EPA/600/R-10/008 | January 2010 | www.epa.gov /nrmrl

Evaluation of Improved Type I

Marine Sanitation Devices

PERFORMANCE EVALUATION REPORT

Office of Research and Development

National Risk Management Research Laboratory - Water Supply and Water Resources Division
PERFORMANCE EVALUATION OF TYPE I 
 

MARINE SANITATION DEVICES 
 

by 


 

Eastern Research Group, Inc. 


 

14555 Avion Parkway, Suite 200 


 

Chantilly, VA 20151 


 

Contract No. EP-C-05-059 


 

Task Order No. 20 


 

for:


 


Raymond M. Frederick 


 

Task Order Manager 


 

U.S. Environmental Protection Agency 


 

Office of Research and Development 


 

National Risk Management Research Laboratory 


 

Water Supply & Water Resources Division 


 

Urban Watershed Management Branch (Edison, NJ 08837) 


 

Cincinnati, Ohio 45268 


 

EPA/600/R-10/008

January 2010
Performance Evaluation Report for Type I MSDs 

Notice 

The work reported in this document was funded by the U.S. Environmental Protection Agency 

(EPA) under Task Order (TO) No. 20 of Contract No. EP-C-05-059 to Eastern Research Group, 

Inc. The EPA, through its Office of Research and Development, funded and managed, or 

partially funded and collaborated in, the research described herein. This document has been 

subjected to the Agency’s peer and administrative review and has been approved for publication. 

Any opinions expressed in this report are those of the author(s) and do not necessarily reflect the 

views of the Agency; therefore, no official endorsement should be inferred. Any mention of trade 

names or commercial products does not constitute endorsement or recommendation for use. 

i 
Performance Evaluation Report for Type I MSDs 

Foreword 

The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the 

Nation’s land, air, and water resources. Under a mandate of national environmental laws, the 

Agency strives to formulate and implement actions leading to a compatible balance between 

human activities and the ability of natural systems to support and nurture life. To meet this 

mandate, EPA’s research program is providing data and technical support for solving 

environmental problems today and building a science knowledge base necessary to manage our 

ecological resources wisely, understand how pollutants affect our health, and prevent or reduce 

environmental risks in the future. 

The National Risk Management Research Laboratory (NRMRL) is the Agency’s center for 

investigation of technological and management approaches for preventing and reducing risks 

from pollution that threaten human health and the environment. The focus of the Laboratory’s 

research program is on methods and their cost-effectiveness for prevention and control of 

pollution to air, land, water, and subsurface resources; protection of water quality in public water 

systems; remediation of contaminated sites, sediments and ground water; prevention and control 

of indoor air pollution; and restoration of ecosystems. NRMRL collaborates with both public and 

private sector partners to foster technologies that reduce the cost of compliance and to anticipate 

emerging problems. NRMRL’s research provides solutions to environmental problems by: 

developing and promoting technologies that protect and improve the environment; advancing 

scientific and engineering information to support regulatory and policy decisions; and providing 

the technical support and information transfer to ensure implementation of environmental 

regulations and strategies at the national, state, and community levels. 

This publication has been produced as part of the Laboratory’s strategic long-term research plan. 

It is published and made available by EPA’s Office of Research and Development to assist the 

user community and to link researchers with their clients. 

 Sally Gutierrez, Director

 National Risk Management Research Laboratory 

ii 
Performance Evaluation Report for Type I MSDs 

Executive Summary 

Performance tests were conducted to evaluate the effectiveness of Type I Marine 

Sanitation Devices (MSDs) in reducing fecal coliform bacteria and visible floating solids (VFS). 

In addition, the performance evaluation described herein also included testing for enterococci 

and Escherichia coli (E. coli) indicators, biochemical oxygen demand (BOD5), total suspended 

solids (TSS), and nutrients (ammonia, total Kjeldahl nitrogen (TKN), nitrate/nitrite, and total 

phosphorous) in both influent to and effluent from the devices. Note that this testing was not 

performed for Type I MSD certification as both devices were already certified by the U.S. Coast 

Guard (USCG) to meet EPA performance standards at the time of testing. 

The Electro ScanTM Model EST 12, manufactured by Raritan Engineering Company, Inc., 

and the Thermopure-2 Model TP-210, by Gross Mechanical Laboratories, Inc., were selected for 

the performance tests because these manufacturers were willing to provide devices for testing, 

and the devices represented the range of technologies that were commercially available at the 

time of testing. Both devices use maceration to eliminate visible floating solids and disinfection 

to destroy pathogens. The Electro ScanTM device disinfects wastewater using chlorine generated 

from salt water, while the Thermopure-2 device disinfects wastewater using heat. 

The Electro ScanTM system consists of a two-chamber treatment tank, system status 

panel, control unit, liquid-crystal display (LCD), and an optional salt feed tank system that can 

be added for operation in fresh or brackish water. The system creates disinfectant from salt 

water. Flushing moves waste to the maceration chamber for particle size reduction. Subsequent 

flushing moves the waste to the oxidation chamber where it is mixed and brought into direct 

contact with electrode plates. When these plates are submerged in salt water and supplied with 

electricity, hypochlorous acid is formed, which then breaks down organic waste products by 

oxidation, including bacteria. The cycle runs for about two minutes in the second chamber, and 

the waste is held in the oxidation chamber until the next flushing cycle, then it is discharged. 

The Thermopure-2 system consists of three main components: the holding tank module, 

SweetTankTM aeration module, and the Thermopure treatment chamber. The unit is designed to 

be plumbed to either a toilet head or a preexisting remote holding tank, and all functions and 

operations in the unit are automatic. Treatment is accomplished by macerating the waste in the 

holding tank module, and then pumping it through the Thermopure treatment chamber where low 

level heat is introduced to eliminate bacteria. No chemicals or additives are required. In addition, 

iii 
Performance Evaluation Report for Type I MSDs 

the Thermopure-2 system does not require salt water to operate; therefore, it is equally efficient 

in fresh, brackish, or salt water. 

Performance Testing 

Performance testing was conducted using procedures for the Sewage Processing Test 

contained in the USCG’s MSD certification requirements at 33 CFR 159.121. One exception to 

the USCG’s Sewage Processing Test requirements is that, for reasons of practicality, testing was 

conducted using a feed of fresh domestic human sewage rather than human sewage in a ratio of 

four urinations to one defecation, as specified at 33 CFR 159.121(c). Furthermore, for this 

evaluation, testing was not limited to fecal coliform bacteria and visible floating solids measured 

in the treated effluent, but rather included a variety of analyses of both influent and effluent 

samples to measure the effectiveness of each treatment device and to characterize influent and 

effluent quality. 

The 10-day tests were performed at the Waco Metropolitan Area Regional Sewerage 

System test facility, beginning on April 9, 2007. The site provided a ready source of fresh 

wastewater and primary sludge as challenge wastewater for testing. An influent sample of the 

challenge wastewater was collected immediately prior to dosing the devices each day and 

analyzed for all parameters to characterize influent quality. 

MSDs were set-up, started, and operated, as closely as possible, to installation onboard a 

vessel and according to the devices’ operation manuals. Operational considerations included a 

tilting schedule, a salt-feed, and a cool-down time. The devices were tested for an 8-hour period 

over 10 days. Sampling personnel dosed each MSD with challenge wastewater at average 

loading levels throughout each day, with peak capacity wastewater doses three times each day. 

Sampling personnel collected effluent samples from the test devices at the beginning, middle, 

and end of each eight-hour period, with one additional sample taken following a peak dosing 

period each day, for a total of 4 samples per device per day. Effluent samples were analyzed to 

characterize effluent quality and performance efficiency. 

April 2007 Test Results 

The effluent produced by the Electro Scan device ranged from nondetect to >1,600 fecal 

coliform bacteria most probable number (MPN) per 100 mL with a mean concentration of 82 

MPN/100 mL. The effluent from the Thermopure-2 device ranged from nondetect to 30,000,000 

fecal coliform bacteria MPN/100 mL with a mean concentration of 4,500,000 MPN/100 mL. For 

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Performance Evaluation Report for Type I MSDs 

the Electro Scan device, 33 of the 40 samples had VFS less than or equal to 10% of TSS. The 

Thermopure-2 device had VFS less than or equal to 10% of TSS in 36 of the 38 samples. 

The Electro Scan device removed almost all pathogen indicators (99.99% or greater). In 

contrast, the Thermopure-2 device removed only half of the fecal coliform. The Thermopure-2 

device did not reach the designated threshold temperature sufficient enough to kill bacteria, 

which may have occurred due to the thermal sensor being misplaced, possibly during 

manufacturing or shipping. 

November/December 2007 Thermopure-2 Retest Results 

Because of problems encountered with the provided Thermopure-2 unit, a retest was 

conducted using a replacement Thermopure-2 unit. The scope of the retesting was reduced due to 

a limitation of funding. The duration of the performance testing was reduced from 10 days to 9 

days. Retesting dates were October 15 and 16, 2007, November 29 and 30, 2007, and 

December 3 through 7, 2007. (This resulted in another exception to USCG’s Sewage Processing 

Test requirements at 33 CFR 159.121(c) as testing was not at least 10 days within a 20-day 

period. Furthermore, USCG certification for the Thermopure-2 unit expired on November 6, 

2007.) The retesting was reduced to TSS testing of the challenge wastewater batch prepared each 

day, and testing of effluent samples for fecal coliform, VFS, BOD5, and TSS. 

There were 28 effluent samples collected during the November/December retesting 

period. The effluent produced by the Thermopure-2 device ranged from nondetect to 3,000,000 

fecal coliform bacteria MPN/100 mL with a mean concentration of 380,000 fecal coliform 

bacteria MPN/100 mL. Of the 28 samples, 26 had VFS less than or equal to 10 % of the effluent 

TSS. While these results show some improvement compared to the April testing, device 

performance remained poor. Although the cause of the poor performance is unknown, the device 

pump-out volume may have exceeded the capacity of the heating chamber, which would have 

mixed unheated (untreated) wastewater with treated wastewater during discharge. 

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Performance Evaluation Report for Type I MSDs 

TABLE OF CONTENTS
 

Page 

1.0 INTRODUCTION .................................................................................................................1-1 
 

1.1 Evaluation Objective............................................................................................1-1 
 

1.2 Evaluation Description.........................................................................................1-1 
 

2.0 TECHNOLOGY DESCRIPTIONS AND SPECIFICATIONS..........................................................2-1 
 

2.1 Electro Scan .........................................................................................................2-1 
 

2.1.1 Description...............................................................................................2-1 
 

2.2 Specifications.......................................................................................................2-2 
 

2.3 Thermopure-2 ......................................................................................................2-6 
 

2.3.1 Description...............................................................................................2-6 
 

2.3.2 Specifications...........................................................................................2-7 
 

3.0 PERFORMANCE EVALUATION TESTING PROCEDURES .......................................................3-1 
 

3.1 Test Facility .........................................................................................................3-1 
 

3.2 Device Installation ...............................................................................................3-1 
 

3.3 Start-Up Testing...................................................................................................3-3 
 

3.4 Sewage Processing Test.......................................................................................3-4 
 

3.4.1 Wastewater Dosing Schedules.................................................................3-4 
 

3.4.2 Challenge Wastewater .............................................................................3-5 
 

3.5 MSD Operation and Maintenance .......................................................................3-6 
 

3.6 Sample Collection................................................................................................3-9 
 

3.7 Process Monitoring ............................................................................................3-11 
 

3.8 Field Quality Control (QC) Measures................................................................3-11 
 

3.9 Deviations from the Work Plan .........................................................................3-12 
 

4.0 TEST RESULTS AND DISCUSSION.......................................................................................4-1 
 

4.1 Fecal Coliform and Visible Floating Solids.........................................................4-1 
 

4.1.1 Fecal Coliform .........................................................................................4-1 
 

4.1.2 Visible Floating Solids.............................................................................4-2 
 

4.2 Other Analyses.....................................................................................................4-3 
 

4.2.1 Pathogen Indicators E. Coli and Enterococci ..........................................4-3 
 

4.2.2 Biochemical Oxygen Demand and Total Suspended Solids....................4-4 
 

4.2.3 Nutrients...................................................................................................4-4 
 

4.2.4 Process Monitoring ..................................................................................4-5 
 

4.3 Type I MSD Performance....................................................................................4-5 
 

5.0 THERMOPURE-2 RETEST ...................................................................................................5-1 
 

