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This page left blank intentionallyii A second approach is to conduct a full suite of TA testing on a BWMS with a "base filter" configuration. Then, a two-part approach would be followed: (1) A design study would be conducted, and (2) A reduced number of BE tests of the alternate filter as installed in the BWMS would be conducted at a USCG-approved independent laboratory (IL). This effort, however, iii would be reduced relative to that of full TA testing. Here, three land-based tests would be conducted, and O&M and component testing would also occur.If time or practicality does not allow the above scenarios to be implemented, a third option is available, although it is not recommended at this time. In this case, a design study would be completed, and it would be followed by testing to demonstrate equivalence of an alternate filter with the original filter. Here, a series of land-based performance tests would be conducted on the filter itself (not installed in the BWMS). Such performance testing would require the same rigor as US TA testing with respect to the quality assurance, testing protocol, and data reporting. A test protocol would be developed following a process similar to that used for the Environmental Technology Verification (ETV) Program Protocol for land-based and shipboard testing of BWMS, that is, by convening panels of experts. This approach could be shown to be as effective as the first two approaches, so it should be pursued.

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