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INTERNATIONAL MARITIME ORGANIZATION
E
SUB-COMMITTEE ON SHIP DESIGN AND
EQUIPMENT
52nd session
Agenda item 20
DE 52/20/5
12 December 2008
Original: ENGLISH
ANY OTHER BUSINESS
Retrofitting existing pollution prevention equipment for compliance with
resolution MEPC.107(49) test standards and oil content monitors
Submitted by the United States
SUMMARY
Executive summary: In response to the direction from MEPC 56, this document proposes test
procedures and discusses the appropriate oil content monitors that should
be used for pollution prevention equipment that has been upgraded
to comply with the requirements of resolution MEPC.107(49).
Strategic direction: 7.1
High-level action: 7.1.2
Planned output: -
Action to be taken: Paragraph 16
Related documents: DE 51/28, paragraph 18.16.1; DE 51/18; MEPC 56/6/2; MEPC 56/6/11;
resolutions MEPC.107(49) and MEPC.60(33); and MEPC 42/15/1
Introduction
1 At MEPC 56, the Committee tasked the DE Sub-Committee to consider among other things
the possible upgrading of existing equipment and the development of an appropriate standard for
such an upgrade. This action was taken following discussions regarding the United States
proposal
in document MEPC 56/6/2 for phasing-out existing pollution prevention equipment that was
unable
to meet the requirements of resolution MEPC.107(49) Revised Guidelines for pollution
prevention
equipment for machinery space bilges of ships. While the United States supports such a phase-
out
on non-complying equipment, the US has always considered the upgrading of existing
equipment
to meet the current standards as a valid means of achieving the goal.
2 On this topic, the US proposes two aspects to be considered in any discussion on the
upgrading of existing separators and appropriate standards: (1) in any upgrade, the equipment
should
necessarily be fitted with an MEPC.107(49) oil content meter; and (2) the test standard for
existing
equipment that has been upgraded with add-on equipment, i.e. the bilge separator and oil content
meter, should be tested and certified as a complete assembly, through MEPC.107(49).
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Oil Content Meters resolution MEPC.107(49) vs. resolution MEPC.60(33)
3 It is important that the upgrading of existing equipment include the incorporation of an oil
content meter complying with the current standard, MEPC.107(49). Existing equipment typically
has oil content meters meeting the previous standard, MEPC.60(33). There are significant
differences between the performance requirements in these two standards for oil content meters
that
reflect the state of technology from those eras. The MEPC.107(49) standard builds on the
previous
standard, and is a marked improvement, to better monitor oily water processed effluents in
preventing oil pollution to the sea.
4 One of the main differences to note between the MEPC.107(49) and MEPC.60(33)
requirements for oil content meters is that the MEPC.107(49) oil content meter is accurate over
a wider range of bilge fluids. Both standards require oil content meters to read distillate oil,
however, the MEPC.107(49) oil content meter is designed to read oil-water emulsions, while the
MEPC.60(33) oil content meter has no such requirement. Additionally, the MEPC.107(49) oil
content meter is required and tested to read heavy oil (residual fuel oil), while the MEPC.60(33)
oil
content meter has no requirement to read heavy oil. A characteristic of heavy oil is that it is more
viscous and has a higher wax number than that of distillate oil. Again, the only requirement in
MEPC.60(33) for oil content meters is to read distillate oil.
5 The MEPC.107(49) oil content meter is more discriminating with solids than the
MEPC.60(33) oil content meter. From the United Kingdoms MSA report of May 1997, it was
noted
that the current oil content meters (i.e. MEPC.60(33) oil content meters) were underestimating
the
amount of oil when encountering particulates and emulsions. Indeed, the requirements for the
MEPC.60(33) oil content meter require a contaminant test using 10 ppm of air cleaner test dust,
whereas the requirements for the MEPC.107(49) oil content meter require a contaminant test
using
water contaminated with iron oxide in a concentration of 10 ppm, followed by tests with iron
oxide
concentrations of 50 ppm and 100 ppm respectively.
6 The difference in required response times between the MEPC.107(49) and MEPC.60(33) oil
content meters is significant as well. The required response time for the MEPC.107(49) oil
content
meter is 5 seconds. By comparison, the required response time for MEPC.60(33) oil content
meter
is 20 seconds.
