvertently discharged overboard.

       Some newer OCMs overcome these problems by using UV fluorescence technology to
detect oil molecules in bilgewater. Oil is comprised of fluorescent compounds, each having a
unique wavelength "signature". Using fluorescence, these compounds can be detected as an
actual concentration of oil in water, with detection limits down to the parts per billion level.
Fluorescence OCMs are  resistant to interferences by turbidity or particles/sediments in the bilge,
which affects turbidity-based OCMs (particles  such as silt, algae, iron oxide do not fluoresce at
oil's wavelength, they do not interfere with the measurement of oil concentration) (see
Attachment A). Several fluorescence OCMs have been EVIO MEPC  107(49) certified and type-
approved by the U.S. Coast Guard for use as a  15 ppm bilge monitor/bilge alarm. However,
personal communication with  a manufacturer indicates that such OCMs are as much  as 10 times
more expensive than the OCMs commonly installed aboard vessels (see Attachment B).

3.6    SPACE REQUIREMENT s

       The space required for bilge separator treatment systems is another concern for vessel
operators because mechanical  space aboard ship (existing  or new vessels) is at a premium. EPA
calculated the "footprint" required for a variety of bilge separator treatment systems,  based upon
the dimensions provided by manufacturers for  skid-mounted systems sized for a 1 m3/hr
capacity. The results, compared in the bar graph below, show that bilge separator treatment
systems of this capacity have footprints ranging from 0.6 to 3.4 m2, a range of a factor of six.
The largest bilge separators are the bioreactor-based system, a centrifuge system, one of the
flotation/coagulation & flocculation-based systems, and one of the UF-based systems.
Interestingly, the two OWS/UF systems have quite different footprints,  0.86 and 2.42 m  . The
smallest bilge separators are both OWS-adsorber treatment systems; these systems are only
slightly larger than the older generation of single-stage gravity OWS (indicated in the figure
below as OWS*) that do not meet the MARPOL 15 ppm oil discharge standard. Most vendors

                                           15

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Oily Bilgewater Separators
Section 3 - Treatment Technologies and components of Bilgewater Separators
address the issue of retrofitting bilge separators into existing confined spaces by reconfiguring

their systems as separate components, as opposed treatment systems mounted on a single skid.
                Floor space footprints of modular 1 m3/hr bilge separators
                                 o*     •**
                                &     o*
       Figure 1: Footprint Required for Various Bilge Separator Treatment Systems
                                           16

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Oily Bilgewater Separators	Section 4 - Effectiveness of Bilge Separator Treatment Technologies


                                                                        SECTION 4
          EFFECTIVENESS OF BILGE SEPARATOR TREATMENT
	TECHNOLOGIES

       EPA evaluated the effectiveness of bilge separators based on their ability to achieve low
effluent oil concentrations. Ideally, this evaluation would be based on the analysis of oil
concentrations in samples of effluent collected from bilge separators treating actual bilgewater
onboard operating vessels. However, very few representative data of this sort are  available.
Instead, the effectiveness of bilge separators is usually demonstrated by the results of
certification tests, conducted by an independent laboratory, of effluent oil concentrations
achieved by bilge separators treating synthetic oily bilgewater. For a number of reasons
(discussed below) these tests may not accurately represent the actual effectiveness of bilge
separators in the real world. However, the certification test data demonstrate that  different bilge
separators can achieve less than 15 ppm effluent oil concentrations under controlled conditions.

       Paradoxically, there is also considerable anecdotal evidence that some bilge separators
have difficulty meeting the 15 ppm MARPOL discharge standard onboard vessels. For example,
the Association Francaise des  Capitaines  de Navires (AFCAN, 2006) reported that bilge
separators brought into service in 2005 had "difficulties" treating bilgewater to reduce
hydrocarbon contents below 200 ppm. Presumably, these bilge separators were type-certified to
meet the current MARPOL regulations. Other problems with the performance of bilge separators
aboard ships have been reported by marine engineers  (MarineTalk discussion forum, accessed
July 20, 2010). Further evidence is provided by the ongoing prosecution in the U.S. of vessel
masters and chief engineers for violating  the APPS by using "magic pipes" (i.e., circumventing
the required pollution prevention equipment and discharging oil sludge and oil  contaminated
waste directly overboard, generally due to failure of the bilge separator). However, some of the
problems reported with the performance of bilge separators may reflect experience with older
(pre MARPOL 73/78) treatment systems, which were often single-stage OWS.

       Vendors  of bilge separators often  promote their own treatment systems  as superior to
other systems, for a variety of reasons (e.g., performance,  reliability and cost). Such opinions
may reflect marketing or actual experience, but are rarely  confirmed by independent, verifiable
data. Thus, it is difficult  to use such anecdotal information objectively regarding the pros and
cons of different bilge separator treatment systems. Given that a number of different bilge
separator treatment systems have been demonstrated to perform effectively via certification, it is
reasonable to conclude that no one system is necessarily "best". Rather, multiple bilge separator
treatment systems appear capable of meeting the 15 ppm standard and possibly the 5 ppm
standards for effluent oil concentrations.

       Although EPA does not endorse specific bilge separators, system information and
performance data gathered for thirteen bilge separators are summarized below.  These bilge
separators are not necessarily representative of all of the systems on the market because: (1) it is
a small  sample size and (2) some of the vendors that responded declined to provide effectiveness
and/or cost data. Although not necessarily representative,  this summary illustrates that bilge
separator treatment systems using different treatment  technologies and combinations of unit
operations can achieve and exceed compliance with existing U.S. Coast Guard  certification
standards, and some may have the  potential to meet 5 ppm limits.

                                           17

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Oily Bilgewater Separators
Section 4 - Effectiveness of Bilge Separator Treatment Technologies
4.1    BILGE SEPARATOR TREATMENT SYSTEM A

       This bilge separator treatment system consists of an OWS, followed by a
strainer/prefilter, followed by a PS-infused spun polypropylene filter absorber. According to the
vendor, the polymer attracts and bonds hydrophobic and oleophilic compounds, including oil.
The vendor, which holds a patent for the absorbent polymer, also markets the filter as a polisher
for other OWS systems. Based on technical product sheets, the filters can be regenerated and the
recovered oil  can be rendered water-free using centrifugation. Alternatively, the spent filters can
be used for fuel or stored for later disposal (see Attachment A).

       The vendor provided their Lloyd's Register Certificate for testing of their  1.0 m3/hr and
2.5 m3/hr bilge treatment systems. For tests using MEPC 107(49) test fluid "C" emulsion,
influent oil concentrations of 50,000, 100,000 and 150,000 ppm hydrocarbon index were reduced
to  effluent concentrations of 0.14 to 0.48 ppm. The average effluent concentration from seven
tests was 0.26 ppm.

4.2    BILGE SEPARATOR TREATMENT SYSTEM B

       This bilge separator treatment system consists of an OWS, followed by a biological
reactor containing support media, followed by a clarifier/monitoring chamber. The biological
reactor is started up by filling with water and inoculating with hydrocarbon-degrading
microorganisms. According to the vendor, refined oils and other petroleum products found in
bilgewater may contain thousands of different hydrocarbons. To biodegrade these compounds,
microorganisms use numerous different enzymes to biochemically catalyze many reactions (e.g.,
oxidation, reduction, hydroxylation, ring cleavage). A "starter" bacterial culture in the form of a
dry powder is provided by the manufacturer for this initial inoculation (Penny and Suominen-
Yeh, 2006).

       Penny and Suominen-Yeh (2006) presented data (Table 2) on the performance of this
bilge separator treatment system onboard three commercial vessels (an ore carrying freighter,  a
ferry and a passenger/ferry) over a two year period. Note that effluent oil concentrations
tabulated below were measured using the OCM, as opposed to laboratory analytical data of
known quality.

 Table 3: Performance of Bilge Separator Treatment System on Three Commercial Vessels
Vessel



Freighter
Ferry
Passenger/ferry
Design
Flow
Rate
(m3/hr)
0.5
0.2
0.3
Average
Treatment
Flow Rate
(m3/hr)
0.3
0.07
0.1
Average
Effluent Oil
Concentration
(OCM ppm)
5.2
6.0
7.6
Range of
Effluent Oil
Concentration
(OCM ppm)
<1-14
<1 -14
<1 -20
Number
of
Samples

31
58
31
       Source: (Penny and Suominen-Yeh, 2006)

       Daily maintenance items for this biomechanical bilge separator treatment system include
nutrient addition and maintaining the pH level within the required range. Weekly and bi- weekly
maintenance includes nutrient analysis and removal of accumulated biomass and other settled
solids. This treatment system does not require filters, sorbent media or similar disposable
materials to remove oil from the liquid phase.
                                           18

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Oily Bilgewater Separators	Section 4 - Effectiveness of Bilge Separator Treatment Technologies


       The vendor provided their summation certificate for testing of their 0.45 m3/hr, 0.68
m3/hr and 0.86 m3/hr bilge treatment systems. For tests using MEPC 107(49) test fluid "C"
emulsion, influent oil concentrations of 6% (60,000 ppm) hydrocarbon oil index were reduced to
effluent concentrations of 1.3 to 1.8 ppm. The average effluent concentration from three tests
was 1.6 ppm.

4.3    BILGE SEPARATOR TREATMENT SYSTEM C

       This bilge separator treatment system consists of DAF/oil skimming, followed by
coagulation and flocculation, DAF/sludge skimming and activated carbon adsorption. This
treatment system is being used aboard roll-on/roll-off (RoRo) and roll-on/roll-off passenger
(RoPax) ferries.  The vendor provided their U.S. Coast Guard certificate of approval for testing
of their 0.55 m3/hr and 2.0 m3/hr bilge treatment systems by SGS Institut Fresenius GmbH of
Taunsstein, Germany. For tests using MEPC 107(49) test fluid "C" emulsion, influent oil
concentrations of 5.8-5.9% (58,000-59,000 ppm) hydrocarbon oil index were reduced to effluent
concentrations of less than 1 ppm.

       The vendor of this system also provided third party data for oil and hydrocarbon index
concentrations from samples of bilgewater effluent following system start up and after 2 years of
operation aboard vessels. In both cases, the effluent oil concentrations were below detection
(detection limits of 1.0 and 0.1 ppm). This bilge separator treatment system also has a 5 ppm
Type Approval Certificate from the French Bureau Veritas International Register.

4.4    BILGE SEPARATOR TREATMENT SYSTEM D

       This bilge separator treatment system consists of an OWS, followed by 100-|im prefilter
and polishing by UF. Ghidossi et al. (2009) present data on the performance of this bilge
separator treatment system during 6 month trials aboard two >20,000 GT ferries operating in the
Mediterranean. The system consisted of two 7 m2 300-kDa12 ceramic membranes treating 1
m3/hr, considered an average bilgewater flow rate for such vessels. The UF system was operated
at a volumetric concentration factor (VCF=feed Q/concentrate Q) of three. Membrane
permeability after regeneration every two days did not vary. The influent hydrocarbon (HC)
concentration of approximately 500 ppm was reduced to 100-200 ppm by the OWS. UF
permeate HC concentrations were less than 1 ppm. Tests performed using UF without OWS
pretreatment demonstrated that the strong reduction of HC content by the OWS was necessary
for effective treatment of oily bilgewater by this system. An episode of treating wastewater
contaminated by chimney soot also demonstrated the importance of effective pretreatment for
UF; the soot permanently blocked the membrane pores, requiring the replacement of the UF
membranes.

       The vendor provided their U.S. Coast Guard certificate of approval for testing of their
0.55 m3/hr and 2.0 m3/hr bilge treatment systems by Tei Testing Services. For tests using MEPC
107(49) test fluid "C" emulsion, influent oil concentrations of 6% (60,000 ppm) hydrocarbon oil
index were reduced to effluent concentrations of 1.5 to 2.5 ppm. The average effluent
concentration from six tests was 1.75 ppm.
12 Nominal molecular weight cutoff of approximately 300,000.
                                           19

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Oily Bilgewater Separators	Section 4 - Effectiveness of Bilge Separator Treatment Technologies
4.5    BILGE SEPARATOR TREATMENT SYSTEM E

       This bilge separator treatment system consists of a strainer and preheater, followed by a
high-speed centrifugal separator. To ensure a 5 ppm effluent oil concentration, the system
includes an organoclay absorber is added as a final polishing step. Since the oil content in the
effluent the centrifugal separator is less than 15 ppm, the corresponding oil loading to the
absorber is low, requiring only annual replacement of the organoclay. According to the
manufacturer, the largest market for the centrifugal separators is large oil tankers.  Centrifuges
treating bilgewater are used aboard large cruise ships.

       The vendor provided their U.S. Coast Guard certificate of approval for testing of an older
2 m3/hr centrifuge-based bilge separator treatment system. The tested system did not include an
organoclay polisher. For tests using MEPC 107(49) test fluid "C" emulsion, influent oil
concentrations of 6 and 6.1% (60,000-61,000 ppm) hydrocarbon oil index were reduced to
effluent concentrations of 8.4 to 11.0 ppm. The average effluent concentration from three tests,
conducted without the organoclay polisher, was 9.5 ppm. Testing of this system with the polisher
produced effluent oil concentrations in compliance with DNV Clean Design Rules 5  ppm
effluent limit.  Seaway Marine Transport, a Canadian shipper operating 24 freighters on the
Great Lakes, has installed centrifuge-based bilge  separators on their vessels. Based on personal
communication with a manufacturer (see Attachment B), the centrifuge-based separators
routinely produce 0-2 ppm effluent oil concentrations without tertiary (organoclay filter)
polishing.

4.6    BILGE SEPARATOR TREATMENT SYSTEM F

       This bilge separator treatment system consists of a hydrophobic high viscosity removal
system (a low turbulence OWS), an oleophilic filter that also coalesces emulsified oil, and an
adsorber using an advanced granular media (AGM). According to the manufacturer's
representative, the AGM is an organoclay material (see Attachment B).