5.1 Performance Evaluation Retesting Procedures....................................................5-1 
 

5.2 Retest Results and Discussion .............................................................................5-4 
 

5.2.1 Fecal Coliform .........................................................................................5-4 
 

5.2.2 Visible Floating Solids.............................................................................5-5 
 

5.2.3 Biochemical Oxygen Demand and Total Suspended Solids....................5-5 
 

5.2.4 Process Monitoring ..................................................................................5-5 
 

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Performance Evaluation Report for Type I MSDs 

TABLE OF CONTENTS (Continued) 

Page 

6.0 DATA QUALITY.................................................................................................................6-1 
 

6.1 Analytical QC ......................................................................................................6-1 
 

6.2 Field QC...............................................................................................................6-2 
 

6.2.1 Equipment Blanks....................................................................................6-2 
 

6.2.2 Field Duplicates .......................................................................................6-3 
 

6.3 Testing Audit .......................................................................................................6-4 
 

7.0 MANUFACTURER RESPONSE .............................................................................................7-1 
 

7.1 Raritan Engineering Company, Inc......................................................................7-1 
 

7.2 Gross Mechanical Laboratories, Inc. ...................................................................7-3 
 

Appendix A: 33 CFR 159 EXCERPTS 

Appendix B: CHALLENGE WASTEWATER DOSING SCHEDULE 

Appendix C: AUDIT REPORT FOR TYPE I MSD TESTING 

vii 
Performance Evaluation Report for Type I MSDs 

LIST OF TABLES
 


Page 

3-1 Influent TSS Results ........................................................................................................ 3-6 
 


3-2 Methods, Sample Volume, Preservatives, and Holding Time ....................................... 3-10 
 

4-1 Fecal Coliform - Electro Scan.......................................................................................... 4-7 
 

4-2 Visible Floating Solids - Electro Scan............................................................................. 4-8 
 

4-3 Escherichia coli - Electro Scan........................................................................................ 4-9 
 

4-4 Enterococci - Electro Scan............................................................................................. 4-10
 


4-5 Biochemical Oxygen Demand (5 day) - Electro Scan................................................... 4-11 
 

4-6 Total Suspended Solids - Electro Scan .......................................................................... 4-12 
 

4-7 Ammonia as Nitrogen - Electro Scan ............................................................................ 4-13 
 

4-8 Total Kjeldahl Nitrogen - Electro Scan ......................................................................... 4-14 
 

4-9 Nitrate/Nitrite as Nitrogen - Electro Scan...................................................................... 4-15 
 

4-10 Total Phosphorus - Electro Scan.................................................................................... 4-16 
 

4-11 pH - Electro Scan........................................................................................................... 4-17 
 

4-12 Temperature - Electro Scan ........................................................................................... 4-18 
 

4-13 Conductivity - Electro Scan........................................................................................... 4-19
 


4-14 Chlorine Residual - Electro Scan................................................................................... 4-20 
 

4-15 Fecal Coliform - Thermopure-2..................................................................................... 4-21 
 

4-16 Visible Floating Solids - Thermopure-2 ........................................................................ 4-22 
 

4-17 Escherichia coli - Thermopure-2................................................................................... 4-23 
 

4-18 Enterococci - Thermopure-2.......................................................................................... 4-24 
 

4-19 Biochemical Oxygen Demand (5 day) - Thermopure-2 ................................................ 4-25 
 

4-20 Total Suspended Solids - Thermopure-2 ....................................................................... 4-26 
 

4-21 Ammonia as Nitrogen - Thermopure-2.......................................................................... 4-27 
 

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Performance Evaluation Report for Type I MSDs 

LIST OF TABLES (Continued) 

Page 

4-22 Total Kjeldahl Nitrogen - Thermopure-2....................................................................... 4-28 
 

4-23 Nitrate/Nitrite as Nitrogen - Thermopure-2................................................................... 4-29 
 

4-24 Total Phosphorus - Thermopure-2................................................................................. 4-30 
 

4-25 pH - Thermopure-2 ........................................................................................................ 4-31 
 

4-26 Temperature – Thermopure-2........................................................................................ 4-32 
 

4-27 Summary of Type I MSD Performance......................................................................... 4-33 
 

5-1 Influent TSS Results – Theromopure-2 Retest ................................................................ 5-3 
 

5-2 Fecal Coliform - Thermopure-2 Retest............................................................................ 5-7 
 

5-3 Visible Floating Solids - Thermopure-2 Retest ............................................................... 5-8 
 

5-4 Biochemical Oxygen Demand (5 day) - Thermopure-2 Retest ....................................... 5-9 
 

5-5 Total Suspended Solids - Thermopure-2 Retest ............................................................ 5-10 
 

5-6 pH - Thermopure-2 Retest ............................................................................................. 5-11 
 

5-7 Temperature – Thermopure-2 Retest............................................................................. 5-12 
 

6-1 Equipment Blank Results................................................................................................. 6-5
 


6-2 Field Duplicate Analytical Results .................................................................................. 6-6 
 

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Performance Evaluation Report for Type I MSDs 

LIST OF FIGURES
 


Page 

2-1 Internal Components of the Electro Scan Treatment Tank.............................................. 2-1 
 

2-2 Electrical Hookup of Electro Scan Components ............................................................. 2-5 
 

2-3 Example Installation for Thermopure-2........................................................................... 2-6 
 

2-4 SweetTankTM Setup ......................................................................................................... 2-7 
 

2-5 Electrical Hookup for Thermopure-2............................................................................... 2-8 
 

3-1 Thermopure-2 and Electro Scan Installation ................................................................... 3-1 
 

3-2 Tilting Mechanism for MSDs .......................................................................................... 3-2 
 

3-3 Schematic Diagram of Sampling Points .......................................................................... 3-9 
 

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Performance Evaluation Report for Type I MSDs 

1.0 INTRODUCTION 

1.1 Evaluation Objective 

This performance test was designed to evaluate the effectiveness of two Type I Marine 

Sanitation Devices (MSDs): the Electro Scan Model EST 12, manufactured by Raritan 

Engineering Company, Inc., and the Thermopure-2, manufactured by Gross Mechanical 

Laboratories, Inc. Performance tests were conducted to evaluate the effectiveness of Type I 

MSDs in reducing fecal coliform bacteria and visible floating solids (VFS). In addition, the 

performance evaluation described herein also included testing for enterococci and Escherichia 

coli (E. coli) indicators, biochemical oxygen demand (BOD5), total suspended solids (TSS), and 

nutrients (ammonia, total Kjeldahl nitrogen (TKN), nitrate/nitrite, and total phosphorous) in both 

influent to and effluent from the devices. 

The performance evaluation tests were conducted under the direction of EPA through the 

support of Eastern Research Group, Inc. (ERG) and ERG’s subcontractor, NSF International 

(NSF). The purpose of this report is to provide objective performance data on these technologies 

so that consumers, developers, and regulators can make informed decisions about purchasing and 

applying the technology in these products. 

1.2 Evaluation Description 

A Type I MSD is a flow-through system designed for vessels of 65 feet or less in length, 

with capability for maceration and disinfection of waste prior to discharge. The Type I MSDs 

underwent performance evaluation testing using procedures for the Sewage Processing Test 

contained in the USCG’s MSD certification requirements at 33 CFR 159.121 (see Appendix A). 

One exception is that, for reasons of practicality, testing was conducted using a feed of fresh 

domestic human sewage rather than human sewage in a ratio of four urinations to one defecation, 

as specified at 33 CFR 159.121(c). Furthermore, for this evaluation, testing was not limited to 

fecal coliform bacteria and visible floating solids measured in the treated effluent, but rather 

included a variety of analyses of both influent and effluent samples to measure the effectiveness 

of each treatment device and to characterize influent and effluent quality. Note that this testing 

was not performed for Type I MSD certification as both devices were already certified by the 

USCG to meet EPA performance standards at the time of testing. 

Because of problems encountered with the provided Thermopure-2 unit, a retest was 

conducted using a replacement Thermopure-2 unit. The scope of the retesting was reduced due to 

1-1
 

Performance Evaluation Report for Type I MSDs 

a limitation of funding. The duration of the performance testing was reduced from 10 days to 9 

days. Retesting dates were October 15 and 16, 2007, November 29 and 30, 2007, and 

December 3 through 7, 2007. (This resulted in another exception to USCG’s Sewage Processing 

Test requirements at 33 CFR 159.121(c) as testing was not at least 10 days within a 20-day 

period. Furthermore, USCG certification for the Thermopure-2 unit expired on November 6, 

2007.) The retesting was reduced to TSS testing of the challenge wastewater batch prepared each 

day, and testing of effluent samples for fecal coliform, VFS, BOD5, and TSS. 

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Performance Evaluation Report for Type I MSDs 

2.0 TECHNOLOGY DESCRIPTIONS AND SPECIFICATIONS 

2.1 Electro Scan 

2.1.1 Description 

Electro Scan (Figure 2-1) is a USCG-approved Type I MSD manufactured by Raritan 

Engineering Company, Inc. The system consists of a two-chamber treatment tank, system status 

panel, control unit, LCD, and an optional salt feed tank system that can be added for operation in 

fresh or brackish water. The device is designed for use on vessels 65 feet or less in length and 

accommodates most existing marine toilets. The device creates disinfectant from salt water. 

Source: Raritan Engineering Company, Inc 

Figure 2-1. Internal Components of the Electro Scan Treatment Tank 

Flushing moves waste to the maceration chamber for particle size reduction. Subsequent 

flushing moves the waste to the oxidation chamber where it is mixed and brought into direct 

contact with electrode plates. When these plates are submerged in salt water and supplied with 

electricity, hypochlorous acid is formed, which then breaks down organic waste products, 

including bacteria, by oxidation. The cycle runs for approximately two minutes in the second 

chamber, and the waste is held in the oxidation chamber until the next flushing cycle, then it is 

discharged. 

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Performance Evaluation Report for Type I MSDs 

2.2	 Specifications 

The Electro Scan has three models, EST12, EST24, and EST32, each with different volts 

of direct current as represented by the numbers in each model name. The EST 12 model was 

selected for performance testing. The main component of the system is the 3-gallon, or 11.4-L, 

treatment tank with dimensions of 13.5 x 9.25 x 16 inches (in.). The treatment tank is divided 

into two 1.5 gallon chambers. The dividing partition contains an electrode pack with electrodes 

protruding into each chamber. The first chamber, containing the macerator, reduces the sewage 

into tiny particles. Salt water used in the flush activates the electrode in the first chamber, which 

produces the disinfectant that treats the sewage. During subsequent flushes, the macerated 

sewage flows up and over the partition into the second chamber via a cross-over pipe. Because of 

this design, any settled solids remain in the first chamber for continued maceration and 

treatment. The second chamber continuously mixes the waste as the second set of electrodes 

continues waste disinfection. According to Raritan, the treatment tank holds about four flushes, 

averaging 0.75 gallons per flush. Therefore, the waste undergoes approximately four treatment 

cycles before being discharged. A complete treatment cycle lasts about 3.75 minutes. 

The following are the chemical reactions that occur in the treatment chambers: 

1.	 The process starts with salt water in the treatment tank. Sodium chloride (NaCl) is 

a strong electrolyte that exists in salt water as sodium (Na+) and chloride (Cl-) 

ions. 

­ NaCl --> Na+

 + Cl

2.	 Through hydrolysis, water (H2O) breaks into hydrogen (H+

) ions and hydroxyl 

(OH-

) ions. 

H2O --> H+ + OH2-2
 

Performance Evaluation Report for Type I MSDs 

3.	 The electrode pack is energized at the anode during the treatment cycle, and 

electricity passes through the conductive salt water. Hydrochloric acid (HCL), and 

hypochlorous acid (HOCL), a powerful bactericide and oxidizing agent, and are 

produced on the surface of the plates, liberating two electrons (e-

). 

­ 2Cl- + OH- + H+

 --> HCl + HOCl + 2e

4.	 At the cathode, the two electrons, hydrogen ions, sodium ions and hydroxyl ions 

combine to produce sodium hydroxide (NaOH) and some hydrogen. 

2e- + 2H+ + 2Na+ + 2OH- --> 2 NaOH + H2↑

5.	 The net reaction is: 

2Cl- + 3OH- + 3H+

 + 2Na+ --> HCl + HOCl + 2NaOH + H2↑

6.	 Hypochlorous acid is formed when sodium hypochlorite (NaOCl) reacts with 

water. 