7 Additional differences to note are that MEPC.107(49) oil content meters are required to be
tamper resistant and the meters are to be designed to not allow the equipment to discharge while
flush water is being fed to it. There are no such requirements in MEPC.60(33). Also, the
MEPC.107(49) oil content monitors are required to store pertinent operational data which can be
reconciled with the oil record book to assure conformance, while MEPC. 60(33) oil content
meters
had no such requirement.
Test Standard for type approval of existing equipment being upgraded
8 The US proposes that the test standard for type approval of existing bilge separation
equipment that is being upgraded should be the MEPC.107(49) test standard and that the
complete
bilge separation equipment (existing plus add-on) should be tested and type approved. Some
have
suggested that only the added-on sections of equipment that is added to existing bilge separation
equipment should be tested, and then using only the new test fluid C, the emulsified oil-water
test
fluid mixture. The United States does not support this position because it ignores a number of
important aspects regarding MEPC.107(49) and the compatibility of the components that make
up
a complete MEPC.107(49) bilge separation system.
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9 It was determined in MEPC 42/15/2 as well as the previously cited United Kingdom
MSA study that bilge separators tested to MEPC.60(33) requirements may not be effective over
the
full range of bilge conditions. Emulsions, heavy oils, and solids were among the causes sited for
unsatisfactory MEPC.60(33) separator performance and were what led to the development of the
MEPC.107(49) test standard.
10 The MEPC.107(49) testing protocol was designed to assure that bilge separators would
handle these various mixtures over a reasonable period of time (24-hour period) without operator
intervention, while maintaining discharge levels not exceeding 15 ppm as measured by testing
samples at a laboratory.
11 MEPC.60(33) complying separators have not been required to be tested on the test fluids of
emulsions, solids and in some cases heavy oil as is required in the MEPC.107(49) standard.
The effect of these bilge fluids on the performance of separators certified to MEPC.60(33) is
unknown. However, it is known that emulsions have an effect on the separation capabilities of
the
MEPC.60(33) separators; for example, those that utilize coalescing have difficulty separating oil
in
water emulsions and further these emulsions may affect the coalescers ability to coalesce free
oil
as well.
12 Additionally, these test fluids would be affected by passing though MEPC.60(33) separators
prior to entering those added-on separator components and the effect on the fluid properties such
as
droplet size, back pressures, velocities and other characteristics are not known. However, it is
well
known that those fluid properties that may be altered by passing through MEPC.60(33)
separators do
have an effect on the performance of MEPC.107(49) separator add-on upgrades. These effects
are
difficult or impracticable to simulate.
13 It is important to acknowledge the effects on the physical fluid properties at each stage of
a separation process. Resolution MEPC.107(49) recognizes these effects, stating the following
test
requirements:
From MEPC.107(49), part 1 TEST AND PERFORMANCE SPECIFICATIONS FOR
TYPE APPROVAL OF 15 PPM BILGE SEPARATORS
1.2.2 The influent, whether emulsified or non-emulsified, which the system has in practice
to deal with, depends on:
.1 the position of the oil/water interface, with respect to the suction point, in the
space being pumped;
.2 the type of pump used;
.3 the type and degree of closure of any control valve in the circuit; and
.4 the general size and configuration of the system.
Therefore the test rig must be so constructed as to include not only the 15 ppm Bilge
Separator, but also the pumps, valves, pipes and fittings as shown in Figure 2. It is to be so
designed for testing 15 ppm Bilge Separators with and without an integral supply pump.
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14 Nowhere in testing would it be more necessary to simulate the actual system configuration
(including equipment configuration) than in the testing of the complete bilge separator itself.
Interaction of existing equipment and upgrade modifications would need environmental and
inclined
operation testing because of interaction between the components.
15 The above factors lead to the conclusion that the best way to meet the intent of the new
regulations is by subjecting each combination of existing separator and any upgrade options to
a complete MEPC.107(49) test protocol.
Action requested of the Sub-Committee
16 The Sub-Committee is invited to consider the above comments, and agree that:
.1 the upgrading of existing equipment should include the incorporation of an oil
content meter complying with the current standard, resolution MEPC.107(49); and
.2 the test standard for existing equipment that is upgraded should be resolution
MEPC.107(49) and the complete bilge separation equipment (existing plus add-on)
should be tested and type approved.
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