       Maintenance of this system consists of periodic replacement of the oleophilic filter and
AGM. The second stage coalescer element is not degraded by oils but acts as a particle filter and
must be replaced when it becomes plugged by solids or sludge.  The third stage adsorber holds
100 kg of AGM. The rate at which these consumables must be replaced depends on both the
quantity (flow rate) and the quality (in terms of oil and suspended solids loading) of the
bilgewater being treated.

       The vendor provided their U.S. Coast Guard certificate of approval for testing of their 1.0
m3/hr bilge treatment system by Institute Fresenius of Taunusstein, Germany.  For tests using
MEPC 107(49) test fluid "C" emulsion, influent oil concentrations of 6% (60,000 ppm)
hydrocarbon oil index were reduced to effluent concentrations below the 1 ppm  detection limit.
The average effluent concentration from three tests was <1 ppm.

4.7    BILGE SEPARATOR TREATMENT SYSTEM G

       This bilge separator treatment system consists of a "descaler" hydrocyclone OWS, a
reactor combining coagulation, flocculation and flotation, an Aqualite (volcanic rock) granular
media filter, and activated carbon polishing as a final stage. The second stage reactor, which is
responsible for separating emulsified oil (i.e., emulsion breaking), is optimized for minimal

                                           20

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Oily Bilgewater Separators	Section 4 - Effectiveness of Bilge Separator Treatment Technologies
residual sludge generation, and automated to reduce the time required for operation and
maintenance (O&M). According to the manufacturer, steam regeneration is used to extend the
life of the Aqualite and activated carbon media, allowing for annual replacement (see
Attachment B).

       The vendor's U.S. representative provided their U.S. Coast Guard Certificate of Approval
for testing of their 1 and 4 m /hr bilge treatment systems by Institut Fresenius AG of
Taunusstein, Germany. For tests using MEPC  107(49) test fluid "C" emulsion, influent oil
concentrations of 8% (80,000 ppm) hydrocarbon oil index were reduced to effluent
concentrations below the 1 ppm detection limit.

       The manufacturer also provided performance data for this bilge separator treatment
system onboard a car ferry over a one year period. This system treated an average daily
bilgewater flow of 5.3 m3/day, achieving monthly average effluent oil concentrations of 0.7 to
2.2 ppm. These  concentrations were measured using the  OCM, as opposed to laboratory
analytical data of known quality.

4.8    BILGE SEPARATOR TREATMENT SYSTEM H

       This bilge treatment system uses a modular design consisting of a feed pump, automatic
filter, preheater, self-discharging separator, oil monitor and control panel.

       Type-approval testing using MEPC 107(49) test fluid "C" emulsion with an influent oil
content of 6% (60,000 ppm) yielded effluent oil content concentrations ranging between 6 and
10 ppm for the 1.5 to 3 m3/hr treatment units.  Type-approval testing of the treatment systems as
large as 7 m3/hr yielded a consistent 5 ppm effluent oil concentration when MEPC 107(49) test
fluid "C" emulsion was used.

4.9    BILGE SEPARATOR TREATMENT SYSTEM I

       EPA was unable to identify the treatment technologies that comprise this system. The
vendor provided their Lloyd's Register Certificate for testing of their 4.0 m3/hr bilge treatment
system. For tests using MEPC 107(49) test fluid "A" having oil concentrations as high as
250,000 ppm, the system yielded effluent oil concentrations ranging from less than 0.1 ppm to
0.26 ppm measured by the hydrocarbon oil index method.  For tests using MEPC 107(49) test
fluid "C" with an influent oil  concentration of 60,000 ppm, the bilge treatment system produced
an effluent having oil concentrations ranging from 0.1  ppm to  0.42 ppm measured by the
hydrocarbon oil index method.

4.10   BILGE SEPARATOR TREATMENT SYSTEM J

       EPA was unable to identify the treatment technologies that comprise this system. The
vendor provided their Lloyd's Register Certificate for testing of their 6.0 m3/hr bilge treatment
system. For tests using MEPC 107(49) test fluid "A" having oil concentrations as high as
250,000 ppm, the system yielded effluent oil concentrations ranging from less than 0.1 ppm to
1.14 ppm measured by the hydrocarbon oil index method.  For tests using MEPC 107(49) test
fluid "C" with an influent oil  concentration of 60,000 ppm, the bilge treatment system was able
to produce an effluent having oil concentrations ranging from  3.4 ppm to 4.7 ppm measured by
the hydrocarbon oil index method.

                                          21

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Oily Bilgewater Separators	Section 4 - Effectiveness of Bilge Separator Treatment Technologies
4.11   BILGE SEPARATOR TREATMENT SYSTEM K

       This bilgewater treatment system consists of an oil filter.  The vendor provided their
SEE-Berufsgenossenschaft Certificate of Type Approval, issued in Hamburg, Germany, for
testing of their 1.0 m3/hr bilge treatment system.  For tests using MEPC 107(49) test fluid "A"
having oil concentrations as high as 250,000 ppm, the system yielded effluent oil concentrations
of 0.1 ppm or less measured by the hydrocarbon oil index method. For tests using MEPC
107(49) test fluid "C" with an influent oil concentration of 60,000 ppm, the bilge treatment
system was able to produce an effluent having oil concentrations consistently less than 0.1 ppm
measured by the hydrocarbon oil index method.

4.12   BILGE SEPARATOR TREATMENT SYSTEM L

       This bilgewater treatment system consists of an oil absorption filter.  The vendor
provided their Lloyd's Register Certificate for testing of their 2.5 m3/hr bilge treatment system.
According to the Certificate of Type Approval, the system is designed to produce an effluent of 5
ppm of oil or less when the influent oil concentration is less than 100 ppm.

       For testing using MEPC  107(49) test fluid "A" having an oil content ranging between
0.47 ppm and 127 ppm, the system yielded effluent oil concentrations ranging from 0.51 to 1.52
ppm.  For tests using MEPC 107(49) test fluid "C" with an influent oil content ranging between
0.08 ppm and 210 ppm, the bilge treatment system was able to produce an effluent having an oil
content ranging from 0.72 ppm to 1.6 ppm.

4.13   BILGE SEPARATOR TREATMENT SYSTEM M

       EPA was unable to identify the treatment technologies that comprise this system. The
vendor provided their Lloyd's Register Certificate for testing of their 4 m3/hr bilge treatment
system. For testing using MEPC 107(49) test fluid "A" having an oil content as high as 250,000
ppm, the system yielded effluent oil  concentrations ranging from less than 0.1 to 0.38 ppm
measured using the hydrocarbon oil index method. For tests using MEPC 107(49) test fluid "C"
with an influent oil concentration of 60,000 ppm, the bilge treatment system was able to produce
an effluent having an oil content ranging from 0.4 ppm to 1.1 ppm measured using the
hydrocarbon oil index method.

4.14   SUMMARY OF BILGE SEPARATOR EFFECTIVENESS

       Table 3 summarizes effluent oil  concentrations measured for these bilge separator
treatment systems. (The complete set of vendor submitted performance data can be found in
Attachment C.) The data presented focus primarily on type certification data for bilgewater
treatment systems that were tested using MEPC 107(49) test fluid "C" since this fluid is likely
the most challenging for the treatment unit and is most similar to actual oily bilgewater. For
example, test fluid "C" is an oil/water emulsion that contains both marine residual fuel oil and
marine distillate fuel oil, a surfactant (e.g., soaps) and iron oxide (corroded metal and suspended
solids).  The emulsion is created by circulating this mixture through a centrifugal pump for more
than one hour. Eleven of the thirteen systems profiled above achieved average effluent
hydrocarbon index concentrations below 5 ppm when treating MEPC 107(49) test fluid C
emulsion during certification tests. One of the systems that did not achieve 5ppm lacked the
polishing step during testing which is currently available from its vendor. Of the three systems

                                          22

-------
Oily Bilgewater Separators
Section 4 - Effectiveness of Bilge Separator Treatment Technologies
that had monitoring data from vessels in service, two achieved comparable effectiveness. The
one system produced somewhat higher effluent concentrations (5.2-7.6 ppm) aboard vessels in
service was OCM data of unknown quality. Although the data from vessels in service is very
limited, it suggests that certification tests conducted with the MEPC 107(49) test fluid C
emulsion may be representative of real world performance, at least for these treatment systems.
As previously noted, this summary  illustrates that bilge separator treatment systems, using
different treatment technologies and combinations of unit operations, can achieve and exceed
compliance the current 15 ppm U.S. Coast Guard certification standard.

             Table 4: Effluent Oil Concentrations for Bilge Treatment Systems
Bilge Separator Treatment System
System A
(OWS/PS absorber)
System B
(OWS/Biological Reactor/Clarifier)
System C
(DAF/coag.-flocc./DAF skimming/GAC)
System D
(OWS/prefilter/UF)
System E
(Strainer/preheat/centrifuge)
System F
(OWS/filter coalesce/AGM adsorber)
System G
(Descaler OWS/ coagulation- flocculation-
flotation/granular media filter/ GAC)
System H
(Filter/preheat/OWS)
System I
(unknown)
System J
(unknown)
System K
(Oil absorption filter)
System L
(Oil absorption filter)
System M
(unknown)
Effluent oil
concentration
(ppm) from MEPC
107(49) testing
using fluid C
emulsion
0.26(0.14-0.48)
1.6(1.3-1.8)
<1
1.75 (1.5-2.5)
9.5 (8.4-1 1.0)a
<1
<1
6.7 (5-10)
0.22(0.1-0.42)
4.1 (3.4-4.7)
<0.1
1.7 (0.72-2.7)
0.8(0.4-1.1)
Effluent oil &
hydrocarbon index
(ppm) from vessels
in service



-------
Oily Bilgewater Separators	Section 4 - Effectiveness of Bilge Separator Treatment Technologies
such as the IMO/MEPC's Integrated Bilgewater Treatment System (IBTS) practices
(IMO/MEPC, 2008; Attachment B).

4.15   LIMITATIONS OF CERTIFICATION TEST DATA

       The MEPC 107(49) certification tests, although an improvement over earlier tests, have
also been criticized as insufficient to replicate actual conditions onboard vessels. Several
treatment system vendors indicated the certification tests are too limited to measure the true
effectiveness of bilge separator treatment systems under real-world conditions aboard vessels
(TANKEROperator, 2009). There are three primary criticisms:

       •  The duration of the tests is too short. During testing the bilge separator treat each of
          three test fluids for only 2.5 hours. These tests can be passed using simple filters that,
          in actual service, would be incapable of maintaining performance over longer time
          periods.

       •  The tests are conducted on stationary treatment systems. The pitching and rolling
          motion aboard vessels would reduce the effectiveness of any gravity-based separation
          method.

       •  The rate and composition of the test fluids are constant throughout the tests.
          These test condition are unrealistic because bilgewater characteristics vary. Some
          treatment technologies are better that others in handling oil "shocks" or other
          variations in bilgewater conditions.

       These critics contend that the shortcomings of the MEPC 107(49) certification tests lead
to the approval of many bilge separator treatment systems that cannot effectively treat bilgewater
aboard vessels. These  criticisms are echoed by comments from marine engineers (MarineTalk
discussion forum, accessed July 20, 2010).
                                           24

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Oily Bilgewater Separators	Section 5 - References


                                                                      SECTION 5
	REFERENCES

AFCAN. 2006. Oily waste management onboard of vessels; September 2006 update. Association
       Francaise des Capitaines de Navires. Accessed September 10, 2010.
       (http://www.afcan.org/dossi ers_techniques/gesti on_dech_huileux2_gb.html).

Alper, H. 2003. Regulatory and technical developments in the treatment of oily bilgewater.
       Presented at the International Conference on Marine Engineering Systems (ICMES).
       Finland, May 2003.

Alper, H. 2001. New Technologies for Controlling Oily Bilgewater Discharges. Presented at the
       Marine Environmental Engineers Technology Symposium (MEETS), May 2001.

Alther, G.R. 1995. Organically modified clay removes oil from water. Waste Management, Vol.
       15, IssueS, 1995, p. 623-628.

Bennett, G., and R. Peters. 1988. The removal of oil from wastewater by air flotation: A review.
       Critical Reviews in Environmental Science and Technology, Vol. 18, Issue 3 1988, p.
       189-253.

Caplan, J., Newton, C. and D. Kelemen. 2000. Technical report: Novel oil/water separator for
       treatment of oily bilgewater. Marine technology and SNAME news, 2000, Vol. 37, No2,
       p.111-115.

Bodzek, M. and K. Konieczny. 1992.The use of ultrafiltration membranes made of various
       polymers  in the treatment of oil emulsion wastewaters. Waste Management. 12, 75.

Cheryan, M., and N. Rajagopalan.  1998. Membrane processing of oily streams. Wastewater
       treatment and waste reduction. J. Membr. Sci., 151, (1998), p. 13.

DNV. 2005. Guidance for the Environmental Classifications CLEAN and CLEAN DESIGN.
       Classification Notes No. 62.1. Det Norske Veritas, Norway
       (http://exchange.dnv.com/Publishing/CN/CN62-l.pdf).

EPA. 2010. Study of Discharges Incidental to Normal Operation of Commercial Fishing Vessels
       and Other Non Recreational Vessels less than 79 feet. Report to Congress. U.S.
       Environmental Protection Agency. Washington,
       D.C.(http://cfpub.epa.gov/npdes/vessels/reportcongress.cfm).

EPA, 2008. Cruise Ship Discharge Assessment Report. Oceans and Coastal Protection Division,
       Office of Wetlands,  Oceans, and Watersheds and Office of Water. U.S. Environmental
       Protection Agency. EPA 842-R-07-005.

EPA. 1999. Appendix A; Includes the Surface Vessel Bilgewater/Oil Water Separator: Nature of
       Discharge for the "Phase I  Final Rule and Technical Development Document of Uniform
       National Discharge Standards (UNDS)," U.S. Environmental Protection Agency. EPA-
       842-R-99-00 I.April 1999.

                                          25

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Oily Bilgewater Separators	Section 5 - References
ERG. 2004. Analysis of UNDS Bilgewater Data. Memo from Joy Abel, Eastern Research Group,
       to Ron Jordan, EPA. September 10, 2004.