NaOCl + H2O --> NaOH + HOCl 

7.	 Hypochlorous acid reacts with contaminants (e.g., soil, dirt, and bacteria) giving 

up its oxygen; leaving hydrochloric acid. 

HOCl + contaminants --> HCl + contaminants Ox 

8.	 The hydrochloric acid reacts with the sodium hydroxide to form sodium chloride 

and water. 

HCl + NaOH --> H2O + NaCl 

Another component of this device is a credit-card-sized system status panel (Figure 2-2), 

which contains a touch pad button for starting the treatment cycle and labeled light-emitting 

diode (LED) indicators to show proper operation or the nature of a possible fault. When installed 

with an electric toilet, flushing the toilet initiates waste treatment as a one-touch operation. When 

installed with a manually operated toilet (hand pump type), an optional pump sensor kit can be 

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Performance Evaluation Report for Type I MSDs 

installed at the toilet, which is wired to, and automatically activates, the Electro Scan treatment 

process. 

The control module (Figure 2-2), containing two boards, serves as the system’s central 

control. The main microprocessor/memory board contains system programming, logic circuitry, 

treatment monitoring, and operational data storage. The second board is an input/output 

component that allows the user to make connections to accessories. Power switching solenoids, 

fuse protection, and a leaf shunt to measure the current flowing through the electrodes are builtin. 

The LCD display unit (Figure 2-2) is the new feature of the system, which distinguishes 

the EST 12 model from the older generation Lectra/San device. The display provides the user 

with information regarding the treatment cycle, such as voltage status, and historical data 

regarding the use of the system. It also contains a reset button if a system error occurs. 

Finally, there is an optional salt feed tank, which is used when the boat is operating in 

freshwater or brackish waters. The feed tank is available in three models: 2 gallon (7.6 L) tank, 4 

gallon (15.2 L) tank, and a 4 gallon (15.2 L) tank with automatic water refill and salt water 

injection. Standard table salt is used to make the salt solution, and this salt water is metered to 

the suction line of the toilet or injected directly into the treatment tank. The standard formula for 

making salt water is 4.6 ounces (oz) of non-iodized salt per gallon of water. 

2-4
 

Performance Evaluation Report for Type I MSDs 

Source: Raritan Engineering Company, Inc 

Figure 2-2. Electrical Hookup of Electro Scan Components 

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Performance Evaluation Report for Type I MSDs 

2.3 Thermopure-2 

2.3.1 Description 

At the time of the April 2007 performance test, the Thermopure-2 (Figure 2-3) was a 

USCG-approved Type I MSD manufactured by Gross Mechanical Laboratories, Inc. At the time 

of the November/December retesting, the Thermopure-2 was not longer USCG-approved as the 

USCG certification expired on November 6, 2007. The system consists of three main 

components: The holding tank module, SweetTankTM aeration module, and the Thermopure-2 

treatment chamber. The device is designed to be plumbed to either a toilet head or a preexisting 

remote holding tank, and all functions and operations in the device are automatic. 

Source: Gross Mechanical Laboratories, Inc 

Figure 2-3. Example Installation for Thermopure-2 

Treatment is accomplished by macerating the waste in the holding tank module and then 

pumping it thought the Thermopure-2 treatment chamber where low-level heat is introduced to 

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Performance Evaluation Report for Type I MSDs 

eliminate bacteria. No chemicals or additives are required. In addition, the Thermopure-2 device 

does not require salt water to operate, so it is equally efficient in fresh or brackish water. 

2.3.2 Specifications 

The Thermopure-2 device is available in four models: TP-210, TP-215, TP-220, and TP230. The last two digits of the model name represent the different sizes of holding tank capacity 

in gallons. The TP-210 model was selected for performance testing. 

For the Thermopure-2 device, wastewater enters a holding tank module as the toilet is 

flushed, where it is macerated. (For installations with a remote holding tank, waste is pulled into 

the Thermopure-2 holding tank module and treated in a series of batches). When wastewater 

enters the holding tank module, the SweetTank Odor Neutralization SystemTM also begins 

working. The SweetTankTM (Figure 2-4) is a unit that was developed to eliminate odors in 

holding tanks without the use of chemicals or filters. Instead, SweetTankTM induces a constant 

flow of air into the holding tank module through a submerged aeration tube, producing an 

oxygen-rich environment in which anaerobic bacteria cannot thrive, thus eliminating odors. The 

air is released though a lateral ventilation system on either side of the boat. 

Source: Gross Mechanical Laboratories, Inc 

Figure 2-4. SweetTankTM Setup 

Whenever macerated wastewater is detected in the holding tank module and the 

macerator has operated for a set amount of time, the treatment system pumps the batch of 

wastewater from the treatment chamber into the Thermopure-2 chamber where heat is applied to 

the wastewater to eliminate bacteria. (Gross Mechanical Laboratories, Inc. representatives did 

not provide the length of maceration time or operating temperature of the device.) If the two 

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Performance Evaluation Report for Type I MSDs 

modules are not at the same height, the device will not pump properly and will require the 

installation of a HVL-750 3/4 in. Vented Loop, which is sold separately. After a treatment cycle, 

the treated waste is then pumped overboard. 

When no wastewater is detected in the holding tank module, the device automatically 

enters stand-by mode. However, when the holding tank module is close to full, use of the toilets 

must stop as additional flushing will overflow the device. 

The treatment unit also has an operation panel (Figure 2-5), which gives the user 

information about the system. At 10% capacity, a yellow light on the panel indicates the 

initiation of treatment and discharge, assuming the system is already at adequate temperatures. 

At 75% capacity, a flashing yellow light and audible alarm goes off to warn users the system is 

close to maximum capacity. Other functions of the panel includes alternating current (AC) and 

direct current (DC) power “on” indicators, a system failure alarm, a hold switch that disables the 

system temporarily, and a mute button. Lastly, a flush kit is installed after the treatment unit 

which facilitates winterization and maintenance, and provides an access port to clear blockages, 

should one occur. 

Source: Gross Mechanical Laboratories, Inc 

Figure 2-5. Electrical Hookup for Thermopure-2 

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Performance Evaluation Report for Type I MSDs 

Warm-up time for the device (measured from the time AC power is first applied to when 

the device is ready to treat and discharge) is approximately six minutes at 15 amperes (A) of AC 

power. The use of the pumps in the system is an additional 16 A of DC power. During periods of 

time when the system is on stand-by, 150 milliamperes (mA) of DC circuit power is used. 

2-9
 

 

Electro Scan device is in the foreground and Thermopure-2 device is in the background. Dosing system shown in 

upper left and effluent receiving tanks in lower right. 

Performance Evaluation Report for Type I MSDs 

3.0 PERFORMANCE EVALUATION TESTING PROCEDURES 

3.1 Test Facility 

NSF conducted the performance tests at its Waco, Texas test facility, located at the Waco 

Metropolitan Area Regional Sewerage System (WMARSS) treatment facility.1

 The site provided 

a ready source of fresh wastewater and primary sludge to provide a challenge wastewater for 

testing. 

3.2 Device Installation 

NSF test-site personnel reviewed the documentation for the two devices to determine the 

best approach for setup and testing of the systems. The size of the two devices allowed them to 

be installed in a manner convenient for dosing and sampling. As shown in Figure 3-1, the 

devices were installed on plywood platforms, taking into account the configuration indicated in 

the manufacturers’ literature. 

Figure 3-1. Thermopure-2 and Electro Scan Installation 

1

 NSF’s facility located in Ann Arbor, Michigan is currently accepted by the USCG as a Recognized Facility for the 

evaluation, inspected, and testing of marine sanitation devices under 33 CFR 159.15. However, NSF’s Waco, Texas 

and Aqua-Tech Laboratories, Inc. subfacility currently is not accepted as a Recognized Facility by the USCG. 

3-1
 
Performance Evaluation Report for Type I MSDs 

The devices were anchored to the platform to accommodate tilting during testing to an 

angle of 30o from the horizontal along one side of the devices (specified by both manufacturers 

as maximum roll/pitch angle). Hinges were installed in the middle of the platform in both the 

length and width directions to permit pivoting of the equipment to the required angle. With this 

platform, tilting of the equipment could be performed along the edges of each device over the 

course of the testing. The tilt angles were pre-set, but were also verified during each tilt event 

using an inclinometer. Figure 3-2 shows the devices during testing in the tilted position. 

Figure 3-2. Tilting Mechanism for MSDs 

Dosing was accomplished through use of infrastructure dedicated to each test device. 

Each test device had a separate dosing pump, dosing manifold, programmable electronic timer, 

dosing bucket, motorized ball valve, return flow line and dose counter in place to allow dosing 

on separate test schedule intervals and dosing volumes as determined by the overall test 

schedule. In each dosing sequence event, the timer closed the drain valve, activated the dosing 

pump, and ran the pump for a set run time to allow complete volume dosing for each dosing 

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Performance Evaluation Report for Type I MSDs 

bucket and then turned off the pump. Each bucket was calibrated before implementing the test 

(including the volume of pipe and valve) to ensure an exact volume for each dosing event. The 

excess dose water overflow pumped to each device for dosing was allowed to flow as gravity 

return flow to the batch tank. After a set period to allow the water level to equilibrate, the timer 

activated the drain valve allowing the dose to gravity flow to the respective test device. The 

Electro Scan device required a separate input signal from the timer used to control dosing 

through a 12 VDC converter, since the dosing would not be from an actual toilet input. The 

Thermopure-2 device, operating off the liquid level in the holding tank, required no special 

interface with the control panel. 

Each device also had a separate 10-gallon polyethylene effluent receiving container. 

Treated effluent accumulated in the receiving containers to ensure a sufficient effluent volume 

for sampling analysis. The effluent receiving containers were emptied, decontaminated, and 

returned to service following collection of each effluent sample. 

3.3 Start-Up Testing 

A trial run of the devices was completed prior to the start of sewage processing to ensure 

everything was operating properly. The testing included preparing the challenge wastewater and 

following the start-up instructions provided by the manufacturers. 

Electro Scan Device 

The Electro Scan device was filled with salt water per the manufacturer’s instructions and 

placed into operation. No leaks were found, measures for voltage and amperage to the device 

were found appropriate, and the device was placed into operation. The control panel fuse burned 

out after two cycles of operation and the wire size was changed to address the matter. The 

change did not remedy the problem, as the control panel indicated “low amp error,” which 

prompted site personnel to talk with the manufacturer. It was intended to use a 110 VAC/12 

VDC converter (manufacturer’s manual indicated that an unfiltered power supply was needed), 

but discussion with the manufacturer indicted that the batteries were needed to provide a pure 

power supply. Four 850 cranking amp automobile batteries were used for the power supply, 

which prevented the error message over each eight-hour test period. The device was then deemed 

to be in proper operation for sewage processing. 

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Performance Evaluation Report for Type I MSDs 

Thermopure-2 Device 

The Thermopure-2 device was filled to 10% of the holding tank volume with fresh water. 

The start-up procedures provided in the manufacturer’s literature were followed, and the device 

was found to be ready for testing. However, when the trial run with wastewater was completed, 

two leaks were found in the tank top. The first was a leak at the interface of the holding tank and 

the plate holding the macerator pump. The cap nuts used to secure the plate to the tank were 

tightened to compress the rubber gasket between the tank and plate, but the leak was not stopped, 

possibly from an uneven mold or bad seam. The second leak was from a thermally-welded 

adapter for the pump-out fitting. A replacement tank, which was found to be free of leaks, was 

provided by the manufacturer and placed into operation. 

3.4 Sewage Processing Test 

The sewage processing test was performed in accordance with 33 CFR 159.121, except 

testing was conducted using a feed of fresh domestic human sewage rather than human sewage 

in a ratio of four urinations to one defecation, as specified at 33 CFR 159.121(c), for reasons of 

practicality. Testing was performed over an eight-hour period for 10 days (five week days per 

week for two consecutive weeks). During this period, the MSDs were challenged with 

wastewater at the average loading flow, with three periods of each day of the MSDs processing 

waste at the peak capacity. The testing dates were April 9 through 13, 2007, and April 16 

through 20, 2007. The MSDs were tilted to an angle of 30° for a one-hour period each day. 

