Sampling of Bilgewater from a Bilgewater Treatment System
U.S. Environmental Protection Agency (EPA) issued a guide to provide vessel owners/operators with tips and tools for meeting the sample collection and analysis monitoring requirements in the 2013 VGP.
The document is written primarily to better educate vessel owners/operators who intend to conduct some or all of the sampling themselves rather than contracting these sampling activities to experienced third-party sampling service providers. However, EPA expects many vessel owners/operators will look to sampling service providers and laboratories to perform these activities for them and this document should serve as a resource for them as well.
Many NPDES permittees hire full-service “turnkey” operations to sample and analyze their discharges in lieu of building these capabilities in-house. Such service providers are currently available in many ports and EPA is aware that additional entities are considering offering similar services soon. When an owner/operator is not interested or unable to perform these sampling activities, use of a full-service provider is a viable alternative.
Vessel Required to Collect and Analyze Samples under the 2013 VGP |
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Finding a sampling service provider or an analytical laboratory
Since different laboratories offer different services, a vessel owner/operator will need to find an analytical laboratory capable of meeting the monitoring requirements specified in the permit before conducting the actual sample collection. In addition to analyzing the samples (or arranging to have them analyzed), some services will provide prepared sampling bottles and sampling gear, conduct the actual sampling, and complete any necessary paperwork and forms. Conversely, some laboratory services only include analysis of a sample delivered to their lab.
Finding the right sampling service provider and laboratory is similar to finding any other specialty service contractor in that you need to find entities that are capable of meeting all of your needs. Most commercial laboratories have websites that list their services and can be found through internet searches or word of mouth. The National Environmental Laboratory Accreditation Program (NELAP) maintains a list of about 1,500 laboratories.
NELAP also maintains a list of laboratories accredited through each of the 50 states; however, about 20 percent of states only list laboratories accredited for drinking water testing. The American Council of Independent Laboratories (ACIL) website also has a search function to find environmental laboratories by location.
Since some samples have short holding times between sample collection and analysis (i.e., less than a day in many instances), vessel owners/operators will need to consider the timing of sample collection to allow sufficient time for transport to the laboratory for analysis. Therefore, the physical location of the laboratory may be important because of the ability to arrange for sample pickup by laboratory personnel or a courier service.
How does my crew Collect, Pack, and Ship Samples? 1. Assemble all the necessary sampling equipment, materials, and supplies onsite. 2. Ensure that bottles are appropriately labeled (waterproof labels are best as they remain intact and legible). 3. Collect a discharge sample aliquot to perform any necessary field measurements (e.g., pH, free residual chlorine). Refer to the user manuals for the field test instruments to ensure proper use and maintenance of these meters. 4. Determine whether sodium thiosulfate (Na2S2O3) is needed for preservation due to the presence of chlorine in the sample and add to the sample bottles as appropriate. 5. Fill the sample bottles with the appropriate discharge samples. 6. If necessary, filter the sample for dissolved metals. See instructions for sample filtering in Section 3.3 below. 7. If the laboratory was unable to add preservation chemicals to each bottle, add any appropriate preservation chemicals at this point and test the pH or chlorine to ensure that the enough has been added. 8. Cool the samples on ice as dictated by the analytical methods. If the discharge water is hot to the touch, consider the need to allow samples to cool for a few minutes prior to placing in ice water to prevent shattering of the sample container or loss of the lid liner into the sample. 9. Repeat steps 2 through 9 if more than one discharge needs to be sampled. 10. Complete chain of custody forms. 11. Wrap glass sample bottles with “bubble wrap” and place all bottles (glass and plastic) in individually sealed zipper storage bag to contain liquids and preservation chemicals in case of shattering, punctures, or leaks. 12. Line the cooler with a large garbage bag to further ensure nothing leaks from the cooler. 13. Place sample bottles and a temperature blank upright in the garbage bag in the cooler and close bag with twist-tie. 14. Arrange sealed plastic freezer bags filled with ice (or chemical ice) on top of the sample bottles (if sample cooling is required for preservation) to maintain preservation temperature during shipping. 15. Place the completed chain of custody form in the cooler (retain a copy for your records). 16. Close cooler and secure with strapping tape to ensure that the lid will remain closed if the latch is accidentally released or damaged. Also tape the cooler drain plug closed so it will not open during shipment. 17. Place a custody seal on the cooler to verify the cooler has not been opened or tampered with during shipment and secure with clear tape to prevent loss during transport. |
Bilgewater/oily water separator effluent
Part 2.2.2 of the 2013 VGP requires owners/operators of new build vessels constructed on or after December 19, 2013 and greater than 400 gross tons that may discharge bilgewater into U.S. waters, to collect a sample of bilgewater effluent (discharge from the vessel after bilgewater treatment system) annually for analysis of oil and grease content by one of the following methods:
- EPA Method 1664; or
- ISO 9377-2 (2000) Water Quality–Determination of Hydrocarbon Oil Index–Part 2: Method Using Solvent Extraction and Gas Chromatography (incorporation by reference, see 46 CFR §162.050–4).