Ghidossi, R., Veyret, D., Scotto, J.L., Jalabert, T. and P. Moulin. 2009. Ferry oily wastewater
       treatment. Separation and Purification Technology, Vol. 64, Issue 3, 12 January 2009, p.
       296-303.

Gryta, M., Karakulski, K. and A. W. Morawski. 2001. Purification of oily wastewater by hybrid
       UF/MD. Water Research, Vol. 35, Issue 15, October 2001, p. 3665-3669.

IMO. 2006. Pollution prevention equipment under MARPOL. IMO Publishing, 2006.

IMO/MEPC. 2008. Revised guidelines for systems for handling oily wastes in machinery spaces
       of ships incorporating guidance notes for an integrated bilgewater treatment system
       (IBTS). International Maritime Organization/Marine Environment Protection Committee.
       November 2008. (http://www.mardep.gov.hk/en/msnote/pdf/msin0833anx.pdf).

Karakulski, K., Kozlowski, A. and A.  W. Morawski. 1995. Purification of oily wastewater by
       ultrafiltration. Sep. Technol., 5, (1995), p. 197.

Koss, L. 1996. Technology development for environmentally sound ships of the 21st century: an
       international perspective. Journal of Marine Science and Technology, Vol. 1, No. 3, June
       1996.

Lee, S.H., Chung, K.C., Shin, M.C., Dong, J.I., Lee, H.S. and K.H.  Auh. 2002. Preparation of
       ceramic membrane and application to the crossflow microfiltration of soluble waste oil.
       Mater. Lett. 52 (2002), p. 266.

Lysyj, I. and E.G. Russell. 1979. Effectiveness of Centralized Bilgewater Treatment- A Field
       Study. Environment International. 2;177-182.

MarineTalk discussion forum. Accessed July 20, 2010. (www.marinetalk.com/forum-
       post.asp?thread_id=T95040).

MyCelx. 2009. MyCelx Filters Chosen for NCAA's Fisheries Fleet. Accessed July 20, 2010
       (http://newsguide.us/index.php?path=/technology/industri al/MyCelx-Filters-Chosen-F or-
       NOAA-s-Fisheries-Fleet-Bilge-Water-Filters-Improve-Environmental-Impact-Prevent-
       Pollution/)

Noyes, R. 1993. Pollution prevention technology handbook. Noyes Publications, Park Ridge,
       N.J.

Penny, R., and M. Suominen-Yeh. 2006. Biological Bilgewater Treatment System. Naval
       Engineers Journal, Vol.  118, Issue 3, p. 45-50.

Sun, C., Leiknesa,T., Weitzenbock, J.  and B. Thorstensen. 2009. The effect of bilgewater on a
       Biofilm-MBR process in an integrated shipboard wastewater treatment system.
       Desalination, Vol. 236, Issues  1-3, 31 January 2009, p. 56-64.
                                           26

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Oily Bilgewater Separators	Section 5 - References
Navy and EPA. 2003. Discharge Assessment Report. Surface Vessel Bilgewater. U.S.
       Environmental Protection Agency, Office of Water, Washington, D.C., and U.S. Navy,
       Naval Sea Systems Command, Washington, D.C., July 2003.

Navy and EPA. 2002. Characterization Assessment Report. Surface Bilgewater/ Oil Water
       Separator (OWS). U.S. Environmental Protection Agency, Office of Water, Washington,
       D.C., and U.S. Navy, Naval Sea Systems Command, Washington, D.C., December 2002.

TANKER Operator. 2009. Bilgewater treatment - centrifugal or gravity separation? May 2009.
       (http ://www.tankeroperator. com).

Tomaszewska, M.,  Orecki, A. and K. Karakulski. 2005. Treatment of bilgewater using a
       combination of ultrafiltration and reverse osmosis. Desalinization. 185: 203-212.

Weber, W. J., Jr.  1972. Physicochemical Processes for Water Quality Control. Wiley-
       Interscience. New York.

Zhu, X., Reed, B.E., Lin, W., Carriere, P.E. and G. Roark. 1997. Investigation of Emulsified Oil
       Wastewater Treatment with Polymers. Separation Science and Technology, Vol. 32,
       Issue 13, August 1997,  p. 2173-2187.
                                          27

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Oily Bilgewater Separators	Section 5 - References
                               ATTACHMENT A:




             PUBLISHED LITERATURE FROM VENDOR WEBSITES
                                      28

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PureBilge, Separators, Alfa Laval
                                                                                              Page 1 of 2
                                                                                                                       Log in to eBusiness |
                              About us    Products and solutions    Service and support    Customer stories    Contact us
     Products

       PureBilge

        How it works

        Documentation

        Contact
PureBilge  oily water

treatment system
PureBilge is a fully automated centrifugal bilge water
treatment system that cleans oily wastewater
onboard vessels at sea. By effectively removing
marine oil pollution, it makes bilge water safe for
discharge overboard.
                                  This reliable single-stage high-speed centrifugal separation system
                                  effectively cleans large bilge water volumes at sea as well as ashore
                                  without the use of chemicals, adsorption filter or membranes.

                                  Cleaning efficiency
                                  PureBilge generally achieves an oil-in-water content of less than 5 ppm.
                                  Performance has been proven under real-life operating conditions and is
                                  unaffected by sea heave, oil shocks or high solids loading.

                                  Superior separation performance
                                  PureBilge features a patented XLrator disc inlet, which gently accelerates
                                  the bilge water as it enters the separator bowl. This prevents the splitting of
                                  oil droplets and the formation of additional emulsions, which gives
                                  PureBilge a substantial edge over other centrifugal separation systems.

                                  Certified and cost-effective
                                  Certified according to IMO resolutions, MEPC.107 (49) and US Coast
                                  Guard document 46 CFR 106.50, PureBilge is designed for unmanned
                                  24/7 operation.

                                  No man-hours are  required for operation or supervision. There's also no
                                  reject to pump ashore and no need to transport land wastes such as filter
                                  elements, coalescence elements, active carbon, or flocculation deposits.
                                  This contributes to reduced operating costs.

                                  Easy to install in any engine room
                                  Designed for plug-and-play installation, PureBilge is  a compact and  factory
                                  -tested separator module that is easy to install in any engine room.
                                  Continuous operation means that there is no need for large bilge water
                                  holding tanks, which frees up space and increases payload capacity.

                                  Fully automated monitoring and control
                                  The new  EPC 60 Bilge process controller is an easy-to operate, computer-
                                  based Alfa Laval process controller. It facilitates advanced fully automated
                                  monitoring and  control of PureBilge functions by displaying in clear text
                                  process parameters, alarms and other data.

                                  PureBilge separation capacities
                                  PureBilge is available in two standard versions:

                                   •  PureBilge 2515: 2 500 l/h, 15 ppm
                                   •  PureBilge 5015: 5 000 l/h, 15 ppm
http://www.alfalaval.com/solution-finder/products/PureBilge/Pages/PureBilge.aspx
                                                                                               7/25/2011

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PureBilge, Separators, Alfa Laval                                                                                                  Page 2 of 2

                                   PureBilge options
                                   PureBilge includes a broad range of options that further simplify installation
                                   and maintenance. Choose the optional equipment that suits your
                                   requirements and the existing conditions on board:

                                    •  5 ppm certificate
                                    •  Heat recovery
                                    •  Safety box
                                    •  Flow meter
                                    •  Sludge removal kit
                                    •  CIP unit
                                    •  Chemical dosing unit
                                    •  Automatic self-cleaning filter
                                    •  Remote control
                                                                                                      Career   Feedback   Legal terms and conditions
http://www.alfalaval.com/solution-finder/products/PureBilge/Pages/PureBilge.aspx                                                    7/25/2011

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                 FREQUENTLY ASKED QUESTIONS
                What cost savings tan I ruali/e with your product?
                This varies from ship to ship, but typically operational savings range
                from 2 to 4 times per year compared with physical/chemical OWS systems

                Are any of the microbes, chemicals, nutrients, or In products of the
                process harmful or considered hazardous material?
                ;V0. The microbes, chemicals, and niftrients provided are safe products to
                handle and use. The by-pmdwts of she system are negligible amounts of
                carbon dioxide Liininatt>r irw specifically designed lo irettt oik emulsified by
                detergents or tlte ship 'x motion. EnSolve has successfully tested the
                PetroLiminalar with a number uf maritime dfgreasery and detergents.

                Will the system function if pure oil or hea> v oil is pumped into
                the system?
                YES. Thai is wh\ the system is designed in stages. Free-phase oilfmin
                Stage I is physically separated fmm water and directed to a waste nil
                collection tank. The emulsified oil that is not separated in Stage t is directed
                to Stage 2 for hiitlogical treatment. Tim unique one-two punch is \\-hai
                distinguishes tntr technology from any other.
PetroLiminator   OWS
Clean Seas Ahead.
            USCG and  IMO Approved
                    OIL WATER SEP

-------
 PETROLIMINATOR SYSTEM BENEFITS
The PetroLiminator OWS system combines the latest
technology with low maintenance, trouble-free
operation. The system's benefits include
0 Cost Savings: Reduces offloading, maintenance, and
   operational costs associated with sludge, spent flocculants,
   filters and/or bilgewater. Some of our clients saved over 90%
   per year in operational costs by using the PetroLiminator
   technology compared with other OWS systems.
0 Green Technology: Little or no HAZMAT materials
   to dispose.
0" Industry Proven: The PetroLiminator technology has been
   employed on ships since 2000.
0 Processing of Emulsified Oils: Chemical and mechanical
   emulsions easily processed.
0 Added Benefit: The system can process many biodegradable
   organic wastes such as antifreeze, solvents, etc.
0 High Process Rate: Some PL models can process up to
   5,400 gallons of bilgewater per day.
              Type Approvals
               Biosystema Inc.
 EnSolve Biosystems, Inc.
 5805 Departure Dr, Suite B
 Raleigh, NC 27616
 (919)954-6196  Fax (9 1 9) 954-6 197

 www.ensolve.com
         Clean Seas Ahead!

-------
Fluorescence Oil Content Monitor
                                                                                                                                     Page 1 of 2
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                                                     TD-107 Oil  Content Monitor
                                              Fluorescence Detection Technology
                                                                                                                                     Mouse Over
                                                                                                                                    for Larger Image
            Click the article below to read how a UV
          Fluorescence Oil Content Monitor can solve your
               Oily Water Separator problems
                                            n
                                                                                                                                              TD-107
                                                                                                                                              Fluorescence Oil
                                                                                                                                              Content Monitor
                                                                                                                                              IMOMEPC 107
                                                                                                                                              [49) Certified
                                                                                                                                              The TD-107 Oil
                                                                                                                                              Content Monitor
                                                                                                                                              s designed with
                                                                                                                                              a positive fitting
                                                                                                                                              injection port to
                                                                                                                                              TD-107 Oil
                                                                                                                                              Content Monitors
                                                                                                                                              includes
                                                                                                                                              standard alarm
                                                                                                                                              relays, 4-20 mA
                                                                                                                                              output for remote
                                                                                                                                              monitoring, and
                                                                                                                                              a user-friendly
                                                                                                                                              USB data port
                                                                                                                                              for review of
                                                                                                                                              recorded
                                                                                                                                              discharge levels
                                                                                                                                              prior to port state
                                                                                                                                              control visits.
                                                              PRODUCT  INFORMATION
    The TD-107 Fluorescence Oil Content Monitor (OCM) is a 15 ppm bilge alarm for oily water separators based on
    fluorescence detection technology. Fluorescence occurs when a molecule absorbs light energy of one specific
    wavelength and emits light energy of a longer wavelength.  Fluorescent compounds (such as oil) each have a
    unique wavelength signature, and these compounds can be detected as an actual concentration of oil in water.
    Fluorescence makes the TD-107 resistant to interferences by turbidity or particles/sediments in the bilge which
    impact competing "light scatter" oil content monitors. Because silt / algae / iron oxide and other particles do not
    fluoresce at oil's wavelength, they cannot interfere as a 'false positive' high alarm that will keep the oily water
    separator in recirculation mode without ever pumping down the oily waste holding tanks.

    The TD-107 Oil Content Monitor is IMO MEPC 107(49) certified and approved by the USCG for use as a 15 or
    5 ppm bilge monitor / bilge alarm, with detection capability up to the parts per billion level. It comes equipped with
    required data logger and can be customized to show system trends. The oil content monitor features self-
    compensating electronics that corrects for fouling of the sample  cell, along with a cell condition monitor to alert crew
    when sample cell cleaning is required. The TD-107 Fluorescence Oil Content Monitor includes standard alarm
    relays and 4-20mA output for remote monitoring, along with user-friendly USB data port for review of 23 months of
    recorded oil content monitor / oily water separator discharge levels over time. The TD-107  Oil Discharge Monitoring
    Equipment (ODME) is essential for staying in compliance with IMO MEPC 107(49).

    Customer Benefits:
    • IMO MEPC 107(49) Certified as Oil Content Monitor /15 ppm Bilge alarm for Oily Water Separators
    • USCG approved / ABS approved / NEMA 4X Oil Content Monitor
                                                                                             IMO MEPC 107(49) Specification Sheets

                                                                                                   TD-107 Fluorescence Oil Content Monitor    PDF

                                                                                             Technical Drawings OCM / Bilge alarm

                                                                                                   TD-107 Fluorescence Oil Content Monitor    PDF

                                                                                             Operation Manual - OCM / Bilge alarm

                                                                                                   TD-107 Fluorescence Oil Content Monitor   Contact

                                                                                             Presentation - How does UV Fluorescence work?