3.4.1 Wastewater Dosing Schedules 

Electro Scan Device 

The peak flow process designated by Raritan is 1 gallon flush of wastewater every six 

minutes and a 30-minute cool-down period after every four to five flushes. This averages to a 

peak flow of 40 gallons in an eight-hour day. Flushing wastewater through the device at a faster 

rate than the suggested peak flow would result in the discharge of untreated or partially treated 

wastewater, as the device has no failsafe to prevent such discharge. The off-peak (average) 

process flow was based on the assumption of four passengers each using the toilet five times in 

an eight-hour day. This resulted in the off-peak flow of 20 gallons in an eight-hour day, which 

was the average loading flow that was used during certification of the device. The dosing 

schedule allowed six minutes for processing each flush, with five cycles before a 30-minute 

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Performance Evaluation Report for Type I MSDs 

cool-down period, as mentioned above. The total daily volume processed was approximately 28 

gallons. The wastewater dosing schedule for the Electro Scan is included in Appendix B. The 

Electro Scan device was dosed daily with 28, 1-gallon doses over the entire 10-day test period. 

Thermopure-2 Device 

As indicated in the technology description, the Thermopure-2 device dosing pattern was 

designed based on an assumed challenge wastewater temperature of 68° Fahrenheit (20° 

Celsius). At this temperature, the peak flow rate was 50 gallons per eight-hour day or about 1 

gallon every 10 minutes. The off peak (average) process flow was based on an assumption of 

four passengers each using the toilet five times in an eight-hour day. This resulted in the off-peak 

flow of 20 gallons in an eight-hour day or 1 gallon of wastewater every 24 minutes. The total 

daily volume of wastewater processed was approximately 32 gallons. The wastewater dosing 

schedule for the Thermopure-2 device is also included in Appendix B. The Thermopure-2 device 

was dosed daily with 32, 1-gallon doses for nine of the 10-day test period. On days two (4/10) 

and seven (4/17), the device received 28 and 14 doses, respectively, because of operational 

problems with the device (see Section 3.5). 

3.4.2 Challenge Wastewater 

A single batch of challenge water was mixed each morning in a 300 gallon batch tank, 

approximately 30 minutes ahead of initial dosing. A 1/3 horsepower circulating pump, used to 

minimize solids settling in the batch tank, was turned on and allowed to run during the 30-minute 

setup period before initial dosing, and continued operating throughout the day until dosing was 

discontinued. In order to achieve the target 500 mg/L TSS minimum influent, trial runs 

bracketing the ratio of primary sludge solids to raw influent ahead of testing indicated an 

approximate ratio of 1/3 primary sludge to 2/3 raw wastewater. Raw influent was pumped 

directly into the batch tank from a drawoff point just after the raw water inlet screen to the Waco 

plant. The primary sludge solids were added to the batch tank using a hose attached to a pressure 

fitting in the primary sludge line from the primary clarifiers to the plant digester. The batch tank 

contained a predetermined volume level that was marked on the tank to which the tank was filled 

with return solids flow from the raw water pump to achieve the target volume for TSS 

concentration. 

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Performance Evaluation Report for Type I MSDs 

Variations in the primary sludge solids concentrations accounted for variations in the 

challenge water TSS concentration encountered during the testing. The batch was made daily 

based on the best estimate of the site personnel to meet the targeted 500 mg/L concentration; 

however, the actual concentration each day was determined after the dosing was completed. As 

shown in Table 3-1, the influent TSS concentrations during the testing ranged from 420 mg/L to 

more than 12,000 mg/L. The average influent TSS concentration over the course of the test was 

2,500 mg/L with a standard deviation of ±3,600 mg/L. 

Table 3-1. Influent TSS Results 

Date Influent TSS (mg/L) 

4/9/07 4,000 

4/10/07 12,000 

4/11/07 1,100 

4/12/07 720 

4/13/07 420 

4/16/07 1,100 

4/17/07 740 

4/18/07 500 

4/19/07 450 

4/20/07 3,300 

3.5 MSD Operation and Maintenance 

Electro Scan Device 

There was no routine maintenance required during the testing, as treatment/electrode 

cleaning is recommended every six months. The device was flushed with two doses of fresh 

water prior to the weekend following the first five days of testing. The power and salt feed 

device were turned off for the weekend and restarted on the following Monday. The same 

process was followed at the end of testing. 

The four-gallon salt feed tank was used for the testing. The manual instructions for the 

salt tank indicated that the tank be filled with up to 10 pounds of solar salt, which would mix 

with a fresh water supply to provide about a 3% salt solution for injection into the device. While 

it was not possible to record the amount of salt water actually injected into the device, the 

amount of solar salt added to the tank was recorded over the 10 days of the test. Over the course 

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Performance Evaluation Report for Type I MSDs 

of the testing, including the trial run prior to the start of the test, a total of 39 pounds of solar salt 

was added to the salt tank. 

Operationally, maintenance was provided several days during the test: 

y	 	 Day eight – An error message on the control panel (MAC MOTOR OVERLD) occurred. 

NSF site personnel removed the macerator motor screws to access the macerator shaft 

and turned the shaft by hand to free it up. The motor was returned to service with no 

further messages. An error message (ELECTROD OVERLD) on the control panel was 

investigated, including wiring checks. The power was turned off then back on, and the 

panel returned to the normal status of “Ready to Flush.” The problem may have been 

related to the salt concentration in the device. 

y	 	 Day nine – An error message (LOW ELECTRODE AMPS) appeared on the control 

panel, indicating that the salt in the salt tank should be checked. A visual check of the 

tank found the salt dosing pump running continuously. The device was reset by shutting 

off the water and power to the pump, then restarting. The warning was repeated during 

the day, with about 10 pounds of salt being added to the tank over the course of the day. 

For the latter part of the day, the power to the pump had to be disconnected between 

doses to keep it from running continuously and getting control panel operational errors. 

At the end of the day, power was reset to the control panel and the salt tank was cleaned, 

flushed, and restocked with salt for the next day. The device operated as it had prior to 

the problems on day nine. 

Thermopure-2 Device 

The only routine maintenance required during the testing was weekly flushing of the 

device, which was completed on Friday of each week. This maintenance involved filling the 

holding tank to 75% capacity with fresh water and allowing the device to process normally. 

Operationally, maintenance was provided several days during the test: 

y	 	 Day two – The device was not pumping out effluent, with the tank filling the holding 

tank, and the 10% and 75% alarm lights and audible alarm activating. All electrical 

connections were checked; however, the fuse blew three times. The emergency discharge 

button was actuated and the pump could be heard running, but still with no discharge. 

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Performance Evaluation Report for Type I MSDs 

The device was shut down, missing four doses, and the pump assembly was replaced, 

which corrected the problem. Disassembly of the failed pump revealed that the retaining 

bolt securing the impeller to the pump shaft had come out, allowing the pump shaft to 

turn without turning the impeller. 

y	 	 Day four – When the device was tilted (to 30o) the audible alarm sounded and the 10% 

and 75% warning lights blinked. No cause was found for this condition, and the alarms 

stopped after about 20 minutes following the device being returned to the upright 

position. The heater light also did not light during this time. 

y	 	 Day six – The air compressor provided with the Sweet Tank component began making a 

rattling noise, which was resolved by removing the retainer clip and allowing the 

compressor to hang by the plastic air line and wiring. The compressor operated without 

noise for the remainder of the test. 

y	 	 Day seven – The same condition of warning alarm and alarm lights occurred and no 

discharge was occurring from the device. All electrical was checked and floats cleaned, 

per manual. The manual pump-out worked, but when dosing was resumed, the tank once 

again filled with no discharge. Dosing was discontinued and the manufacturer contacted. 

Site personnel, working with the manufacturer, determined that the thermal switch in the 

device was open, not allowing for discharge from the device. The final solution was to 

jumper across contacts for the switch to keep the testing going. This was successful, 

although eighteen doses and two effluent samples were lost because of the problem. 

y	 	 Day eight – It was observed that the device did not heat when tilted to one of the four 

directions (three o’clock position). Also on that day, effluent was observed spraying out 

of the vacuum breaker on the inlet side of the device when it was pumping out. NSF site 

personnel dismantled the breaker and found no apparent reason for the malfunction. A 

modification of the breaker, which the manufacturer representative acknowledged did not 

impact device operation, was made to accommodate the remainder of the test. 

y	 	 Day nine – During the tilt cycle (to the three o’clock position), steam and a small amount 

of solids were emitting from the effluent hose, which indicated that the discharge pump 

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Performance Evaluation Report for Type I MSDs 

may have been out of the water. The device was righted for 30 seconds and the 

emergency pump-out switch was activated to prevent damage to the heating element. The 

device was returned to the tilt position and subsequent doses filled the tank enough to 

allow the pump to operate properly. 

3.6 Sample Collection 

Samples of the influent feed (challenge wastewater) and of the effluent discharged from 

each device (Figure 3-3) were collected according to the schedule provided in Appendix B. Note 

that the automated dosing schedule was started at the same time each day and the sample 

schedule was followed precisely to accommodate the processing times needed for each of the 

MSDs and the number of wastewater doses required to obtain sufficient effluent volume for 

testing. 

Influent 

wastewater 

Treatment 

Device 

Effluent 

wastewater SP2 

SP1 

Note: SP1 is the influent sampling point; SP2 is the effluent sampling point. 

Figure 3-3. Schematic Diagram of Sampling Points 

A grab sample of the challenge wastewater (mixed contents of the batch tank) was 

collected from the outlet of the recirculation pump immediately prior to dosing to the devices 

each day, for a total of 10 samples. Grab samples were collected using a clean 1.5-gallon glycolmodified polyethylene terephthalate (PETG) carboy, collecting approximately six liters each day. 

The collected wastewater was thoroughly mixed and poured off into appropriate sample bottles 

for the analyses (See Table 3-2). The sampling device was dedicated to challenge wastewater 

sample collection and was thoroughly decontaminated using Alconox cleaning solution and 

deionized/distilled water rinse after each use. 

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Performance Evaluation Report for Type I MSDs 

Table 3-2. Methods, Sample Volume, Preservatives, and Holding Time 

Reference/Method Name 

Sample Volume 

(mL) Preservativea 

Holding 

Time 

160.2 Total Suspended Solids 250 4C 7 days 

405.1 Biochemical Oxygen 

Demand, 5-day 

1000 4C 48 hours 

350.1 Ammonia 500 H2SO4, 4C 28 days 

353.2 Nitrate/ Nitrite 100 H2SO4, 4C 28 days 

351.2 Kjeldahl nitrogen 500 H2SO4, 4C 28 days 

365.2 Total phosphorus 50 H2SO4, 4C 28 days 

Hach #58700-00 Residual chlorine 50 None None 

9221 C Fecal coliform 100 Na2S2O3 

b

, 4C 6 hour 

Enterolert® Enterococcus 100 Na2S2O3

 b, 4C 6 hour 

Colilert® E. coli 100 Na2S2O3

 b, 4C 6 hour 

33 CFR 159.125 Visible Floating Solids 1000 None None a

 Sample containers were pre-preserved with chemical preservatives as appropriate, and proper sample preservation 

was verified upon sample receipt at the laboratory. 

b

 Na2S2O3 addition performed only for samples from the Electro Scan device due to presence of total residual 

chlorine. 

Effluent samples from the test devices were collected at the beginning, middle, and end 

of each eight hour period during dosing, with one additional sample taken following a peak 

dosing period each day. A total of 40 effluent samples were collected for the Electro Scan device 

(four samples per day for 10 days), and a total of 38 effluent samples were collected for the 

Thermopure-2 unit (two effluent sampled were missed due to unit operating problems on day 7 

as discussed in Section 3.5). Grab samples from each device were taken by draining the effluent 

from each of the 10-gallon effluent receiving containers into separate clean 1.5-gallon PETG 

carboys, collecting approximately six liters each sample time. The carboys were thoroughly 

mixed and poured off into appropriate sample bottles for the analyses to be completed (Table 3­

2). The sampling devices (effluent receiving containers and carboys) were dedicated to effluent 

sample collection from each device and were thoroughly decontaminated using Alconox 

cleaning solution and deionized/distilled water rinse after each use. 

NSF site personnel measured residual chlorine and visible floating solids onsite due to 

the relatively short holding times. Aqua-Tech Laboratories, Inc.2

 completed the chemical and 

biological analyses. 