In addition, the 2013 VGP requires that a reading of the OCM be recorded at the time of sample collection so that the oil content measured by the laboratory can be compared to that measured by the OCM.
Graywater
Part 2.2.15.2 of the 2013 VGP specifies that new build vessels constructed on or after December 19, 2013 and with a maximum crew capacity greater than or equal to 15, and providing overnight accommodations to those crew are required to collect samples of graywater discharge for analysis. For these vessels, the 2013 VGP requires two samples a year3 to be collected, at least 14 days apart, and analyzed for the following:
• Biological Oxygen Demand (BOD)
• Fecal Coliform or E. coli
• Total suspended solids
• pH
• Total residual chlorine
The analyses must be conducted according to 40 CFR Part 136 methods and the results must be reported in the vessel’s Annual Report. Samples for fecal coliform or E. coli may be collected and analyzed only once per year if the owner/operator is having difficulties meeting the short holding times.
Residual Biocides from Ballast Water Treatment
Vessels subject to Part 2.2.3.5.1.1.1 of the 2013 VGP must conduct monitoring of the ballast water discharge for any residual biocides or derivatives used in the treatment process to demonstrate that residual biocides or derivatives are in compliance with this permit.
For more information please read the “Vessel Discharge Sample Collection & Analytical Monitoring” guide issued by U.S. EPA
Additional information:
[collapse title=”EPA Method 1664” collapseid=”UniqueID”]
EPA Method 1664 measures oil and grease content as Hexane Extractable Material (HEM), and also measures Silica Gel Treated N-Hexane Extractable Material (SGT-HEM). Both HEM and SGT-HEM samples are extracted using hexane, but for the SGT-HEM samples, the hexane extract undergos an additional silica gel treatment process to remove polar material, and therefore, measurements include only nonpolar material. The weight of extracted oil and grease after the solvent is evaporated is then reported. EPA Method 1664 is approved by EPA at 40 CFR Part 136 for measuring oil and grease under the Clean Water Act; therefore, EPA Method 1664 is routinely offered by commercial analytical laboratories in the United States.[/collapse]
[collapse title =”ISO Method 9377-2” collapseid=”UniqueID2″]
ISO Method 9377-2 runs a portion of the dried solvent extract through a gas chromatography instrument (reported as oil index).The ISO 9377-2 (2000) method is that specified by the US Coast Guard at 46 CFR 162.050-39 for measuring oil content in samples taken in approval testing of bilgewater separators, monitors, and alarms; this method is not commonly offered by US commercial analytical laboratories.
There is a disparity in costs between the two methods with ISO 9377-2 (2000) potentially costing five to ten times more than EPA Method 1664. However, the hydrocarbon oil index method may be more likely to produce results consistent with type approval testing. The vessel owner/operator can choose which method they wish to employ.
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Source and Image Credit: U.S. EPA
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