                                                                                                   TD-107 Fluorescence Oil Content Monitor
                                                                                             IMO MEPC 107(49) Type Approvals
                                                                                                                        USCG Approval
                                                                                                    Oil Content Monitor /15 ppm Bilge Alarm
                                                                                                                        Other Countries
                                                                                                    Oil Content Monitor/15 ppm Bilge alarm
PDF



PDF

PDF
http://www.nagmarine.com/products/ocm/oilcontentmonitor.html
                                                                                                     Learn more at: www.td107.com


                                                                                                                                      7/28/2011

-------
Fluorescence Oil Content Monitor                                                                                                     Page 2 of 2

    • Fluorescence unaffected by sediment / particles / turbidity allows Oily Water Separator to work as intended
    • Simple and easy maintenance, including an optional 'hot-swap' calibration program
http://www.nagmarine.com/products/ocm/oilcontentmonitor.html                                                                       7/28/2011

-------
 MyCelx
 Oil Removal Technologies
Proposal
For: Great Lake Environmental Center
     Doug Endicott

 MyCelx Water Treatment System for removal of hydrocarbons
Proposal Date: 8/6/10

Project No: EPA 10m3/hr 107(49)

Prepared by: MyCelx Technologies Corporation

Contact: Bob Lawson
      lawson@mycelx.com
      901-213-1778
MyCelx- Proposal/Complete System- 10 m3/hr
Page -  1

-------
 MyCelx
 Oil Removal Technologies
MyCelx Oil  Removal  Technology
  MyCelx Oil Removal Systems - Applications
                                Discharge into Sewer
Required Discharge levels of oil in
     water: 15-100 ppm
                                Discharge into Sea
Required Discharge levels of oil in
      water: <15 ppm
                             Produced water discharge or
                                    recycle
                                   (no sheen)
Required Discharge levels of oil in
      water: <10 ppm
                             Discharge into River, Lake or
                                     Pond
                              Water Feed into a Reverse
                              Osmosis Unit/Desalination
Required Discharge levels of oil in
     water: <1-5 ppm
Required Discharge levels of oil in
      water: <1 ppm
                               Process water recycle
Required Discharge levels of oil in
      water: 1-2 ppm
MyCelx- Proposal/Complete System- 10 m3/hr
     Page- 2

-------
 MyCelx
 Oil Remove I Technologies
MyCelx Technology offers an effective, robust and economically viable oil
removal solution

    •  Environmentally Green Engineered Oily Water Filtration
       & Hydrocarbon Odor Removal Solutions
    •  Patented Molecular, Composition of Matter and Applications
    •  The only technology certified by Lloyd's Register, UK for oily water treatment and discharge into
       marine environments
    •  Deployed and implemented in over 100 installations in major petrochemical, oil & gas, marine,
       power and utilities, government and military, manufacturing industries.

MyCelx Technology offers the fastest, easiest, most reliable and economically
viable solution to oily water filtration for water reuse options

   •   Fast - Small Footprint, Low pressure drop, High Throughput
   •   Easy-Operator Friendly, Low Manpower Requirements, Simple Maintenance
   •   Reliable - Safe, Robust Operation and Process Protection, >99% efficiency
   •   Economical - Lowest capital & competitive operating costs

MyCelx Technology is Green Technology

   •   Lowest energy consumption
   •   Smallest footprint and most efficient process for oil contamination removal
   •   Lowest disposable/recyclable byproducts
   •   MyCelx Technology utilizes a fully green manufacturing process with 100% conversion of raw
       products to finished goods

Why choose MyCelx Oil Removal Systems?

   •   No visible oil sheen guarantee in the effluent
   •   Instant and permanent oil removal - GRO, DRO and oils ( free, dispersed and emulsified)
   •   Least size and footprint to high oil removal efficiency
   •   No additional pump requirement - requires less than 1 bar to operate - inline pressure of
       process water > 1 bar is suffice
   •   High Oil Removal Capacity (4-10 Ibs/filter) -low waste - 1/10-1/100 lower waste of any
       alternate adsorbent media  including GAC
   •   Fixed Oil Removal Capacity - Effectiveness does not vary with influent concentration
   •   Simple process - safe and easy to use
   •   Low handling or maintenance time - no electrical or mechanical moving parts
   •   Internationally proven and  over 500 oil removal installations
   •   Certified by Lloyds Register to meet low discharge levels in oily water
   •   ISO 9001: 2000 Certified
   •   Ability to meet 1 ppm or less on oil removal
   •   No sludge waste
   •   No liquid or oily water waste

MyCelx- Proposal/Complete System - 10 m3/hr                       Page - 3

-------
 MyCelx
 Oil Remove I Technologies
MyCelx Key Clients List

OIL & GAS E&P OPERATIONS
     •  Anadarko Petroleum Corporation
     •  EnCana
     •  Breitburn Energy
     •  Petrochina
     •  Conoco Phillips
     •  MWH Global
     •  Williams Pipelines
     •  Magellan Pipeline
     •  Enterprise Pipeline Products
     •  JLC Technologies
     •  Global Petroleum Research Institute
     •  CFR Consulting

PETROCHEMICAL & CHEMICAL PROCESSING
OPERATIONS

    •   British Petroleum ( BP)
    •   Saudi Basic Industries Corporation
       (SABIC)
    •   Sunoco Chemicals
    •   Marathon Petroleum
    •   Bechtel, WSRC
    •   IBEC
    •   Nalco Dyes
    •   Akzo Nobel Pharmaceuticals
    •   Abbott Labs/ Ross Laboratories

UTILITIES - POWER AND WATER

    •   United States Army Corp of Engineers
    •   Pennsylvania Energy Company (PECO)-
       Utility Co. for Pennsylvania
    •   Tennessee Valley Authority—Kentucky
       Hydro Plant
    •   Allegheny Power
    •   New York Power Authority
    •   Niagara Power Authority
    •   Grand Bahamas Power
    •   Hawaii Power
    •   GE Energy
    •   Vogtle Electric Generating Plaza
    •   Hydro One-Ontario
    •   Bechtel WSRC
    •   Florida Power and Light Company
MANUFACTURING/HEAVY INDUSTRY
     •  Lockheed Martin
     •  Jacobs Engineering
     •  JCM Associates - Constitution Square
     •  GE Glass-Ecomagination
     •  DeBeers
     •  Toyota Motor Corporation
     •  General Motors Corporation
     •  Chrysler Motor Corporation
     •  Honda Automotive Corporation
     •  United Technologies Corporation (UTC)

MARINE APPLICATIONS

    •  Wilhelmsen Shipping
    •  Overseas Shipping Group (OSG)
    •  Teekay Shipping
    •  Mediterranean Shipping Company (MSC )
    •  Dole Ocean Cargo Express
    •  Eletson Shipping Corporation
    •  Austal
    •  BP Shipping
    •  Matson Navigation
    •  Barber ship
    •  United States Coast Guard (USCG)
    •  United States Navy
    •  Canadian Coast Guard
    •  Royal National Lifeboat Institution
    •  Donjon Salvage
    •  Disney/ Princess Cruise Lines
    •  Carnival Cruise Lines
    •  Galapagos  Island Cruise Lines

OIL SPILL REMEDIATION

    •   State of California - Fish and Game
       Commission
    •   Australian Antarctic Division
    •   Environmental Protection Division - US
       EPA
    •   U.S. Steel Corp
    •   Vogtle Electric Generating Plaza
    •   Hydro One-Ontario
MyCelx- Proposal/Complete System- 10 m3/hr
                    Page -  4

-------
 MyCelx
 Oil Removal Technologies
Process Schematic
Description:

The BK 107(49) unit will have four stages. The first stage is MyCelx oil water separator with enhanced
coalescing media inside. The oil water separator is followed by a bag filter housing on the stage 2. Stage
3 and stage 4 are MyCelx 20 round cartridge filter housing with high efficiency bilge filters on them.
Bilge water generated is flown through four stages of MyCelx treatment system and then through OCM
which is controls the flow of the treated water. If the OCM reads less than 15 ppm the bilge will be sent
for overboard discharge. If the OCM reads more than 5 ppm the bilge water will be directed back to the
bilge tank for recirculation.
MyCelx- Proposal/Complete System- 10 m3/hr
Page -  5

-------
 MyCelx
 Oil Removal Technologies
Picture and Schematic of the Housings in different stages.

Stage -2: Bag Filter Housing
                                 1/4' VENT PDK'T
                                                       CLAUP

                                                       GASKET

                                                       COMPRESSION SPRING

                                                       BASKET
                                                        1/4' GAUGE
                                                        PORTS
                                                        BASKET
                                                        ADJUSTABLE
                                                        LEGS
                                                        llk'AIN
                                                  	£• FMPT
                                            OUTLET
Inlet and outlet connections are 2" NPT
MyCelx- Proposal/Complete System- 10 m3/hr
Page -  6

-------
 MyCelx
 Oil Removal Technologies
Stage-3and4MX20
                                                                    VENT

                                                                    HEAD
                                                                    KNOT?
                                                                    CLAMP
                                                                    GASKET

                                                                    HDLD DDWN °LATE
                                                                    SPR:NG SEAL ASSEMBLY
                                                                    DDE CARTRIDGE

                                                                    22E CARTRIDGE (OPTIONAL)



                                                                    CENTER RDll M)
                                                                   DRAINS


                                                                    - 4' RF FLAN3E
Inlet and outlet are 3" Flange
MyCelx- Proposal/Complete System- 10 m3/hr
Page-  7

-------
 MyCelx
 Oil Remove I Technologies
Design Parameters and Technical Specifications: Table 5
Flow Capacity
Operating Flow Rate
Required Operating Pressure
Max. Operating Pressure
Max Operating Temperature
Rating
Materials of Construction
Drain Ports from 3 filter
vessels/housings
Estimated Maintenance or Media
Replacement Period of each
Parallel Unit
Design Oil in water content in
discharge
10 m3/hr or 44 gpm
10 m3/hr or 44 gpm
5 psi
150psig
180 F
Non -stamped vessels. Optional ASME stamped vessels are
available
SS304 Vessels
¥2" Brass Ball Valves on Drains Ports
2- 4 months (depending on the oil loading)
1-5 ppm
Options requested:

- Left hand design
- High lift option
- float switch
- Differential pressure switches and control panel lights
- Pressure relief valve
 - Gasoline resistant pump
MyCelx- Proposal/Complete System- 10 m3/hr
Page-  8

-------
 MyCelx
 Oil Removal Technologies
MyCelx 107(49) Certified System:
MyCelx- Proposal/Complete System- 10 m3/hr
Page- 9

-------
 MyCelx
 Oil Removal Technologies
MyCelx 107(49) Certification
                       U. S. Department of Homeland Security


                          United  States Coast Guard



                         Certificate  of Spprotial


   Coasc  Guaid Approval Number: 162.050/A9Q34/0                      Expires:  09 December 2013

                               OIL  POLLUTION PREVENTION EQUIPMENT
                       The following device has been tested in accordance
                                with IMO Resolution MEPC.107(49)

                                MYCELX  TECHNOLOGIES CORPORATION
                                     470-E woods Mill  Road
                                     Gainesville  GA 30501

   MyClex 107 - 10.0;  15  ppm  Separator

   Equipment manufactured  by Recovered Energy  Incorporated to specification/assembly drawing
   no.  BOSS 45T 107 dated  5/26/2005.   Coalescer  manufactured by Recovered Energy  Incorporated
   to specification/assembly drawing no.  BOSS  107 Separator System, Rev. A dated  7/7/2005.
   Filters manufactured by Recovered Enecgy  Incorporated to specification/assembly drawing no.
   BOSS 107 Separator System,  Rev. A dated 7/7/2005.  Control equipment manufactured by
   Recovered Energy Incorporated to specification/assembly drawing no. IMO 107  dated 5/23/2005.

   Maximum throughput of system is 10.2 cu.  m/hr (45.0 gpm} .

   An integral pump is fitted  with this equipment.  A copy of this certificate  should be
   carried aboard a vessel fitted with this  equipment at all times.  IMO Certificates of Type
   Approval do not expire  and  are valid for  equipment manufactured at any time  during the
   period of validity of this  certificate.   Test data and results attached in the appendix.

   This certificate documents  compliance  with  46 CFR 162.050.

                                          ***  END ***
      THIS IS TO CERTIFY THAT the above named manufacturer has submitted to the undersigned satisfactory evidence that the item specified herein complies
   with the applicable laws and regulations as ouliined on the reverse side of ihis Certificate, and approval is hereby given- This approval shall he in effect until the
   expiration dale hereon Luiless sooner canceled or suspended by proper authoiit).




                                 GIVEN UNDER MY HAND THIS 9* DAY OF

                                 MARCH 20(.K>. AT WASHINGTON li.C.
                                 Chief, Engineering Division
                                 U.S. Coast Guard Marine Safety Center
   DEPT. OF HOMELAND SECURITY, USCG, CGHQ-1D030
   [REV 3.0JI
MyCelx- Proposal/Complete System- 10 m3/hr                         Page -  10

-------
 MyCelx
 Oil Removal Technologies
MyCelx Lloyd's Register Certification Data
Lloyd's Register EMEA
71 Fmrfmrrh Sim I, London, EC3M4SS
Telephone 0207121 2910 Fax 02071974246
Email dc}>-stt 70
riicrons microns
•1?.?. 0
11 11
11 0
11 0
U 0
11 0
11 0

lie
Ui
US
NAS
Class
11
11
9
10
10
11
10

ISO Code
19/15
19/14
17/11
18/12
18/11
19/13
18/12


ycl's Register North Ameriw,
irlrsluit, S(

nr.
.uoyds
Register
                 THIS DOCUMENT IS SUBJECT TO THE PROVISIONS ON THE REVERSE
MyCelx- Proposal/Complete System- 10 m3/hr
                                                      Page -  11

-------
 MyCelx
 Oil Remove I Technologies
Shipping and Handling Costs:
                             Components
                   EX WORKS, Gainesville, Georgia, USA
Available as complete skid
Rental Costs:
         Item
        Components
   Price
      Housings
   MyCelx BilgeKleen
        107(49}
     Filter Media
 Complete system with oil water
 separator and MyCelx polisher
 with Oil content monitor, pump
and control valves. Including one
 set of media installed inside the
          housings
    (Replacement Set)
$45,900.00
                            Total for set of media
                                     $4,891.00
MyCelx- Proposal/Complete System- 10 m3/hr
                                  Page -  12

-------
 Coffin World Water Systems
Take the Guesswork Out
of Your Bilge Water Separator
                  ULTRA-SEP
                  OILY WATER SEPARATORS
 -«*~
•^«r

-------
                                     \
Can you really
count on your
Oily Water
Separator!
As regulations become more stringent and enforcement increases, everyone, including owners, designers,
builders and operators of ships and offshore oil rigs, have become aware that the oily water separator (OW5)
is a serious design specification and operating consideration...and a key personal responsibility.