2

 NSF’s facility located in Ann Arbor, Michigan is currently accepted by the USCG as a Recognized Facility for the 

evaluation, inspected, and testing of marine sanitation devices under 33 CFR 159.15. However, NSF’s Waco, Texas 

and Aqua-Tech Laboratories, Inc. subfacility currently is not accepted as a Recognized Facility by the USCG. 

3-10
 
Performance Evaluation Report for Type I MSDs 

3.7 Process Monitoring 

Process monitoring of influent and effluent streams was performed to verify that test 

conditions remained relatively constant over the course of the evaluation. Monitoring parameters 

were measured at regular intervals over the course of testing. 

Each grab sample of challenge water and effluent was tested for pH and temperature to 

monitor the operating conditions of the test system. Conductivity testing was also completed on 

the influent and effluent wastewater for the Electro Scan device. 

y	 	 pH: Analyses for pH were performed according to SM 4500-H. A three-point calibration 

was performed each day that the meter was used for testing. 

y	 	 Temperature: Temperature was measured according to SM 2550. 

y	 	 Conductivity: Salt content of challenge water and treated effluent were monitored using 

a conductivity meter, similar to method EPA 120.1. This testing was performed for 

testing of the Electro Scan device only. 

Wastewater flow rates (peak and off peak) were also monitored and recorded over the 

course of testing. 

3.8 Field Quality Control (QC) Measures 

Field quality control samples for this project included equipment blanks and field 

duplicate samples. Note that not all QC measures listed are required for all methods. 

The purpose of equipment blanks is to document adequate decontamination of sampling 

equipment before use and to evaluate possible contamination caused by sampling equipment or 

by sampling equipment decontamination procedures. Sampling equipment included the effluent 

receiving containers for each device and the plastic carboys used to collect, mix, and pour the 

influent and effluent samples. The sampling crew collected these blanks by rinsing 

decontaminated sampling equipment with deionized/distilled water. Equipment blanks were 

analyzed for the same parameters as those analyzed on the samples collected using the sampling 

equipment. 

Field duplicate samples were collected to evaluate total measurement precision and 

covered all the sources of data variability in sample collection, handling, preparation, and 

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Performance Evaluation Report for Type I MSDs 

analysis. Test personnel collected field duplicate samples simultaneously as split samples from 

the selected composite sample at a rate of one per batch of 10 to 20 samples for microbiologicals 

and one per batch of 10 samples for all other analytes. 

3.9 Deviations from the Work Plan 

Performance testing proceeded as specified in the work plan with the deviations below: 

y	 	 Malfunction of effluent pump on the Thermopure-2 device on day two resulted in four 

missed doses of challenge wastewater. No samples were missed. 

y	 	 Malfunction of the thermal switch on the Thermopure-2 device on day seven resulted in 

eighteen missed doses of challenge wastewater and two missed effluent samples. 

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Performance Evaluation Report for Type I MSDs 

4.0 TEST RESULTS AND DISCUSSION 

This section presents the data collected during the performance tests. Section 4.1 presents 

the analytical results and discussion for fecal coliform and visible floating solids. Section 4.2 

presents the analytical results and discussion for analytes other than coliform and visible floating 

solids. Section 4.3 discusses the performance of the two MSDs tested. Analytical data for the 

Electro Scan device are presented in Tables 4-1 through 4-14, and analytical data for the 

Thermopure-2 device are presented in Tables 4-15 through 4-26. Tables are presented at the end 

of this section. 

4.1 Fecal Coliform and Visible Floating Solids 

4.1.1 Fecal Coliform 

Table 4-1 presents the fecal coliform data for the Electro Scan device, and Table 4-15 

presents the fecal coliform data for the Thermopure-2 device. Note that two effluent samples 

were not collected for the Thermopure-2 device as discussed in Section 3.9, resulting in a total of 

38 effluent samples for this device rather than the planned 40 samples. The effluent produced by 

the Electro Scan device ranged from nondetect to >1,600 fecal coliform bacteria MPN/100 mL 

with a mean concentration of 82 MPN/100 mL (see Table 4-1). The effluent from the 

Thermopure-2 device ranged from nondetect to 30,000,000 fecal coliform bacteria MPN/100 mL 

with a mean concentration of 4,500,000 MPN/100 mL (see Table 4-15).3 

Upon receipt of the analytical data, ERG contacted representatives of Gross Mechanical 

Laboratories, Inc., the manufacturer of the Thermopure-2 device, to inform them of the 

performance of their device. The manufacturer’s representative visited the test facility to 

investigate. The representative verified proper device installation and test infrastructure. After 

drilling a 1-in. hole in the schedule 80 housing on the Thermopure-2 device, the representative 

found that a small internal thermal sensor that controls the heating and pumping cycle for the 

device, which is supposed to be inserted in a drilled recess in the heating block, was not in the 

recess or was not completely in the recess. The representative stated that misplacement of the 

thermal sensor would result in the device not reaching the designated threshold temperature 

sufficient to kill bacteria. It would also account for the shorting that occurred in the thermal 

3 Performance testing was not conducted in accordance with the test conditions described in 33 CFR 159.53 

(Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic human sewage 

rather than human sewage in a ratio of four urinations to one defecation, as specified in 33 CFR 159.121(c). 

4-1
 
 

 

Performance Evaluation Report for Type I MSDs 

switch on day seven (see discussion in Section 3.5). The manufacturer’s representative placed 

the sensor all the way into the recess and ran water through the device, measuring the 

temperature through several cycles. Effluent temperatures ranging between 61oC and 85oC were 

observed, which the representative stated was perfect working order. This compares to effluent 

temperatures ranging between 38oC and 49oC during the performance test (see Table 4-26). Per a 

request by Gross Mechanical Laboratories, Inc., a retest of a replacement Thermopure-2 device 

was conducted (see Section 5.0). 

It is not clear whether the sensor had come out in shipping or had simply not been 

installed properly during assembly. Given that the sensor is approximately 1-1/2 in. in length, 

and the distance between the outer schedule-80 housing and the surface of the heating block, into 

which the recess hole was drilled is only approximately 3/8-in., it does not appear likely that the 

sensor could have slipped out during shipping. 

4.1.2 Visible Floating Solids 

Table 4-2 presents the VFS data for the Electro Scan device, and Table 4-16 presents the 

VFS data for the Thermopure-2 device. Note that two effluent samples were missed for the 

Thermopure-2 device as discussed in Section 3.9, resulting in a total of 38 effluent samples for 

this device rather than the planned 40 samples. VFS is determined by passing approximately 1L 

of sample expeditiously through a U.S. Sieve No. 12 (openings of 0.0661 in. or 1.68 mm). The 

material retained on the sieve is dried to a constant weight at 103 °C and reported in mg/L. VFS 

is also reported as a percentage of the sample TSS. 

VFS concentrations in the effluent produced by the Electro Scan device ranged from zero 

to 5,500 mg/L with a mean concentration of 190 mg/L (see Table 4-2). VFS concentrations in the 

effluent from the Thermopure-2 device ranged from zero to 1,600 mg/L with a mean 

concentration of 66 mg/L (see Table 4-16). For the Electro Scan device, 33 of the 40 effluent 

samples had VFS less than or equal to 10% of the effluent TSS (see Table 4-2). For the 

Thermopure-2 device, 36 of the 38 effluent samples had VFS less than or equal to 10% of the 

effluent TSS (see Table 4-16). 4 

The effluent TSS concentration does not appear to indicate the effluent VFS 

concentration. For the Electro Scan device, 10 samples had TSS concentrations that exceeded 

4 Performance testing was not conducted in accordance with the test conditions described in 33 CFR 159.53 

(Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic human sewage 

rather than human sewage in a ratio of four urinations to one defecation, as specified in 33 CFR 159.121(c). 

4-2
 
 

Performance Evaluation Report for Type I MSDs 

1,000 mg/L. Of these, eight samples had corresponding VFS concentrations that were 10% or 

less than the TSS concentration and two samples did not. While the Electro Scan effluent sample 

with the highest TSS concentration had a corresponding VFS concentration significantly greater 

than 10% of the TSS concentration, the sample with the second highest TSS concentration had a 

corresponding VFS concentration significantly less than 10% of the TSS concentration. For the 

Thermopure-2 device, eight samples had effluent TSS concentrations that exceeded 1,000 mg/L. 

Of these, seven samples had corresponding VFS concentrations that were 10% or less than the 

TSS concentration (including the sample with the highest TSS concentration), and only one 

sample did not. 

4.2 Other Analyses 

4.2.1 Pathogen Indicators E. Coli and Enterococci 

Tables 4-3 and 4-4 present E. coli, and enterococci data for the Electro Scan device, 

respectively, and Tables 4-17, and 4-18 present E. coli, and enterococci data for the Thermopure2 device, respectively. E. coli is a subgroup of fecal coliform that indicates possible presence of 

enteric pathogens. Enterococcus is a subgroup of fecal streptococcus and is the most efficient 

bacterial indicator of water quality. (Fecal streptococcus is a subgroup of fecal coliform used to 

differentiate human versus animal sources of these microbiologicals.) Epidemiological studies 

suggest a positive relationship between high concentrations of E. coli and enterococci in ambient 

waters and incidents of gastrointestinal illnesses associated with swimming. The studies support 

the use of E. coli and enterococci (instead of fecal coliform) as indicators of microbiological 

pollution.5

 There are currently no E. coli or enterococci federal performance standards for Type I 

MSDs. 

Pathogen indicators generally were not detected in the effluent from the Electro Scan 

device. For those samples where pathogen indicators were detected, they were generally found at 

concentrations within 10 times the analytical detection limit. Four pathogen indicator results 

were uncharacteristically high: two detected E. coli concentrations of >24,000 MPN/100 mL, 

and two detected enterococci concentrations of 5,900 MPN/100 mL and >24,000 MPN/100 mL. 

5

 U.S. Environmental Protection Agency. Health Effects Criteria for Fresh Recreational Waters, EPA-600/1-84-004, 

Research Triangle Park, NC, August 1984. 

U.S. Environmental Protection Agency. Health Effects Criteria for Marine Recreational Waters, EPA-600/1-80-031, 

Research Triangle Park, NC, August 1983. 

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Performance Evaluation Report for Type I MSDs 

Both pathogen indicators were detected at elevated concentrations in the effluent from the 

Thermopure-2 device. E. coli concentrations were generally in the millions of MPN/100 mL, 

while enterococci were generally in the hundreds of thousands of MPN/100 mL. As discussed in 

Section 4.1.1, misplacement of the thermal sensor in the Thermopure-2 device is believed to 

have resulted in the device not reaching the designated threshold temperature sufficient to kill 

bacteria. 

4.2.2 Biochemical Oxygen Demand and Total Suspended Solids 

Tables 4-5 and 4-6 present BOD5 and TSS data, respectively, for the Electro Scan device, 

and Tables 4-19 and 4-20 present BOD5 and TSS data, respectively, for the Thermopure-2 

device. BOD5 and TSS were detected in all effluent samples for both devices. There are currently 

no BOD5 or TSS federal performance standards for Type I MSDs. 

The following table, for the purpose of comparison, shows the effluent quality from the 

Type I MSDs (which are not required to remove BOD5 or TSS) and EPA’s standards for 

secondary treatment for land-based publicly owned treatment works (POTWs). Note that the 

technology and capacity of Type I MSDs and POTWs are very different and must be considered 

in any comparison. 

BOD5 Comparison of Effluent from Type I MSDs to Secondary Treatment Standards 

Analyte 

Average Effluent Concentration From Type I MSDs EPA Secondary 

Treatment Standards a 

Electro Scan Thermopure-2 

BOD5 (mg/L) 780 920 45 

TSS (mg/L) 1,000 1,000 45 

a

 40 CFR 133.102 Secondary Treatment Regulations, 7-day average. 

4.2.3 Nutrients 

Tables 4-7 through 4-10 present nutrient data for the Electro Scan device, and Tables 4­

21 through 4-24 present nutrient data for the Thermopure-2 device. Ammonia, TKN, and total 

phosphorus were detected in all effluent samples for both devices. Detection of nitrate/nitrite was 

generally not consistent in effluent samples for both devices. There are currently no nutrient 

federal performance standards for Type I MSDs. 

4-4
 

 

 

Performance Evaluation Report for Type I MSDs 

Ammonia is an inorganic form of nitrogen in water and wastewater, as is nitrate/nitrite. 

Ammonia is produced within humans when proteins are digested and used by the body, and 

excess ammonia is excreted in urine. TKN measures both ammonia and organic nitrogen. 