•  Are you confident that every drop of water your vessel discharges overboard will meet the strict new International
  Maritime Organization standards?

*  Do your crews spend too much time on OWS maintenance, cleaning, replacing filters, or measuring chemicals?

•  Does your system produce hazardous by-products that must be disposed of onshore?

•  Do you have worldwide original equipment manufacturer support for OWS service, certification and inspection issues?

Given the high stakes, can you really count on your OWS?
Now you can. Without fail.
Everywhere. All the time.

     ULTRA-SEP
     OILY WATER SEPARATORS
                                                    SRIR-Q-LIXTCIR.

                                              Featuring SPIR-Q-LATOR * positive physical barrier
                                              membrane technology for assured compliance
    Drawing on the company's seventy years of marine equipment design and development
   experience. Coffin World Water Systems (CWWS) continues its leadership in environmental
             and operational excellence in bilge water separation technology.

-------
ULTRA-SEP™ sets the new standard
    Unlike other systems that rely on monitors to prevent overboard discharge greater than
    15 ppm, ULTRA-SEP is designed to prevent discharge greater than 5 ppm to the monitor
    or overboard.
                               ULTRA-SEP Flow Diagram
     A two-stage system that takes
     the guesswork out of compliance
     The first stage initial separation of free oil and gross
     particutates is done with our industry-leading
     HELI-SEP* high efficiency coalescing separator.
     The second stage separation of emulsified oil is
     accomplished with SPIR-O-LATOR" leading-edge
     membrane technology.
       up
The Q   formula for Success
ULTRA-SEP systems with positive physical barrier SPIR-O-LATOR technology surpass all other water
separation technologies in meeting the new standards with high efficiency, superior effectiveness,
economical operation and assured exposure-reducing performance. This is the e4 Formula for Success.
EFFECTIVENESS:
The only system to provide a positive
physical barrier
The SPIR-O-LATOR is the industry's most advanced technology
to process emulsified oil. It's based on membrane technology,
which provides the only positive physical barrier to prevent
contaminated water from passing through the system to
the monitor.

ECONOMY:
Low maintenance, fewer consumables
and no waste disposal
The ULTRA-SEP system results in the lowest total cost of OWS
operation by reducing the labor, and entirely eliminating the
coalescing filters, media, chemicals, and the hazardous
by-products associated with other systems.
EFFICIENCY:
Continuous overboard flow
The SPIR-O-LATOR Membrane provides maximum
operational efficiency with minimum labor. A special pore
structure rejects oil and dirt at the membrane surface. A
self-cleaning flow pattern prolongs operating time between
cleanings and provides continuous overboard discharge.

EXPOSURE:
Reduces exposure to regulatory,
financial and operational risks
ULTRA-SEP reduces risk exposure with positive physical barrier
protection that will not run to failure like many other systems.
SPIR-O-LATOR Membrane technology has proven its reliable
and superior performance and has been adopted by many of
the world's leading fleets.

J

-------
 FIRST STAGE:
 High efficiency removal of free oil with HELI-SEP
 The world's leading coalescing matrix separator
®
The first stage efficiently removes free
oils using our HELI-SEP coalescing matrix
separator, which is familiar to ship operators
worldwide. More than 7,000 units in
service around the world is proof of its
reliable performance.

   Incoming bilge water is drawn through a
   high-density permanent matrix providing
   approximately 242,300 coalescing points with
   a surface area of 390 square meters per cubic
   meter of matrix volume.

2 Free oil droplets coalesce and rise to the top of
   the vessel for collection and discharge while
   paniculate impurities settle to the bottom
   for removal.

   The oil discharge sensor initiates the
   automated first stage cleaning cycle, cleaning
   automatically during oil discharge.


-------
    ULTRA-SEP™ does not require complicated flocculation chemical regimens or continual dosing, thus saving
    the cost of chemical supplies and labor!
    ULTRA-SEP Membrane technology continuously produces water to a purity of less than Sppm oil, while
    systems based on centrifuges, media or coalescing filters can provide an incomplete separation of emulsified
    oil under certain conditions.
    Unlike other technologies that remove oil from bilge water, leaving an emulsification of varying degrees,
    SPIR-O-LATOR Membranes remove the water, ensuring safe discharge under the strictest of regulations.
SECOND STAGE:
Superior separation of emulsions with SPIR-O-LATOR
Positive  physical barrier membrane technology
                                        ®
                A 10 micron oil molecule can't pass
                through a.01 micron pore. The SPIR-0-LAJOR
                Membrane is the only OWS technology
                that provides a positive physical barrier
                against oil and contamination.
SPIR-O-LATOR Membranes reliably and
continuously produce clean water with less
than 5 ppm oil content ULTRA-SEP systems are
certified to IMO MEPC107(49) by the U.S. Coast
Guard—one of the industry's toughest testing
and enforcement agencies.

1  Processed water from the first stage is pumped
   through the second stage at the optimum flow
   and pressure for SPIR-O-LATOR Membranes.
2 The membranes repel oil at the surface and
   attract water. Their .01 micron pores present a
   positive physical barrier that rejects oil molecules
   and particulates while allowing water to pass.
3 Water permeating the membranes is
   clean with less than 5 ppm and can be
   discharged overboard.
4 Concentrated oil waste—the "reject"—is
   sent to the sludge tank.

-------
HowSPIR-O-LATOR   technology works
   CWWS has been a pioneer in the application of membrane technology to meet the stringent
   new standards for today's bilge water separation. With more than a decade of operational
   experience in shoreside and marine applications to separate oily water, the CWWS
   SPIR-O-LA TOR is the most sophisticated and effective OWS technology available for bilge
   water separation.
Water is pumped from the outside through the membranes
to come out clean through the central core

The unique SPIR-Q-LATOR flow continuously pushes bilge water between the layers of membranes. The smaller water molecules are
forced into the center of the membranes while the larger molecules of oil remain outside. The two parallel streams of fluids come out
the end—clean water in the center, ready to be freely discharged and oily residue on the outside to be removed.
The SPIR-O-LATOR unit contains multiple membrane sheets, spirally wound around a central core (permeate tube). Each sheet consists
of oleophobic (oil repelling) outer layers and a hydrophilic (water attracting) central layer to collect the separated clean water. The spiral
design provides a large surface area (up to 264 square feet per membrane) for more effective demulsification.
   Here's How It Works...
            me Technology
                              After removal of free oil,
                              bilge water is pumped
                              from one end of the
                              SPIR-O-LATOR to the
                              other, flowing between
                              the sheets of the spirally
                              wrapped membrane.
Simultaneously, the
bilge water is driven by a
pressurized cross-directional
flow against the membrane
surfaces. The unique spacer
design provides flow channel
for solids to pass from end
to end between membrane
sheets without clogging.
Each membrane sheet
has two oleophobic {oil
repelling) outer surfaces
and a hydrophilic (water
attracting) inner layer.
This construction repels
oil while drawing water
molecules into the interior
of the membrane.

-------
         The unique benefits of SPIR-O-LATOR®

         • Provides a positive physical barrier
           Membranes are the only separation technology that present a positive physical barrier that will not allow oil molecules to pass
           through to the discharge side of the system.The membrane barrier prevents oil from reaching the oil monitor, which means less
           cleaning of the monitor, fewer alarms for the crew and minimizes potential for accidental discharge.

         • Cleans in place without clogging
           The SPIR-O-LATOR Membranes'oleophobic surface and asymmetric pore structure result in less fouling by free oils and concentrated
           oil emulsions. This makes membrane technology the only OWS system that is largely self-cleaning.

         • Has a long operating life
           High oil content in the bilge will not cause a membrane to be spent more quickly, as is the case with adsorption systems, which
           require regular replacement of filters or media. Simple cleaning in place will allow the membrane to continue in operation without
           replacement, saving on costs of material, labor and ship downtime.

         • Is not a run to failure technology
           Unlike many other OWS systems which have to be maintained when they channel or become saturated, allowing quantities of oil to
           pass through to the monitor, SPIR-O-LATOR Membranes operate continuously, preventing  oil from reaching the monitor.
The surface of the
membrane presents
.01 micron pores through
which the bilge water
is driven with a 5 bar
differential pressure.
.01 micron pore size accepts
entry of water molecules
while preventing entry of oil
molecules and particulates.
The asymmetrical pore
structure does not allow
oil and particulates to lodge
in openings and clog pores.
The water infiltrates into the
permeate of the individual
laminate sheets that are
attached to the permeate
tube, and travels through
the permeate layer to
the tube.
The SPIR-O-LATOR flow
continuously pushes
bilge water through
the membrane pores to
produce a central core of
clean water that may be
freely discharged, and a
segregated stream of oily
waste that is processed to
the sludge tank.


-------
Tnee   Formula  for Success
   Evaluating oily water separation technology requires balancing complex factors
   that influence operational efficiency, the effectiveness of the system under real
   world conditions, economic considerations, and risk exposure. This is the 64
   Formula for Success.
   EFFECTIVENESS
   The effectiveness of a system is dependent on its ability to
   process the concentration and types of participates
   contained in the water, the ability of the system to remove
   the oil content, and the reliability of the equipment to
   maintain high performance.


   The ULTRA-SEP™ system:
   • Provides a positive physical barrier to oil and consistently
    produces clean water with less than 5 ppm oil content to
    the monitor and overboard
   • Removes particulates along with oil
   • Produces clean water without hazardous chemical or
    biological waste by-products
   • Operates continuously without maintenance delays
   • Technology is proven worldwide in both shipboard
    andshoreside installations

   ECONOMY
   OWS systems vary greatly in acquisition and operating costs.
   The right system can save money in maintenance costs, labor,
   disposal costs and consumables. An important cost factor
   is non-operation. Frequent repairs and slow service cause
   vessel downtime.
   The ULTRA-SEP system:
   • Is just 20% of the cost of operation per ton compared to
   other systems
   • Does not require chemicals, coalescing filters, clay
   or carbon filter replacements
   • Has a long-lasting membrane life cycle of 5 years
   • Produces no chemical sludge that must be disposed of
   • Is easy and economical to install
   • Provides compact designs

EFFICIENCY
OWS systems vary widely in operational factors such as
complexity of operation, amount of labor required for daily
maintenance, time spent replacing consumables and labor
required for environmentally-sound disposal.
The ULTRA-SEP system:
• Requires minimal operator involvement, saving time
 and labor costs
• Offers PLC (Programmable Logic Controller) with automatic
 operation and cleaning
• Provides continuous operation and can be cleaned in place
• Continuously processes bilge water, preventing the need for
 onshore bilge water disposal
• Has control and instrumentation interface kits available for
 remote monitoring and recording


EXPOSURE
Failure of the OWS system puts your business, the
environment... and you at risk. In order to mitigate the risk
of financial, operational or legal consequences, your OWS
system must be easy to operate, economical, effective and
provide reliability for the rugged requirements of life at sea.
The ULTRA-SEP system:
• Provides a positive physical barrier that minimizes the risk
 of accidental overboard discharge
• Is certified by the U.S. Coast Guard (USCG) to MEPC W7(49)
 and has Marine Equipment Directive (MED) certification
• Is backed by experienced CWWS engineering and service
 professionals who are available forlOPP, USCG and other
 port inspections
• Is supported by a worldwide network of parts and service
 technicians to provide fast response

-------
Comparing OWS Technologies

  Any comparison of OWS technology must take into account the actual operation of the
  system day after day and year after year. How effective is the system? How does it affect
  your operating efficiency? What does it cost both initially and to keep in proper operation?
  What is the risk to the ship owners and others in the event of system failure. The chart
  below provides an overview of how OWS technologies perform in the key value criteria.
                                          OWS Technology
                            Coalescing Adsorption Flocculation Centrifuge  Membrane
j| EFFECTIVENESS
Continuous separation of chemical
and mechanical emulsions
Susceptible to permanent clogging
Continuous less than 5 ppm effluent
to the monitor (all conditions)
J*fr EFFICIENCY
Clean in place
Replacement filters required
when bacterial fouling occurs
Consumable media required for
consistent discharge less than 5 ppm
Oil saturation resulting
in recirculation
^ ECONOMY
Purchase price
Consumable filtration media
Filtration media disposal cost
Labor involved to
clean the unit
Footprint
{O| EXPOSURE
^f^f
Effluent consistently less than 5 ppm
Potential for vessel downtime due
to inoperable OWS or failed IOPP
Creation of waste for
onshore disposal
Positive barrier to prevent
oil discharge
Low
Yes
No
NO
Yes
Yes*
Yes
Medium
Yes*
Yes
Medium
Medium
No
Medium
Yes*
No
Low
Yes
NO
No
Yes
Yes
Yes
Low
Yes
Yes
Medium
Small
No
High
Yes
No
High
No
No
No
Yes*
Yes*
Yes
High
Yes*
Yes
Medium
Large
No
Low
Yes*
No
Medium
No
No
Yes
Yes*
Yes*
No
High
Yes*
Yes
Medium
Large
No
Low
Yes*
No
High
No
Yes
Yes
No
No
No
Medium
No
No
Low
Medium
Yes
Low
No
Yes
* fo consistently meet less than 5 ppm.

-------
            Coffin World  Water Systems
                                                      fit or
    replacement, ULTRA-SEP" offers a full
    range of//WO MEPC. 107(49) solutions
                                               Unmatched flexibility to get
                                               the benefits of ULTRA-SEP any where
    ULTRA-SEP
    Modular
ULTRA-SEP systems are available in seven models from 0.50 to 10 cubic
meters per hour capacity and various power configurations. All models
carry U.S. Coast Guard certification to MEPC. 107(49) as well as EC Marine
Equipment Directive (MED) certification, Russian Maritime Register of
Shipping and ABS type approval.

NEW BUILDING - Skid-mounted and Compact ULTRA-SEP units are
available up to 10 ton/hour with a variety of pump and motor options to
meet your needs. CAD block drawings are available for Naval Architects
and Designers as required.

RETROFIT-The ULTRA-SEP MD (Modular-Design) is delivered in modules
sized to facilitate access through hatches and fit into tight spaces. Like
our skid-mounted models for new builds, the modular-design units
come pre-piped and pre-wired for easy assembly and integration with
existing connections. Retrofits can be completed while underway without
disrupting other activities.

UPGRADE - Technical specification, design, drawing and certified
equipment packages are available for upgrade of HELI-SEP installations
from MEPC.60(33) to MEPC. 107(49) certification. Please consult CWWS Sales
and/or Service personnel for more information.
           Specifications for ULTRA-SEP Systems from 0.5 to 10 Cubic Meters per Hour Capacity
Model No.
US 500
US 1000
US 2000
US 3000
US 5000
US 7500
US 10000
Capacity
mVh 6PM
0.5 2.2
1.0 4.4
20 8.8
3.0 13.2
5.0 22.0
7,5 M,0
10.0 44.0
tength*
mm IN
890 35
965 38
1830 72
1830 72
2640 104
2640 104
2640 104
Width*
mm IN
760 JO
890 35
1320 52
1320 52
1420 56
1815 71,5
1815 71.5
Height*
mm IN
1550 61
1SSO 61
1670 66
1670 66
1830 74
1995 78.5
1995 78.5
Weight*
kg IBS
350 770
390 858
625 1380
690 1525
863 1902
1430 3150
1535 3380
Oily Water
Inlet
mm IN
25 1,0
25 1.0
40 1.5
40 1.5
50 2.0
SO 2.0
SO 2.0
Oil Outlet
mm IN
25 1.0
25 1.0
25 1.0
25 1,0
25 1.0
25 1.0
25 1.0
Clean Water
Inlet
mm IN
25 1.0
25 1.0
as 1.0
25 1.0
25 1.0
25 1.0
25 1.0
Processed
Water Outlet
Discharge
mm IN
25 1.0
25 1.0
25 1.0
25 1.0
25 1.0
SO 2,0
50 2.0
Processed
Water Outlet
Re circulate
mm IN
25 1.0
25 1.0
25 1.0
25 1.0
25 1.0
50 2,0
50 2.0
Power
kW
3
4
8.6
8.6
8.8
125
12.5
         'Approximate dimensions fat single skid system.
                                                                  Thtsysttm an atat be batatiedin mGd^sk&dtptiidkigo

        Note: For ships with challenging bilge conditions, CWWS has developed and offers an array of technical
        solutions from tank design to automatedpretreatment,
10

-------
Worldwide resources to keep your water clean
and your environment protected
    Coffin World Water Systems (CWWS) serves a global customer base with state of the art
    separation technology for meeting water discharge regulations, process requirements
    and water purification standards. We call on our depth of experience, ISO 9001 quality
    manufacturing and a worldwide network of factory trained engineers to provide solutions
    that fulfill your requirements for effectiveness, efficiency, economy and the reduction
    of risk exposure.
  TOTAL COMMITMENT

  Coffin World Water Systems combines
  the experience and dedication of two
  industry powerhouses. World Water
  Systems and Coffin Turbo Pump, to
  continue its worldwide leadership role
  in the marketplace. We are committed
  to bringing the finest technology, the
  most experienced professionals and best
  practices to the critical problem of water
  treatment and clean discharge into our
  oceans and waterways.

  Our commitment is demonstrated
  through a company-wide dedication
  to quality, development of superior
  products, meeting customer needs, and
  is backed by expert support, service and
  comprehensive warranties.
WORLDWIDE FOOTPRINT

Our extensive network of service centers,
engineers and trained representatives
enables us to provide service, parts,
consulting, certification and problem
solving worldwide. We know the value
of time in critical marine and offshore
applications, and we are always available
to help you keep your operations up and
running whereverthey may be around
the globe.

CWWS offers a wide range of products
to the marine and offshore oil and gas
industries. Please see our website
tvwtv.cworWwater.com to obtain technical
information and product brochures for:

•  ULTRA-FILTRATION and monitoring
  solutions for deck wash applications

•  AQUA-SEP reverse osmosis fresh water
  making equipment

  CRP-SEP oily water separators for
  process water applications on rigs
  and platforms

  ULTRA-SAFE assured compliance
  monitoring systems for marine
  and offshore
DESIGN AND
TECHNOLOGICAL LEADERSHIP

Over the past quarter of a century, CWWS
has been a leader in environmental
and operational excellence in water
separation technology.

We combine our extensive knowledge of
water treatment, filtration and separation
technology with innovative systems
engineering and efficient manufacturing
techniques to provide our customers with
proven and effective solutions for their
water generation, fluid separation and
wastewater discharge applications.

Our pioneer HELI-SEP* single vessel oily
water separator revolutionized the market
with its compact footprint, automatic
operation and low maintenance
requirements. CWWS is now setting new
standards in oily water separation with
leading edge SPIR-O-LATOR81 Membrane
technology to provide vastly improved
operation and superior results. CWWS was
the first OWS manufacturer to  be certified
by the U.S. Coast Guard in June, 2004, to
IMOMEPC.l 07(49).
                                                                   www.cworldwater.com

-------
                           COFFIN WORLD WATER SYSTEMS
                           Leading global innovator in water separation systems
                           CWWS products, parts and services are available around the world through an extensive network of
                           technical representatives who are factory trained in the application, selection and operation of our
                           products. CWWS representatives offer extensive knowledge and experience in the proper application
                           of our equipment. They are backed by our world leading experts in water applications. Together they
                           will work closely with you to ensure that your installation operates to the highest level of performance
                           and meets your requirements.
                           Contact your local representative or our corporate offices for more information, technical support or
                           to arrange for a service technician to visit your location. CWWS is a division of Coffin Turbo Pump.
        Corporate Headquarters

        1732 McGaw Avenue
        Irvine, California 92614
        U.SA

        Tel: +1-949-222-5777
        Fax:+1-949-222-5770

        i nfo@c wo rl d water .c om
European Sales Office

The Gatehouse, 35 Robjohns Road
Chelmsford Essex CM1 3AG
England

Tel:+44 (0)1245 251711
Fax:+44 (0)1245 252088
                                                                                             Taipei
                                                                                             Taiwan
Coffin Turbo Pump

326 South Dean Street
Englewood, New Jersey 07631
U.S.A.

Tel: +1-201 -568-4700
Fax:+1-201-568-4716
                                                                  Coffin World Water Systems
                                                                             www. cworldwater. com
® Coffin World Water Systems LLC
MJS-1001  10-07

-------
                        ATTACHMENT B:




SUMMARIES OF INFORMATION GATHERED IN TELEPHONE CONVERSATIONS

-------
                                    EMAIL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: September 22, 2010
Company Name: Victor Marine
Contact Name: Antony Chan
Email Address:  achan@victormarine.com
Name: Doug Endicott
Subject: Victor Marine Bilge Oil Water Separators

                       TOPICS DISCUSSED AND ACTION TAKEN

Dear Doug,

With regards to your enquiry here is some information you have requested.

1. Victor Marine OWS units are tested to and compliant to MEPC 107(49). I have enclosed our third
party testing of the VM1000 report (which was witnessed by class surveyors and an USCG
representative). All results show 
-------
The cost of a VM1000 change is £545.00 each. Thus assuming the unit is run 1 hr daily, this would be 1
change per annum.

c) During the service you would require to change the gasket set too. This is £95.00

So total annual cost can be estimated to be £545.00+£165.00+£95.00 = £805.00 per annum or a better
calculation would be £2.40 per tonne of bilge water processed.

From our database and experience, we have seen replacement filters/media ordered between 6-18
months.

I hope the above gives you an indication of the unit costs, if you require further information please let us
know,

Kind Regards

Antony Chan
Engineering Manager, Victor Marine

From: Duncan Marshall [mailto:dmarshall@victormarine.com]
Sent: 21 September 2010 12:36
To: dendicott@glec.com
Cc: achan@victormarine.com; 'Dennis Day'; 'Peter Barton'
Subject: RE: requesting information for bilge oily water separators

Thank  you for your interest in our products  and we  are pleased to  send you copies
of  our standard quotes for  both the CS and VM Oily  Water Separators.   Both
separators  use the same technology and processes but  as you can  see  the  VM is a
much more sophisticated model  and therefore  is  a more expensive  unit  to
manufacture.

The smallest  unit we manufacture is a 0.25 m3/hour  and the largest  is 5  m3/hour
we  have therefore quoted for  both the 0.25 m3/hour  and the 1  m3/hour  units but
should you  require the price  of any other units please do not  hesitate to contact
us.

Our Antony  Chan will contact  you over the next  24 - 48 hours  either  by e-mail or
phone  to discuss our equipment further and as the designer of  our  separators is
much more qualified to discuss the equipment than me.

I hope the  attachments are  of  interest and should you have any queries I am sure
Antony will  be able to answer  them.
Kind Regards

Duncan Marshall
Sales Manager

-------
Mob: +44 7932 001497

	Original Message	
From: Doug Endicott [mailto:dendicott@glec.com]
Sent: 17 September 2010 13:39
To: info@victormarine.com
Subject: requesting information for bilge oily water separators

Hello,

I am a contractor to the federal EPA, supporting their development of
a national Vessel General Permit for non-recreational vessels.  Part
of this work involves gather information for EPA on the current
commercially available onboard treatment systems to remove oil  from
bilge water. Victor Marine is being contacted because it
advertises the VM Series oily water separator certified by IMO  MEPC
107(49) for removing oil from bilge water.

I have reviewed the information about the VM Series separators  on your
comany's
web site, and have questions to ask as follow-up. This information may be
summarized for inclusion in the Administrative Record to support EPA's
Vessel General Permit.
Specifically:

Can you provide information on capital and O&M costs for treatment systems
with capacities of approximately 1 cubic meter per day and 1 cubic meter per

hour? Do the O&M costs include service and/or maintenance parts, labor,
replacement media, and residuals disposal? If not, are there guidelines  for
useage rates of these items for in-service treatment systems?

Secondly, can you provide third-party data for oil/hydrocarbon
concentrations in the effluent from this treatment system?
Is this data for the system treating real bilge water onboard a ship, or is
it data from a certification test?
In the latter case, I am interested in treatment data for  Test Fluid C
"emulsified oil" defined under CFR 162.050.

Would it be possible to speak to a company representative about the VM
Series separators  certified OWS?
I can be reached at (231) 941-2230 between 9 and 4:30 EOT.

Thank you,
Doug Endicott
Great Lakes Environmental Center
739 Hastings Road
Traverse City, MI 49686
(231) 941-2230 office
www.glec.com
webpages.charter.net/dougendicott/

-------
                          9/13/10 TELEPHONE CALL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: September 13, 2010
Company Name: Seaway Marine Transport
Contact Name:  Steve Wright
Phone No.: (swright@seawaymarinetransport.com)
Name: Doug Endicott
Subject: Bilge Oily Water Treatment System

                      TOPICS DISCUSSED AND ACTION TAKEN

Tobias Mattsson of Alfa Laval suggested I contact Mr. Wright. He is the director of marine
projects at Seaway Marine Transport, a Canadian shipper operating 24 freighters on the Great
Lakes. Because his company operates vessels on the Great Lakes, they must comply with 5 ppm
oil standards for their bilge discharges.

Seaway Marine Transport's primary concerns in choosing bilge separators are that they be
effective and reliable. Cost is not so much an issue, because the cost of not complying with the 5
ppm standards would be inevitably greater. Their company has installed centrifuge-based bilge
separators (Alfa Laval) on their vessels. This choice was based on the positive reputation of the
centrifuges for bilge separation, Alfa Laval's reputation for supporting their products, and the
company crew's experience operating and maintaining other centrifuges aboard ship, which are
used for fuel treatment and lube oil separation.  In fact, most vessels have 3 centrifuges on board.
Thus, the crews are familiar with this technology, which is an important consideration. Their
Alfa Laval separators are very reliable and routinely produce 0-2 ppm effluent oil concentrations
without tertiary (organoclay filter) treatment.

In Mr. Wright's opinion, the centrifuge systems are the best available, although he also indicated
that other "top of the market" (i.e., high purchase price) systems (e.g., Marinfloc, Wartsilla) are
known to perform well. Lower-cost bilge separators (especially OWS/filter combinations) can
also work, but are more sensitive to changing bilge water composition, can require large
quantities of consumables (e.g., sorbent media), and can be more difficult to properly maintain.

OCMs are as much trouble to the ships' crews as the separators. They require continuous
maintenance and cleaning to avoid malfunctions and erroneous readings due to interferences
with the turbidity they monitor. Mr. Wright suspects that more than half of the OCM readings
above 5 ppm aboard his vessels are erroneous, which is a problem because (1) it causes the bilge
separators to recirculate instead of discharging clean effluent and (2) these readings are recorded
and saved for 18 months. The accuracy of the Dekma and Rivertrace OCMs they use is
reportedly + 5 ppm,  so their readings are questionable.

Mr. Wright indicated that there is a big difference between meeting a 5 ppm oil standard versus
15 ppm in bilge water discharge, the former requiring much greater effort. Seaway Marine
Transport's experience is that meeting 5 ppm oil standards for bilge discharge is possible,
although it requires a serious commitment to acquiring and maintaining effective bilge separators
and OCMs, along with following guidance such as the IMO Integrated Bilge Water Management

-------
practices. The latter include proper design of bilge water holding tanks (oil skimming within the
tanks, suction from the bottom of the tanks, etc.).