Examples of organic nitrogen include proteins, peptides, nucleic acids, and urea. A comparison 

of the ammonia and TKN results in both the influent and effluent samples show that 

approximately 20% of TKN is the ammonia form. Total nitrogen is the combination of inorganic 

and organic forms of nitrogen in water and wastewater. 

4.2.4 Process Monitoring 

Review of pH results for the Electro Scan and Thermopure-2 devices in Tables 4-11 and 

4-25, respectively, showed there were no uncharacteristic pH excursions in the challenge 

wastewater or the treated effluent. 

Temperature variations for the Electro Scan device (see Table 4-12) reflect variations in 

ambient temperatures at the test site. On average, influent and effluent temperatures were similar, 

which is expected as the Electro Scan device does not affect wastewater temperature. In contrast, 

effluent temperatures for the Thermopure-2 device were greater than the influent temperatures 

(see Table 4-26) due to the Thermopure-2 heating mechanism. However, as discussed in Section 

4.1.1, the Thermopure-2 device failed to reach the designated temperature sufficient to kill 

bacteria. 

Elevated effluent conductivity as compared to influent conductivity for the Electro Scan 

device (see Table 4-13) results from the salt addition required for the electrodes to generate 

chlorine residual. Successful generation of residual chlorine is demonstrated by the free and total 

chlorine residual results provided in Table 4-14. Conductivity and chlorine residual testing were 

performed for the Electro Scan device only. 

4.3 Type I MSD Performance 

Table 4-27 compares the average influent and effluent concentrations for each device as 

determined from the individual results presented in Tables 4-1 through 4-26.6

 Review of these 

results reveals significant variability in analyte concentrations in both the influent and effluent 

6

 Performance testing for fecal coliform and VFS was not conducted in accordance with the test conditions described 

in 33 CFR 159.53 (Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic 

human sewage rather than human sewage in a ratio of four urinations to one defecation, as specified in 33 CFR 

159.121(c). There are currently no federal performance standards for Type I MSDs for parameters other than fecal 

coliform and VFS. 

4-5
 

 

Performance Evaluation Report for Type I MSDs 

for most analyses as illustrated by high standard deviations. Challenge wastewater and treated 

effluent are not homogeneous, and sample concentrations are highly dependent on the amount 

solids in the individual grab samples. Such variability is expected with raw, complex wastewater 

with high amounts of solids. With the exception of the fecal coliform, E. coli, and enterococci 

sample results, extreme variability in influent and effluent sample results preclude any 

meaningful assessment of MSD performance efficiency. 

The Electro Scan device removed almost all fecal coliform, E. coli, and enterococci 

(99.99% or greater). In contrast, the performance of the Thermopure-2 device in removing these 

analytes was generally low and highly erratic. In general, only half of fecal coliform, E. coli, and 

enterococci were removed. As discussed in Section 4.1.1, misplacement of the thermal sensor in 

the Thermopure-2 device is believed to have resulted in the device not reaching the designated 

threshold temperature sufficient to kill bacteria. 

4-6
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-1. Fecal Coliform - Electro Scan 

Date 

Influent Concentration 

(MPN/100mL) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent Concentration 

(MPN/100mL) 

8:12 AM Peak 2 

4/9/2007 4,000,000 8:24 AM Peak 4 

12:15 PM Off Peak 2 

3:48 PM Off Peak ND(2) 

8:12 AM Peak ND(1.1) 

4/10/2007 6,000,000 10:36 AM Peak ND(1.1) 

12:15 PM Off Peak >23 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak ND(1.1) 

4/11/2007 5,000,000 12:15 PM Off Peak ND(1.1) 

1:36 PM Peak ND(1.1) 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak 1.1 

4/12/2007 4,700,000 8:24 AM Peak ND(1.1) 

12:15 PM Off Peak ND(1.1) 

3:48 PM Off Peak 12 

8:12 AM Peak 2 

4/13/2007 30,000,000 12:15 PM Off Peak ND(1.1) 

1:36 PM Peak <2.2 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak 1.1 

4/16/2007 6,000,000 8:24 AM Peak ND(1.1) 

12:15 PM Off Peak ND(1.1) 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak <1.1 

4/17/2007 22,000,000 10:36 AM Peak 2.2 

12:15 PM Off Peak ND(1.1) 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak 2 

4/18/2007 3,000,000 12:15 PM Off Peak ND(1.1) 

1:36 PM Peak 9.2 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak ND(1.1) 

4/19/2007 5,000,000 8:24 AM Peak ND(1.1) 

12:15 PM Off Peak >1,600 

3:45 PM Off Peak >1,600 

8:12 AM Peak ND(1.1) 

4/20/2007 9,000,000 12:15 PM Off Peak ND(1.1) 

1:36 PM Peak ND(1.1) 

3:48 PM Off Peak ND(1.1) 

Average ± 

Standard 

Deviation 

9,500,000 ± 9,100,000 <82 ± 350 

ND – Not detected (number in parentheses is detection limit). 
 

> - The sample was not diluted sufficiently; actual concentration is greater than the reported upper limit.
 


< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results). 
 

4-7
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-2. Visible Floating Solids - Electro Scan 

Date 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent TSS 

Concentration 

(mg/L) 

Effluent VFS 

Concentration 

(mg/L) 

VFS as % 

TSS (%) 

8:12 AM Peak 560 0 0 

4/9/2007 8:24 AM Peak 460 0 0 

12:15 PM Off Peak 4,800 5,500 110 

3:48 PM Off Peak 1,700 100 5.9 

8:12 AM Peak 3,300 100 3.2 

4/10/2007 10:36 AM Peak 1,500 0 0 

12:15 PM Off Peak 650 100 15 

3:48 PM Off Peak 500 100 20 

8:12 AM Peak 580 0 0 

4/11/2007 12:15 PM Off Peak 460 0 0 

1:36 PM Peak 450 0.6 0.13 

3:48 PM Off Peak 430 0.7 0.16 

8:12 AM Peak 1,800 370 21 

4/12/2007 8:24 AM Peak 2,500 86 3.4 

12:15 PM Off Peak 1,700 32 1.9 

3:48 PM Off Peak 1,300 110 8.5 

8:12 AM Peak 1,300 130 10 

4/13/2007 12:15 PM Off Peak 760 9.4 1.2 

1:36 PM Peak 960 180 15 

3:48 PM Off Peak 630 4.7 0.8 

8:12 AM Peak 680 16 2.4 

4/16/2007 8:24 AM Peak 910 6 0.7 

12:15 PM Off Peak 670 0 0 

3:48 PM Off Peak 1,000 130 13 

8:12 AM Peak 1,000 46 5.8 

4/17/2007 10:36 AM Peak 1,400 110 7.9 

12:15 PM Off Peak 710 7 1 

3:48 PM Off Peak 840 50 6 

8:12 AM Peak 590 10 1.7 

4/18/2007 12:15 PM Off Peak 490 8 1.6 

1:36 PM Peak 910 110 12 

3:48 PM Off Peak 600 7 1.2 

8:12 AM Peak 450 5 1.1 

4/19/2007 8:24 AM Peak 920 27 2.9 

12:15 PM Off Peak 320 1 0.31 

3:45 PM Off Peak 270 2 0.74 

8:12 AM Peak 590 30 5.1 

4/20/2007 12:15 PM Off Peak 600 5 0.83 

1:36 PM Peak 1,000 70 7.4 

3:48 PM Off Peak 780 14 1.8 

Average ± 

Standard 

Deviation 

1,000 ± 860 190 ± 860 

4-8
 

 

 

Performance Evaluation Report for Type I MSDs 

Table 4-3. Escherichia coli - Electro Scan 

Date 

Influent Concentration 

(MPN/100mL) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent Concentration 

(MPN/100mL) 

4/9/2007 6,400,000 

8:12 AM Peak ND(500) 

8:24 AM Peak ND(500) 

12:15 PM Off Peak ND(500) 

3:48 PM Off Peak ND(500) 

4/10/2007 7,700,000 

8:12 AM Peak ND(100) 

10:36 AM Peak ND(100) 

12:15 PM Off Peak 980 

3:48 PM Off Peak ND(100) 

4/11/2007 6,800,000 

8:12 AM Peak ND(1.1) 

12:15 PM Off Peak ND(11) 

1:36 PM Peak ND(10) 

3:48 PM Off Peak ND(10) 

4/12/2007 20,000,000 

8:12 AM Peak ND(11) 

8:24 AM Peak ND(11) 

12:15 PM Off Peak Excluded 

3:48 PM Off Peak Excluded 

4/13/2007 8,000,000 

8:12 AM Peak ND(10) 

12:15 PM Off Peak ND(10) 

1:36 PM Peak ND(5.6) 

3:48 PM Off Peak ND(1.1) 

4/16/2007 6,100,000 

8:12 AM Peak ND(11) 

8:24 AM Peak ND(11) 

12:15 PM Off Peak ND(11) 

3:48 PM Off Peak ND(10) 

4/17/2007 19,000,000 

8:12 AM Peak <11 

10:36 AM Peak ND(11) 

12:15 PM Off Peak ND(11) 

3:48 PM Off Peak ND(10) 

4/18/2007 6,300,000 

8:12 AM Peak 79 

12:15 PM Off Peak 41 

1:36 PM Peak ND(10) 

3:48 PM Off Peak ND(10) 

4/19/2007 3,700,000 

8:12 AM Peak Excluded 

8:24 AM Peak ND(10) 

12:15 PM Off Peak >24,000 

3:45 PM Off Peak >24,000 

4/20/2007 7,400,000 

8:12 AM Peak ND(10) 

12:15 PM Off Peak ND(10) 

1:36 PM Peak ND(10) 

3:48 PM Off Peak ND(10) 

Average ± 

Standard 

Deviation 

9,100,000 ± 5,600,000 <1,400 ± 5,500 

ND – Not detected (number in parentheses is detection limit). 

Excluded – Sample result was determined by the laboratory to be inconclusive (see Section 6.1). 

> - The sample was not diluted sufficiently; actual concentration is greater than the reported upper limit. 

< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results). 

4-9
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-4. Enterococci - Electro Scan 

Date 

Influent Concentration 

(MPN/100mL) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent Concentration 

(MPN/100mL) 

8:12 AM Peak 38.1 

4/9/2007 1,300,000 8:24 AM Peak 29.4 

12:15 PM Off Peak ND(1,000) 

3:48 PM Off Peak 1.0 

8:12 AM Peak ND(100) 

4/10/2007 3,300,000 10:36 AM Peak 3.0 

12:15 PM Off Peak 6.2 

3:48 PM Off Peak 1.0 

8:12 AM Peak 3.3 

4/11/2007 350,000 12:15 PM Off Peak ND(1.1) 

1:36 PM Peak ND(1.1) 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak ND(10) 

4/12/2007 9,200,000 8:24 AM Peak 10 

12:15 PM Off Peak 1.1 

3:48 PM Off Peak 257 

8:12 AM Peak 1.1 

4/13/2007 570,000 12:15 PM Off Peak ND(1.1) 

1:36 PM Peak ND(1.1) 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak ND(1.1) 

4/16/2007 960,000 8:24 AM Peak ND(1.1) 

12:15 PM Off Peak ND(1.1) 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak ND(1.1) 

4/17/2007 370,000 10:36 AM Peak 1.0 

12:15 PM Off Peak ND(1.1) 

3:48 PM Off Peak ND(1.1) 

8:12 AM Peak ND(1.1) 

4/18/2007 840,000 12:15 PM Off Peak 15 

1:36 PM Peak ND(10) 

3:48 PM Off Peak ND(10) 

8:12 AM Peak 17 

4/19/2007 1,900,000 8:24 AM Peak 6.9 

12:15 PM Off Peak >24,000 

3:45 PM Off Peak 5,900 

8:12 AM Peak ND(10) 

4/20/2007 720,000 12:15 PM Off Peak ND(10) 

1:36 PM Peak ND(10) 

3:48 PM Off Peak ND(10) 

Average ± 

Standard 

Deviation 

2,000,000 ± 2,700,000 <790 ± 3,900 

ND – Not detected (number in parentheses is detection limit). 
 

> - The sample was not diluted sufficiently; actual concentration is greater than the reported upper limit.
 


< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
 


4-10
 

Performance Evaluation Report for Type I MSDs 

Table 4-5. Biochemical Oxygen Demand (5 day) - Electro Scan 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent 

Concentration (mg/L) 

8:12 AM Peak 310 

4/9/2007 1,900 8:24 AM Peak 240 

12:15 PM Off Peak 1,500 

3:48 PM Off Peak 600 

8:12 AM Peak 1,200 

4/10/2007 NA 10:36 AM Peak 690 

12:15 PM Off Peak 410 

3:48 PM Off Peak 320 

8:12 AM Peak 290 

4/11/2007 530 12:15 PM Off Peak 200 

1:36 PM Peak 170 

3:48 PM Off Peak 180 

8:12 AM Peak 920 

4/12/2007 810 8:24 AM Peak 1,400 

12:15 PM Off Peak 1,300 

3:48 PM Off Peak 1,100 

8:12 AM Peak 1,700 

4/13/2007 500 12:15 PM Off Peak 1,800 

1:36 PM Peak 2,600 

3:48 PM Off Peak 2,600 

8:12 AM Peak 340 

4/16/2007 990 8:24 AM Peak 610 

12:15 PM Off Peak 500 

3:48 PM Off Peak 670 

8:12 AM Peak 760 

4/17/2007 820 10:36 AM Peak 970 

12:15 PM Off Peak 770 

3:48 PM Off Peak 1,100 

8:12 AM Peak 690 

4/18/2007 450 12:15 PM Off Peak 270 

1:36 PM Peak 540 

3:48 PM Off Peak 450 

8:12 AM Peak 650 

4/19/2007 400 8:24 AM Peak 350 

12:15 PM Off Peak 280 

3:45 PM Off Peak 350 

8:12 AM Peak 380 

4/20/2007 2,100 12:15 PM Off Peak 710 

1:36 PM Peak 1,100 

3:48 PM Off Peak 490 

Average ± 

Standard Deviation 950 ± 630 780 ± 600 

NA – Sample not analyzed due to laboratory error (see Section 6.1). 

4-11
 

Performance Evaluation Report for Type I MSDs 

Table 4-6. Total Suspended Solids - Electro Scan 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent 

Concentration (mg/L) 

8:12 AM Peak 560 

4/9/2007 4,000 8:24 AM Peak 460 

12:15 PM Off Peak 4,800 

3:48 PM Off Peak 1,700 

8:12 AM Peak 3,300 

4/10/2007 12,000 10:36 AM Peak 1,500 

12:15 PM Off Peak 650 

3:48 PM Off Peak 500 

8:12 AM Peak 580 

4/11/2007 1,100 12:15 PM Off Peak 460 

1:36 PM Peak 450 

3:48 PM Off Peak 430 

8:12 AM Peak 1,800 

4/12/2007 720 8:24 AM Peak 2,500 

12:15 PM Off Peak 1,700 

3:48 PM Off Peak 1,300 

8:12 AM Peak 1,300 

4/13/2007 420 12:15 PM Off Peak 760 

1:36 PM Peak 960 

3:48 PM Off Peak 630 

8:12 AM Peak 680 

4/16/2007 1,100 8:24 AM Peak 910 

12:15 PM Off Peak 670 

3:48 PM Off Peak 1,000 

8:12 AM Peak 1,000 

4/17/2007 740 10:36 AM Peak 1,400 

12:15 PM Off Peak 710 

3:48 PM Off Peak 840 

8:12 AM Peak 590 

4/18/2007 500 12:15 PM Off Peak 490 

1:36 PM Peak 910 

3:48 PM Off Peak 600 

8:12 AM Peak 450 

4/19/2007 450 8:24 AM Peak 920 

12:15 PM Off Peak 320 

3:45 PM Off Peak 270 

8:12 AM Peak 590 

4/20/2007 3,300 12:15 PM Off Peak 600 

1:36 PM Peak 1,000 

3:48 PM Off Peak 780 

Average ± 

Standard Deviation 2,500 ± 3,600 1,000 ± 860 

4-12
 

Performance Evaluation Report for Type I MSDs 

Table 4-7. Ammonia as Nitrogen - Electro Scan 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent 

Concentration (mg/L) 

8:12 AM Peak 4.2 

4/9/2007 13 8:24 AM Peak 3.3 

12:15 PM Off Peak 9.8 

3:48 PM Off Peak 11 

8:12 AM Peak 7.7 

4/10/2007 12 10:36 AM Peak 3.4 

12:15 PM Off Peak 2.2 

3:48 PM Off Peak 3.9 

8:12 AM Peak 3.2 

4/11/2007 14 12:15 PM Off Peak 6.8 

1:36 PM Peak 8.9 

3:48 PM Off Peak 6.9 

8:12 AM Peak 6.2 

4/12/2007 15 8:24 AM Peak 5.6 

12:15 PM Off Peak 7.2 

3:48 PM Off Peak 10 

8:12 AM Peak 16 

4/13/2007 15 12:15 PM Off Peak 8.7 

1:36 PM Peak 8.0 

3:48 PM Off Peak 8.1 

8:12 AM Peak 1.5 

4/16/2007 13 8:24 AM Peak 10 

12:15 PM Off Peak 5.9 

3:48 PM Off Peak 5.7 

8:12 AM Peak 5.7 

4/17/2007 14 10:36 AM Peak 9.3 

12:15 PM Off Peak 3.2 

3:48 PM Off Peak 7.0 

8:12 AM Peak 10 

4/18/2007 18 12:15 PM Off Peak 5.5 

1:36 PM Peak 7.7 

3:48 PM Off Peak 12 

8:12 AM Peak 2.2 

4/19/2007 19 8:24 AM Peak 6.5 

12:15 PM Off Peak 21 

3:45 PM Off Peak 19 

8:12 AM Peak 8.8 

4/20/2007 21 12:15 PM Off Peak 16 

1:36 PM Peak 12 

3:48 PM Off Peak 18 

Average ± 

Standard Deviation 15 ± 3.0 8.2 ± 4.7 

4-13
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-8. Total Kjeldahl Nitrogen - Electro Scan 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent 

Concentration (mg/L) 

8:12 AM Peak 17 

4/9/2007 170 8:24 AM Peak 28 

12:15 PM Off Peak 130 

3:48 PM Off Peak 82 

8:12 AM Peak 37 

4/10/2007 290 10:36 AM Peak 27 

12:15 PM Off Peak 28 

3:48 PM Off Peak 30 

8:12 AM Peak 15 

4/11/2007 62 12:15 PM Off Peak 27 

1:36 PM Peak 22 

3:48 PM Off Peak 21 

8:12 AM Peak 31 

4/12/2007 230 8:24 AM Peak 38 

12:15 PM Off Peak 66 

3:48 PM Off Peak 76 

8:12 AM Peak 37 

4/13/2007 41 12:15 PM Off Peak 43 

1:36 PM Peak 49 

3:48 PM Off Peak 38 

8:12 AM Peak 22 

4/16/2007 73 8:24 AM Peak 31 

12:15 PM Off Peak 43 

3:48 PM Off Peak 46 

8:12 AM Peak 43 

4/17/2007 37 10:36 AM Peak 56 

12:15 PM Off Peak 47 

3:48 PM Off Peak 54 

8:12 AM Peak 47 

4/18/2007 75 12:15 PM Off Peak 15 

1:36 PM Peak 66 

3:48 PM Off Peak 44 

8:12 AM Peak 5 

4/19/2007 46 8:24 AM Peak 15 

12:15 PM Off Peak 45 

3:45 PM Off Peak 34 

8:12 AM Peak 66 

4/20/2007 74 12:15 PM Off Peak 47 

1:36 PM Peak 69 

3:48 PM Off Peak 61 

Average ± 

Standard Deviation 110 ± 89 42 ± 23 

4-14
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-9. Nitrate/Nitrite as Nitrogen - Electro Scan 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent 

Concentration (mg/L) 

8:12 AM Peak 3.0 

4/9/2007 0.11 8:24 AM Peak 3.6 

12:15 PM Off Peak 2.3 

3:48 PM Off Peak 1.3 

8:12 AM Peak 1.2 

4/10/2007 0.3 10:36 AM Peak 1.1 

12:15 PM Off Peak 1.1 

3:48 PM Off Peak 1.8 

8:12 AM Peak 2.2 

4/11/2007 ND(0.05) 12:15 PM Off Peak 0.95 

1:36 PM Peak 0.97 

3:48 PM Off Peak 1.0 

8:12 AM Peak 2.3 

4/12/2007 0.08 8:24 AM Peak 1.8 

12:15 PM Off Peak 1.9 

3:48 PM Off Peak 0.8 

8:12 AM Peak 1.1 

4/13/2007 ND(0.05) 12:15 PM Off Peak 1.1 

1:36 PM Peak 1.4 

3:48 PM Off Peak 1.4 

8:12 AM Peak 4.7 

4/16/2007 ND(0.05) 8:24 AM Peak 2.7 

12:15 PM Off Peak 0.94 

3:48 PM Off Peak 1.1 

8:12 AM Peak 1.4 

4/17/2007 ND(0.05) 10:36 AM Peak 1.1 

12:15 PM Off Peak 1.5 

3:48 PM Off Peak 1.4 

8:12 AM Peak 2.0 

4/18/2007 ND(0.05) 12:15 PM Off Peak 5.5 

1:36 PM Peak 4.3 

3:48 PM Off Peak 2.3 

8:12 AM Peak 10 

4/19/2007 0.07 8:24 AM Peak 6.8 

12:15 PM Off Peak ND(0.05) 

3:45 PM Off Peak 0.2 

8:12 AM Peak 1.7 

4/20/2007 ND(0.05) 12:15 PM Off Peak 1.2 

1:36 PM Peak 1.2 

3:48 PM Off Peak 0.77 

Average ± 

Standard Deviation <0.09 ± 0.078 <2.1 ± 1.9 

ND – Not detected (number in parentheses is detection limit). 
 

< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
 


4-15
 

Performance Evaluation Report for Type I MSDs 

Table 4-10. Total Phosphorus - Electro Scan 

Date 

Influent Concentration 

(mg/L) 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent 

Concentration (mg/L) 

8:12 AM Peak 9 

4/9/2007 59 8:24 AM Peak 12 

12:15 PM Off Peak 53 

3:48 PM Off Peak 31 

8:12 AM Peak 33 

4/10/2007 79 10:36 AM Peak 16 

12:15 PM Off Peak 13 

3:48 PM Off Peak 11 

8:12 AM Peak 15 

4/11/2007 15 12:15 PM Off Peak 12 

1:36 PM Peak 12 

3:48 PM Off Peak 12 

8:12 AM Peak 15 

4/12/2007 72 8:24 AM Peak 17 

12:15 PM Off Peak 19 

3:48 PM Off Peak 21 

8:12 AM Peak 16 

4/13/2007 9.6 12:15 PM Off Peak 11 

1:36 PM Peak 13 

3:48 PM Off Peak 10 

8:12 AM Peak 16 

4/16/2007 11 8:24 AM Peak 12 

12:15 PM Off Peak 9 

3:48 PM Off Peak 9 

8:12 AM Peak 11 

4/17/2007 9 10:36 AM Peak 15 

12:15 PM Off Peak 12 

3:48 PM Off Peak 14 

8:12 AM Peak 10 

4/18/2007 19 12:15 PM Off Peak 6 

1:36 PM Peak 18 

3:48 PM Off Peak 12 

8:12 AM Peak 3 

4/19/2007 14 8:24 AM Peak 7 

12:15 PM Off Peak 11 

3:45 PM Off Peak 9 

8:12 AM Peak 14 

4/20/2007 13 12:15 PM Off Peak 14 

1:36 PM Peak 20 

3:48 PM Off Peak 15 

Average ± Standard 

Deviation 30 ± 28 15 ± 8.4 

4-16
 

Performance Evaluation Report for Type I MSDs 

Table 4-11. pH - Electro Scan 

Date Influent pH 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow Effluent pH 