I asked Mr. Wright about how his company's vessels handle oil residuals. They do not incinerate
oil waste aboard ship in the Great Lakes, although they have considered this as an option. They
offload oil waste at the fueling facilities that they use, one being at Hamilton, Ontario. Common
charges for oil waste disposal are Can$ 0.13-14/liter (this is equivalent to $ 0.48-5I/gallon).

-------
                             TELEPHONE CALL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: August 26, 2010
Company Name: Alfa Laval
Contact Name:  Larry Bogia
Phone No.: (267) 980-1779
Name:  Doug Endicott
Subject: Bilge Oily Water Treatment System

                      TOPICS DISCUSSED AND ACTION TAKEN

Larry Bogia is the US marine sales manager with Alfa Laval, a company that markets centrifuge-
based bilge oily water treatment systems. According to information on the company's web site
(www.alfalaval.com), the Alfa Laval product line includes bilge oil separators that are Coast
Guard certified for MEPC 107(49). I confirmed this with Larry. He told me that the company's
Eco stream bilge treatment system had recently been redesigned to increase capacity. He has
visited  100 vessels in the past year where this system has been installed. Although the Ecostream
system is 3 times more expensive (purchase cost) than certified units from other manufacturers,
he believes that the Ecostream gives superior performance. The Ecostream system currently
costs 75,000 Euros, over $100,000 in the US.

He was aware of company data showing Ecostream systems producing effluent oil
concentrations less than 3 ppm for entire deployments. When asked about certification test data,
Larry mentioned that their older data had relatively high effluent oil concentrations (-14 ppm)
because Alfa Laval did not use a free oil sensor to bypass the treatment system if fed pure oil (as
occurs  in one of the certification tests). Other manufacturers' systems typically include such a
sensor  and bypass, and the newer Alfa Laval systems do as well.

Larry indicated that oil content meters (OCMs) was another  area where real improvements could
be made. The best units, costing over $30,000, are much more accurate than the low-cost OCMs
that are in wide use.

He suggested that  I contact Tobias Mattsson in Sweden to obtain the latest certification test data.

-------
                             TELEPHONE CALL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: September 1, 2010
Company Name: Coffin World Water Systems
Contact Name:  Lou Muzzarone
Phone No.: (800) 568-9798
Name: Doug Endicott
Subject: ULTRASEP Bilge Oil Water Separators (follow-up)

                      TOPICS DISCUSSED AND ACTION TAKEN

Follow-up conversation with Lou Muzzarone to better understand the issue of waste residuals
generated by bilge oily water separators. Lou expressed that the best bilge separator treatment
systems achieve both treatment effectiveness (low effluent oil) and operating economy (less oily
waste requiring disposal) by removing more of the water from the bilge water. 500 ppm is only
0.5% oil in bilge water, a fairly small volume if most of the water can be removed.

Liquid residuals from bilge separators most often end up in the sludge tanks aboard vessels.
When full, these must be pumped ashore for treatment and disposal as oily waste classification
(distinct from hazardous waste). Disposal costs vary by port, may be as high as $1-2 per gallon.

The economic justification for bilge treatment is to reduce the volume of oily bilge water  that
must be stored aboard the vessel. For vessels <400 GT, the assumption is that these vessels make
frequent port calls & therefore can store oily ballast water to be pumped ashore for treatment and
disposal.

Solid phase residuals (sorbents) disposal is more ambiguous. Probably treated similar to oily
rags, disposal by landfill or incineration on shore.  GAC becomes saturated when oil reaches 10-
20% by weight.

Residuals from coagulation/flocculation (sludge) probably go to vessel's sludge tank.

The concentrate generated by UF is recirculated to the bilge tank, with most of the oil de-
emulsified. The OWS should separate this oil on the next treatment pass. Thus, the overall waste
oil generated in a OWS/UF system should be only -15% of the treated bilge water.

UF membrane lifetime is expected to be 5 years; Coffin warranties membranes for 3 years.
Membrane replacement not included in O&M costs he provided previously. Lou promised to
provide this cost in the near future.

Oil and hydrocarbons typically do not occur as molecules in water; (large) macromolecules
instead.

-------
                              TELEPHONE CALL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: August 10, 2010
Company Name: MyCelx
Contact Name: Bob Lawson
Phone No.: (901) 213-1778
Name: Doug Endicott
Subject: Bilge Oil Water Separators

                       TOPICS DISCUSSED AND ACTION TAKEN

Bob Lawson is sales manager at MyCelx, a company that markets bilge water treatment systems.
These systems use a series of treatment steps including coalescence, strainer/prefilter and a
polypropylene filter treated with a proprietary polymer (MyCelx). These treatment systems are
certified to comply with MEPC 107(49), and are the only certified systems that use filtration.
The company also  supplies MyCelx filters to other manufacturers of bilge water treatment
systems.

He indicated that many MEPC 107(49) certified treatment systems did work well when treating
bilge water containing  emulsified oil. Some membrane treatment systems use MyCelx filters as
pretreatment. MyCelx filters are used to polish bilge effluent on OSG  (a US shipper) vessels,
and have been evaluated for use on smaller vessels by NOAA and the Coast Guard.

Bob provided several emails with additional information about Coast Guard certification test
results and cost data. Copies of these emails are attached (below).
From: Bob Lawson 
To: Doug Endicott 
Subject: MyCelx BilgeKleen Systems
Date: Thu, 5 Aug 2010 11:01:38 -0500

Doug,

This is the Lloyd's certification for our bilge polishing filters. The attached letter from Lloyd's allows these filters to be added to
an MEPC 60(33) certified system (this was the only certification available at that time).

Best regards,

Bob Lawson
Sales Manager
901-213-1778
lawson @mvcelx.com
From: Bob Lawson 
To: Doug Endicott 
Subject: FW: Bilge Treatment Oversight
Date: Thu, 5 Aug 2010 11:17:06 -0500
Organization: MyCelx

-------
Doug,

This attachment gives an oversight of our range of bilge treatment systems:
      MEPC 107(49) certified OWS for vessels over 400GT
      Sub 5 polishing filters to be added to MEPC 107(49) or 60(33) certified OWS to achieve discharge levels > 5 ppm O&G.
      Mycelx bilge filters to be used on commercial and recreational vessels without OWS systems.

Best regards,

Bob Lawson
Sales Manager
901-213-1778
lawson @mvcelx.com
From: Bob Lawson 
To: "'Doug Endicott"1 
References: <006801cb34b9$a68c5580$f3a50080$@com>
<002e01cb3590$004ed440$OOec7ccO$@com>
In-Reply-To: <00aa01cb3591$lIcfc430$6932a8c0@glec.local>
Subject: RE: Bilge Treatment Oversight

Doug,

Re: Big Blue Bilge Filter System

This is a very inexpensive bilge water treatment system used on commercial vessels that do not have an OWS. The system
consists of two plastic OC3 filters housing operated in series to achieve a discharge of < 5ppm. This system has a built in visual
indicator to let you know when to change filters. The second filter housing has a clear bowl. When the first filter is saturated with
oily hydrocarbons it begins to pass small quantities of oil. Since the flow direction through the filters is outside-in, the passed oil
from the first filter will show up on the outside of the second filter cartridge. At the next convenient opportunity the first filter
cartridge should be discarded and the second filter cartridge moved up to the front. A new cartridge is place in the second
position.
This system is rated up to 20 gpm, but two systems (4 housings) can be connected in parallel for flows up to 40 gpm. We have a
tour boat in the Galapagos Islands with a bilge system of 80 gpm that has 4 systems piped in parallel.
This is still a comparably compact and inexpensive system (pictures available).
As I mentioned, NOAA recently installed MyCelx big blue bilge systems on their fleet of vessels. I have attached a press release
that was issued with NOAAs cooperation and a picture of one of the vessels.
The pricing on a two housing system is as follows:

MvCelx Big Blue Bilge System  Max. flow rate 22 GPM

OC3   (4.5x20")  white   $134.00  incl. filter cartridge  and mounting bracket
OCC3  (4.5x 20")  clear   $175.00   incl. filter cartridge and mounting bracket
                 Total  $309.00

Replacement cartridges  MD20LD5-5 $405.00 per case of 5

Best regards,

Bob Lawson
Sales Manager
901-213-1778
lawson @mycelx.com

From: Doug Endicott [mailto:dendicott@glec.com]
Sent: Friday, August 06, 2010 12:59 PM

-------
To: Bob Lawson
Subject: Re: Bilge Treatment Oversight

For the sake of comparability with other OWS systems, probably the PureShip BilgeKleen MEPC 107(49) 1.0 and 10 m3/hr are
the most appropriate. If you have cost data for the smaller "Big Blue" systems, I will use that as well. I think EPA is considering
what to do about vessels < 40 tons.
	Original Message	
From: Bob Lawson
To: 'Doug Endicott'
Sent: Friday, August 06, 2010 1:51 PM
Subject: RE: Bilge Treatment Oversight

Do you have any specific systems or applications that you would like pricing on?

From: Doug Endicott [mailto:dendicott@glec.com]
Sent: Thursday, August 05, 2010 12:03 PM
To: Bob Lawson
Subject: Re: Bilge Treatment Oversight

Thank you, Bob. I will review this material for inclusion in the technical report I'm preparing for EPA. Were there any cost data
you could share with me regarding the capital and O&M costs of the integrated OWS/MYCELX systems?

Doug
	Original Message	
From: Bob Lawson
To: Doug Endicott
Sent: Thursday, August 05, 2010 12:17 PM
Subject: FW: Bilge Treatment Oversight

Doug,

This attachment gives an oversight of our range of bilge treatment systems:
           MEPC 107(49)  certified OWS for vessels over 400GT
           Sub 5 polishing filters to be added to MEPC 107(49) or 60(33) certified OWS to achieve discharge levels > 5 ppm
        O&G.
           Mycelx bilge filters to be used on commercial and recreational vessels without OWS systems.

Best regards,

Bob Lawson
Sales Manager
901-213-1778
lawson @mycelx.com
From: Bob Lawson 
To: "'Doug Endicott'" 
Subject: MyCelx 107 (49) 1.0
Date: Fri, 6 Aug 2010 14:39:45 -0500
Organization: MyCelx

Price: MyC 107 (49) 1.0m3/hr  $13,350
       Replacement media      $453

Best regards,

Bob Lawson
Sales Manager
901-213-1778
lawson @mycelx.com

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                             TELEPHONE CALL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: September 23, 2010
Company Name: Total Marine Solutions
Contact Name:  Caroline Medich
Phone No.: (954) 327-2032
Name: Doug Endicott
Subject: Bilge Oily Water Treatment System

                      TOPICS DISCUSSED AND ACTION TAKEN

Caroline Medich is managing director with Total Marine Solutions, the US representative for
Marinfloc bilge oily water treatment systems. Marinfloc markets the EBBWCS Type CD oily
water separator, which is certified by IMO MEPC 107(49) for removing oil from bilge water.
Much information about this treatment system is available on the Marinfloc web site
(www.marinfloc.com). The type CD separators operate continuously and have multiple treatment
stages: a "descaler" that operates somewhat analogously to a centrifuge (except without moving
parts) to remove primarily free oil; a reactor that combines coagulation and flocculation with
flotation and skimming of emulsified oil; filtration using Aqualite (volcanic rock) to remove any
residual floes; and activated carbon polishing as a final stage.

Marinefloc publishes list prices for its separators, although Ms. Medich indicated that lower
costs are often negotiated. Marinefloc also publishes an operating cost of $3/cubic meter
($11/1,000 gallons), which includes replacement parts, chemicals, media and labor. It was
unclear whether this operating cost included residual disposal. Filter media and GAC are steam
regenerated, and (at most) require annual replacement.

Residual generation has been highly optimized in the Marinfloc type CD separators, and is
estimated to be 3-5%  of the volume of bilge water treated, although this depends upon how much
oil and solids  is in the bilge water. Aboard some ships, the crews are very diligent about keeping
oil out of bilge water, while on other ships no such effort is made and the bilge separator faces a
heavier oil loading. Managing solids/sludge in the bilge water is a similar issue. Ms. Medich
noted that many low cost OWS  require frequent cleaning because they become plugged by
solids. This can become a maintenance problem, especially if the ship's crew is not properly
trained in proper cleaning procedures.

I requested certification data for effluent oil concentrations, as well as "case study" data from
separators aboard ships in service. Ms. Medich promised to send available data of this sort in
several days. She also noted that Marinfloc is unique in that it guarantees their type CD
separators to produce a bilge effluent with oil concentrations below 5 ppm. In her experience,
effluent oil concentrations are usually 1-2 ppm.

-------
                                      EMAIL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: September 1, 2010
Company Name: Alfa Laval
Contact Name:  Tobias Mattsson
Email Address:   tobias.mattsson@alfalaval.com
Name: Doug Endicott
Subject: Alfa Laval Bilge Oil Water Separators

                        TOPICS DISCUSSED AND ACTION TAKEN

Doug,

No, you must have got that wrong. It is not that bad. Our high speed separator is designed to clean the
water so the oil being pumped out from the oil outlet will not be perfectly pure. In general the water
content in the oil will not be more than 10% regardless of  if an emulsion is present or not. We use heat
and the XLrator in combination of approx 7000 G to break emulsions.

PureBilge is still not a magic machine which will perform perfectly in all circumstances but it is far better
than most other available equipment. There are some other good performing OWS's on the market also
and they have more or less the same price tag as our system. Our two main competitors in the high-end
market is Marinfloc (chemical and filter based) and Westfalia (also high speed separator) but we have so
far never lost when ship owners are comparing the performance in real life onboard.

I think the IMO-guideline implementation of IBTS is a good initiative. That will help increase the
performance on any OWS and hopefully avoid some of the worst problems the crews onboard are facing.

Alfa Laval also have a sludge separator to treat the oily sludge onboard and dewater the oil so it can be
safely incinerated, used  a boiler fuel or simply reduce the sludge volumes so it will be cheaper to land it
ashore. The oily sludge contains mainly water but also a lot of oil and particles. The water from the sludge
separator is pumped to the bilge holding where the OWS  will de-oil the water further down to legal limits
for discharge overboard. The oil from the sludge separator contains around 1% of water. In a perfect
world I would like a sludge de-watering separator to be included in the IBTS.

I more than happy to help you with your work so please don't hesitate to contact me. I'm trying to keep to
facts and am avoiding the sales angles. I've been working onboard myself and know how much the crews
are struggling with the oily water treatment. Most oily waste equipment is really sub-standard and
shouldn't be onboard.  I think we have the same goal; avoid oil pollution from vessels and ease the
workload for oily water treatment for the crews.

BR's
Tobias
Tobias Mattsson, B.Sc. Marine Eng.
Application Manager Oil Treatment, Parts & Service Equipment
Tel direct: +46 8 530 653 29 - Mobile: +46 708 99 53 29 - Fax: +46 8 530 651 64
tobias.mattsson@alfalaval.com

Alfa Laval Tumba AB

-------
Visit: Hans Stahles vag 7 - SE-147 80 Tumba
Registration number: 556021-3893 - Registered office: Tumba
Tel switchboard: +46 8 530 650 00 - Fax switchboard: +46 8 530 650 55
www.alfalaval.com
Horn:        "Doug Endicott" 

To:          "Tobias Mattsson" 
Date:        2010-09-01 20:31

Subject:      Re: requesting infromation about bilge oily water treatment systems
Tobias,

Thank you again for your willingness to provide information about your centrifugal separators. When we
spoke last week, I recall that you mentioned that the oil separated by the centrifuge typically had a water
content of about 50%, but I cannot find this recorded in my notes or in the literature.  Is this correct? Or
does this vary in practice, for example with the proportion of emulsified oil being treated?

Thanks again,
Doug

Douglas Endicott
Great Lakes Environmental Center
739 Hastings Road
Traverse City, Ml 49686
(231) 941-2230 off ice
www.glec.com
webpages.charter.net/dougendicott/

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                                   EMAIL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: August 6, 2010
Company Name: Government of Canada
Contact Name:  Paul Topping
Phone No.: (paul.topping@tc.gc.ca)
Name:  Doug Endicott
Subject: Canadian Regulation of Bilge Oily Water Treatment System

                      COPY OF TEXT FROM EMAIL EXCHANGE

Hi Doug,

I had a conversation with my precedessor who was involved with setting the 5ppm limit.  Our
regulations require a 15 ppm oil filtering equipment with a 5 ppm oil content meter, alarm and
automatic stopping device if a vessel is to discharge bilge water from its machinery space into
inland waters (such as the Great Lakes and the Seaway). The fitting of such equipment is,
however, not mandatory as a vessel has the option of retaining oily bilge water on board for
discharge ashore, or in the case of an ocean going vessel, discharging 15 ppm oily water into the
sea after it leaves inland waters.

When the 5 ppm option was first introduced in our regulations, there was a requirement to have
both approved 5 ppm oil filtering equipment and a 5 ppm oil content meter, but this didn't work
as foreign administrations were only approving 15 ppm oil filtering equipment. In the case of
the oil content meter, the only concern with using a 15 ppm meter is that the meter must also be
adjusted to 5 ppm and then be accurate in the 5 ppm range. If the 15 ppm oil filtering equipment
is not producing an effluent that is at 5 ppm or below, then the automatic stopping device  will
prevent any of the effluent from being  discharged overboard.  The systems work by fitting a y-
valve that diverts any non-compliant effluent back to the oil filtering equipment to be
reprocessed so that, unless there is a large influx  of new unprocessed oily bilge water, eventually
the 15 ppm oil filtering equipment should be able to produce an effluent under 5 ppm. If it can't,
then the options of discharging ashore  or at sea as mentioned above are available.

With respect to which technologies meet this  standard, all the equipment that we have approved
is listed in our Approved Products Catalogue  at:
http://wwwapps2.tc.gc.ca/Saf-Sec-Sur/4/APCI-
ICPA/en/APCI  SelectApprovedPollutionPreventionEquipment.asp?cat=APPE

On the above page in the middle selection "Search by Function:", select CBA (Canadian Bilge
Alarm 5ppm) this will provide a list of available  products.
Cheers

Paul

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	Original Message	
From: Doug Endicott 
To: Topping, Paul
Cc: Albert.Ryan@epamail.epa.gov 
Sent: Tue Jul 27 14:23:09 2010
Subject: Re: Canadian Oily Water Separator Contact

Hello Paul,

As you point out below, Canada limits the bilge discharge of oil and grease at 5 ppm in inland
waters. We are interested in this because it suggests that Canada may have some experience (and
hopfully data) regarding whether oily water separator  and filtration technologies can meet the 5
ppm limit in practice. My reading of the Canada Shipping Act suggests that the 5 ppm limit
actually applies to the bilge alarm and automatic stop,  not the filtering equipment itself. The
filtering equipment appears to require certification for  acheiving a 15 ppm effluent, consistent
with MARPOL. Maybe you can clarify how the pollution regulations apply in practice, and
whether the 5 ppm limit can be acheived by currently available treatment technologies (and, if
so, which ones)?

Thank you for your assistance,
Douglas Endicott
Great Lakes Environmental Center
739 Hastings Road
Traverse City, MI 49686
(231)941-2230 office
www.glec.com
webpages.charter.net/dougendicott/

Topping, Paul wrote:
> Hello Ryan
>
> Things are going well, the weather is fine here.  A few days with
> humidity, but nothing like Washington. You have my sympathies.
>
> I can assist Doug as I administer our pollution regulations for ships,
> a link to which is found below.
> http://laws.justice.gc.ca/en/showtdm/cr/SOR-2007-86
>
> We have three regimes in Canada depending on where one's ship is
> located.
>
> (1) Coastal waters -east and west, south of 60°N, we set a 15ppm
> discharge limit per Annex I to the MARPOL Convention.
>
> (2) Great Lakes  and Seaway east of Montreal -5ppm limit

-------
> (3) Artie waters (all Canadian waters north of 60°) zero discharge.
> This is under the Arctic Waters Pollution Prevention Act
> http ://laws.justice. gc. ca/eng/A- 1 2/index.html
>
> Cheers,
>Paul
> ----- Original Message -----
> From: Albert.Ryan@epamail.epa.gov [mailto:Albert.Ryan@epamail.epa.gov]
> Sent: Tuesday, July 27, 2010 12:31 PM
> To: Topping, Paul
> Cc: Doug Endicott
> Subject: Canadian Oily Water Separator Contact
> Hello Paul,
>
> I hope you are enjoying your summer and not facing a scorcher like we
> have in DC.
>
> Doug Endicott, cc'd in this email, is currently doing some background
> research for us looking at oily-water separator technologies.  Would
> you have a good contact in either Transport Canada or another
> department that Doug can contact to assist in his research.  The
> questions are merely factual background and searching for good quality
> OWS discharge data.
>
> Many thanks,
> Ryan
>
> Ryan Albert, Ph.D.
> Environmental Scientist
> EPA EAST-Room 7329B Mail Code: 4203M
> 1200 Pennsylvania Ave., N.W.
> Washington DC 20460
> (202) 564-0763

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                                  EMAIL RECORD

Project: 6004-21 NPDES Task Order 4, Task 1 Permit Development
Date: September 1, 2010
Company Name: Wartsila
Contact Name:  T.Nielsen
Phone No.: (tommy.Nielsen@wartsila.com)
Name:  Doug Endicott
Subject: Bilge Oily Water Treatment System

                      COPY OF TEXT FROM EMAIL EXCHANGE

From: Nielsen, Tommy (Wartsila Senitec)
Sent: 30 August 2010 9:29
To: 'dendicott@glec.com'
Subject: Inquiry from public website: Sustainability & Environment
Regarding the oil in the discharged water

I have attached some test results where we have measured the oil content during the USCG test,
after start up and after two years in operation. I have also attached the 5 ppm type approval
certificate.
Regarding the cost:

We have collected customer feedback to get real figures of the Cost per m3 discharged for our M-
Series. The average cost are 3,5 US$/m3 based on this survey (se below what was measured in
the survey).
     Chemicals consumption
     Filter material consumption (sand and activated carbon)
     Power consumption (unit)
     Power consumption (preheating)
     Spares consumed
     Man-hours used for maintenance
     Attendance requirement for operation
Note that the highest cost for the customer often is the sludge disposal cost. With a bilge water
system that works the sludge disposal cost are minimized. We try to point out to our customers

-------
that reduced cost and environmental improvements goes hand in hand and can be achieved by
improvement of the sludge and bilge management.
Best regards
Tommy

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          ATTACHMENT C:




VENDOR SUBMITTED PERFORMANCE DATA

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Vendor Submitted Performance Data
System & Data Type
System A - Certification
System A - Certification
System A - Certification
System A - Certification
System A - Certification
System A - Certification
System A - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System B - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Analyte
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Effluent Result
(ppm)
0.48
0.14
0.21
0.14
0.37
0.26
0.23
1
1.1
1.3
1.1
1.3
2.6
1.5
1.6
1.4
0.5
0.5
0.5
0.5
0.5
0.5
1.6
1.8
1.3
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0

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System & Data Type
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System C - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Analyte
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
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Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Effluent Result
(ppm)
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
5.0
4.5
4.0
3.5
3.5
3.0
4.5
1.5
1.5

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System & Data Type
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System D - Certification
System C - Certification
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Case Study Specific
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Test Fluid
Test Fluid A
Test Fluid A
Test Fluid A
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Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Unknown
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Analyte
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Oil and grease
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Effluent Result
(ppm)
4.5
4.5
4.5
4.0
4.0
4.5
3.5
2.5
3.5
2.5
2.0
2.0
1.5
1.5
2.5
3.5
3.0
2.5
3.5
3.0
2.5
1.5
1.5
1.5
2.5
1.5
2.0
<1
6
0
1
0
0
0
8
6

-------
System & Data Type
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
Testing Type
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Test Fluid
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Analyte
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Effluent Result
(ppm)
5
0
3
3
9
13
10
7
1
5
0
5
0
1
10
0
0
7
3
6
14
14
6.5
4
2
1
7
7
8
9
4
8
0
5
7
5

-------
System & Data Type
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
Testing Type
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Test Fluid
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Analyte
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Effluent Result
(ppm)
13
4
8
6
3
6
1
2
2
3
10
2
6
2
4
5
5
14
4
4
11
8
7
6
8
0
5
7
5
1
6
4
5
7
4
6

-------
System & Data Type
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
Testing Type
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Operational Reading
Test Fluid
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Process Water
Analyte
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Effluent Result
(ppm)
6
8
7
6
3
6
2
5
2
3
0
7
9
12
10
20
10
8
3
6
7
0
10
10
11
9
13
12
10
11
8
13
0
3
1
5

-------
System & Data Type
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System B - OCM Reading
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System E - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
System F - Certification
Testing Type
Operational Reading
Operational Reading
Operational Reading
Operational Reading
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Process Water
Process Water
Process Water
Process Water
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Analyte
Oil in water concentration
Oil in water concentration
Oil in water concentration
Oil in water concentration
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Effluent Result
(ppm)
0
0
3
8
7.1
5.7
5.7
12
10.9
14.7
3.2
12.5
1.7
1.4
2.3
1.6
9.2
8.4
11
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1

-------
System & Data Type
System F - Certification
System F - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
System G - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Analyte
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Effluent Result
(ppm)
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1

-------
System & Data Type
System G - Certification
System G - Certification
System E - Certification
System C - In Service Test
System C - In Service Test
System D - In Service Test
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
System Start Up Testing
System Follow up Testing
Case Study Specific
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid C
Test Fluid C
unknown
Process Water
Process Water
Process Water
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Analyte
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbons
Hydrocarbons
Hydrocarbon Oil Index
Hydrocarbon Concentration
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Effluent Result
(ppm)
<1
<1
<5
<1.0
<0.1
<1
6
6
5
8
6
6
10
6
6
8
8
9
8
8
8
9
10
6
6
6
5
8
6
6
10
6
6
8
8
9

-------
System & Data Type
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Analyte
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Effluent Result
(ppm)
8
8
8
9
10
6
6
6
5
8
6
6
10
6
6
8
8
9
8
8
8
9
10
6
6
6
5
8
6
6
10
6
6
8
8
9
10

-------
System & Data Type
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Analyte
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Effluent Result
(ppm)
8
8
8
9
10
6
4
4
4
6
4
9
8
8
7
4
5
5
6
5
5
5
5
5
4
4
4
6
4
9
8
8
7
4
5
5
11

-------
System & Data Type
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Analyte
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Effluent Result
(ppm)
6
5
5
5
5
5
4
4
4
6
4
9
8
8
7
4
5
5
6
5
5
5
5
5
4
4
4
6
4
9
8
8
7
4
5
5
12

-------
System & Data Type
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System H - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System I - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Analyte
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Effluent Result
(ppm)
6
5
5
5
5
5
0.21
<0.1
<0.1
0.13
0.17
0.12
0.26
0.17
0.18
0.1
0.26
0.35
<0.1
0.14
0.13
0.15
0.42
0.1
0.14
0.11
<0.1
0.21
0.19
0.15
0.2
0.92
1.14
0.63
0.44
0.51
13

-------
System & Data Type
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System J - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System M - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Analyte
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Effluent Result
(ppm)
0.17
0.1
2.2
3.4
4.1
4.7
0.2
0.2
0.11
0.21
0.14
<0.1
<0.1
0.2
0.38
<0.1
0.24
0.15
0.2
0.34
0.16
0.4
1
1.1
0.1
0.1
<0.1
0.1
<0.1
0.1
O.I
O.I
0.1
O.I
0.1
O.I
14

-------
System & Data Type
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System K - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
System L - Certification
Testing Type
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
IMO Res. MEPC. 107(49)
Test Fluid
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid A
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid B
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Test Fluid C
Analyte
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Hydrocarbon Oil Index
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Oil content
Effluent Result
(ppm)
0.1
0.1
O.I
0.1
O.I
0.1
1.25
1.52
0.88
1.35
0.51
5.3
4.1
4.1
1.2
1.1
2.7
2.2
1.6
1.5
0.72
15

-------