8:12 AM Peak 5.8 

4/9/2007 6.2 8:24 AM Peak 6.2 

12:15 PM Off Peak 6.1 

3:48 PM Off Peak 6.1 

8:12 AM Peak 6.3 

4/10/2007 6.1 10:36 AM Peak 6.3 

12:15 PM Off Peak 6.5 

3:48 PM Off Peak 6.4 

8:12 AM Peak 6.2 

4/11/2007 6.4 12:15 PM Off Peak 5.8 

1:36 PM Peak 6.1 

3:48 PM Off Peak 6.2 

8:12 AM Peak 6.4 

4/12/2007 5.8 8:24 AM Peak 6.4 

12:15 PM Off Peak 6.1 

3:48 PM Off Peak 6.1 

8:12 AM Peak 6.2 

4/13/2007 6.2 12:15 PM Off Peak 6.2 

1:36 PM Peak 6.4 

3:48 PM Off Peak 6.3 

8:12 AM Peak 6.6 

4/16/2007 7.0 8:24 AM Peak 6.4 

12:15 PM Off Peak 6.3 

3:48 PM Off Peak 6.3 

8:12 AM Peak 6.3 

4/17/2007 5.9 10:36 AM Peak 6.2 

12:15 PM Off Peak 6.4 

3:48 PM Off Peak 6.3 

8:12 AM Peak 6.5 

4/18/2007 7.0 12:15 PM Off Peak 6.3 

1:36 PM Peak 6.2 

3:48 PM Off Peak 6.4 

8:12 AM Peak 6.0 

4/19/2007 6.1 8:24 AM Peak 6.2 

12:15 PM Off Peak 6.8 

3:45 PM Off Peak 6.0 

8:12 AM Peak 6.5 

4/20/2007 6.7 12:15 PM Off Peak 6.4 

1:36 PM Peak 6.4 

3:48 PM Off Peak 6.4 

4-17
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-12. Temperature - Electro Scan 

Date 

Influent 

Temperature (°C) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Temperature (°C) 

8:12 AM Peak 14 

4/9/2007 14 8:24 AM Peak 13 

12:15 PM Off Peak 16 

3:48 PM Off Peak 18 

8:12 AM Peak 15 

4/10/2007 21 10:36 AM Peak 18 

12:15 PM Off Peak 20 

3:48 PM Off Peak 23 

8:12 AM Peak 17 

4/11/2007 21 12:15 PM Off Peak 25 

1:36 PM Peak 26 

3:48 PM Off Peak 27 

8:12 AM Peak 18 

4/12/2007 22 8:24 AM Peak 19 

12:15 PM Off Peak 23 

3:48 PM Off Peak 26 

8:12 AM Peak 20 

4/13/2007 22 12:15 PM Off Peak 23 

1:36 PM Peak 25 

3:48 PM Off Peak 26 

8:12 AM Peak 12 

4/16/2007 20 8:24 AM Peak 16 

12:15 PM Off Peak 22 

3:48 PM Off Peak 23 

8:12 AM Peak 15 

4/17/2007 21 10:36 AM Peak 21 

12:15 PM Off Peak 21 

3:48 PM Off Peak 24 

8:12 AM Peak 17 

4/18/2007 21 12:15 PM Off Peak 18 

1:36 PM Peak 22 

3:48 PM Off Peak 25 

8:12 AM Peak 19 

4/19/2007 21 8:24 AM Peak 25 

12:15 PM Off Peak 26 

3:45 PM Off Peak 27 

8:12 AM Peak 19 

4/20/2007 22 12:15 PM Off Peak 25 

1:36 PM Peak 26 

3:48 PM Off Peak 27 

Average ± Standard Deviation 20 ± 2.4 21 ± 4.3 

4-18
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-13. Conductivity - Electro Scan 

Date 

Influent 

Conductivity 

(mS/cm) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Conductivity 

(mS/cm) 

8:12 AM Peak 0 

4/9/2007 0 8:24 AM Peak 20 

12:15 PM Off Peak 0.08 

3:48 PM Off Peak 0.06 

8:12 AM Peak 0.11 

4/10/2007 0.01 10:36 AM Peak 0.17 

12:15 PM Off Peak 0.55 

3:48 PM Off Peak 18 

8:12 AM Peak 0.04 

4/11/2007 0 12:15 PM Off Peak 0.43 

1:36 PM Peak 0.25 

3:48 PM Off Peak 15 

8:12 AM Peak 18 

4/12/2007 0.04 8:24 AM Peak 0.42 

12:15 PM Off Peak 15 

3:48 PM Off Peak 17 

8:12 AM Peak 32 

4/13/2007 0.05 12:15 PM Off Peak 0.38 

1:36 PM Peak 25 

3:48 PM Off Peak 17 

8:12 AM Peak 35 

4/16/2007 0 8:24 AM Peak 37 

12:15 PM Off Peak 18 

3:48 PM Off Peak 34 

8:12 AM Peak 17 

4/17/2007 0.48 10:36 AM Peak 33 

12:15 PM Off Peak 19 

3:48 PM Off Peak 18 

8:12 AM Peak 27 

4/18/2007 0.51 12:15 PM Off Peak 41 

1:36 PM Peak 39 

3:48 PM Off Peak 31 

8:12 AM Peak 110 

4/19/2007 0.51 8:24 AM Peak 75 

12:15 PM Off Peak 3 

3:45 PM Off Peak 27 

8:12 AM Peak 35 

4/20/2007 1.1 12:15 PM Off Peak 31 

1:36 PM Peak 36 

3:48 PM Off Peak 36 

Average ± Standard Deviation 0.27 ± 0.37 22 ± 22 

4-19
 

Performance Evaluation Report for Type I MSDs 

Table 4-14. Chlorine Residual - Electro Scan 

Date 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent Free 

Chlorine (mg/L) 

Effluent Total 

Chlorine (mg/L) 

8:12 AM Peak 1.0 2.2 

4/9/2007 8:24 AM Peak 0.80 2.2 

12:15 PM Off Peak 1.2 1.7 

3:48 PM Off Peak 0.34 2.2 

8:12 AM Peak 0.45 0.90 

4/10/2007 10:36 AM Peak 0.66 2.2 

12:15 PM Off Peak 0.74 2.2 

3:48 PM Off Peak 0.59 2.2 

8:12 AM Peak 0.55 2.2 

4/11/2007 12:15 PM Off Peak 0.81 2.2 

1:36 PM Peak 1.1 2.2 

3:48 PM Off Peak 0.73 2.2 

8:12 AM Peak 0.10 2.2 

4/12/2007 8:24 AM Peak 0.54 2.2 

12:15 PM Off Peak 0.30 2.2 

3:48 PM Off Peak 0.50 2.2 

8:12 AM Peak 6.8 6.8 

4/13/2007 12:15 PM Off Peak 0.76 6.9 

1:36 PM Peak 0.61 8.8 

3:48 PM Off Peak 0.89 8.8 

8:12 AM Peak 0.25 2.2 

4/16/2007 8:24 AM Peak 0.86 2.2 

12:15 PM Off Peak 0.98 2.2 

3:48 PM Off Peak 0.69 2.2 

8:12 AM Peak 0.40 2.2 

4/17/2007 10:36 AM Peak 1.2 2.2 

12:15 PM Off Peak 1.2 2.2 

3:48 PM Off Peak 1.6 2.2 

8:12 AM Peak 1.0 2.2 

4/18/2007 12:15 PM Off Peak 1.4 2.2 

1:36 PM Peak 1.5 2.2 

3:48 PM Off Peak 1.4 2.2 

8:12 AM Peak 0.96 2.2 

4/19/2007 8:24 AM Peak 0.90 2.2 

12:15 PM Off Peak 0.99 2.2 

3:45 PM Off Peak 1.3 2.2 

8:12 AM Peak 0.82 2.2 

4/20/2007 12:15 PM Off Peak 1.2 2.2 

1:36 PM Peak 1.3 2.2 

3:48 PM Off Peak 1.4 2.2 

Average ± Standard Deviation 1.0 ± 1.0 2.7 ± 1.8 

4-20
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-15. Fecal Coliform - Thermopure-2 

Date 

Influent Concentration 

(MPN/100mL) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent Concentration 

(MPN/100mL) 

8:30 AM Peak 13,000,000 

4/9/2007 4,000,000 8:50 AM Peak 220 

12:15 PM Off Peak 8,000,000 

3:52 PM Off Peak 5,000,000 

8:30 AM Peak 9,000,000 

4/10/2007 6,000,000 11:46 AM Peak 5,000,000 

12:15 PM Off Peak 5,000,000 

3:52 PM Off Peak 3,000,000 

8:30 AM Peak 1,300,000 

4/11/2007 5,000,000 12:15 PM Off Peak 2,700,000 

2:52 PM Peak 2,400,000 

3:52 PM Off Peak 3,500,000 

8:30 AM Peak 1,700,000 

4/12/2007 4,700,000 8:50 AM Peak 140,000 

12:15 PM Off Peak 500,000 

3:52 PM Off Peak 6,000,000 

8:30 AM Peak 30,000,000 

4/13/2007 30,000,000 12:15 PM Off Peak 1,300,000 

2:58 PM Peak 3,000,000 

3:52 PM Off Peak 7,000,000 

8:30 AM Peak 5,000,000 

4/16/2007 6,000,000 8:50 AM Peak 7,000,000 

12:15 PM Off Peak 11,000,000 

3:52 PM Off Peak 5,000,000 

8:30 AM Peak 17,000,000 

4/17/2007 22,000,000 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 13,000,000 

8:30 AM Peak 5,000,000 

4/18/2007 3,000,000 12:15 PM Off Peak ND(2,000) 

2:52 PM Peak 170,000 

3:52 PM Off Peak ND(2,000) 

8:30 AM Peak 13,000 

4/19/2007 5,000,000 8:50 AM Peak 11,000 

12:15 PM Off Peak ND(2,000) 

3:52 PM Off Peak <3,000 

8:30 AM Peak 500,000 

4/20/2007 9,000,000 12:15 PM Off Peak 23,000 

2:52 PM Peak 90,000 

3:52 PM Off Peak ND(2000) 

Average ± 

Standard 

Deviation 

9,500,000 ± 9,100,000 <4,500,000 ± 6,100,000 

NC – Sample not collected due to unit operating problems (see Section 3.9). 
 

ND – Not detected (number in parentheses is detection limit).
 


< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
 


4-21
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-16. Visible Floating Solids - Thermopure-2 

Date 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent TSS 

Concentration 

(mg/L) 

Effluent VFS 

Concentration 

(mg/L) 

VFS as 

% TSS 

(%) 

8:30 AM Peak 2,400 78 3.2 

4/9/2007 8:50 AM Peak 2,000 0 0 

12:15 PM Off Peak 400 0 0 

3:52 PM Off Peak 620 0 0 

8:30 AM Peak 2,700 100 3.7 

4/10/2007 11:46 AM Peak 880 0 0 

12:15 PM Off Peak 600 100 17 

3:52 PM Off Peak 320 0 0 

8:30 AM Peak 380 0 0 

4/11/2007 12:15 PM Off Peak 260 0 0 

2:52 PM Peak 260 1.9 0.7 

3:52 PM Off Peak 310 0.9 0.29 

8:30 AM Peak 4,900 1,600 33 

4/12/2007 8:50 AM Peak 6,000 240 4.0 

12:15 PM Off Peak 580 2.8 0.48 

3:52 PM Off Peak 2,400 36 1.6 

8:30 AM Peak 2,200 49 2.2 

4/13/2007 12:15 PM Off Peak 370 3.1 0.84 

2:58 PM Peak 660 5 0.76 

3:52 PM Off Peak 400 0 0 

8:30 AM Peak 960 79 8.2 

4/16/2007 8:50 AM Peak 1,200 35 2.9 

12:15 PM Off Peak 290 0 0 

3:52 PM Off Peak 400 10 2.5 

8:30 AM Peak 420 1 0.24 

4/17/2007 11:46 AM Peak NC NC NC 

12:15 PM Off Peak NC NC NC 

3:52 PM Off Peak 360 7.5 2.1 

8:30 AM Peak 260 1 0.38 

4/18/2007 12:15 PM Off Peak 360 3 0.83 

2:52 PM Peak 800 28 3.5 

3:52 PM Off Peak 410 12 2.9 

8:30 AM Peak 970 49 5.0 

4/19/2007 8:50 AM Peak 310 18 5.8 

12:15 PM Off Peak 360 4.5 1.2 

3:52 PM Off Peak 310 1 0.36 

8:30 AM Peak 560 9 1.6 

4/20/2007 12:15 PM Off Peak 530 26 4.9 

2:52 PM Peak 640 51 8.0 

3:52 PM Off Peak 310 0 0 

Average ± 

Standard 

Deviation 

1,000 ± 1,300 66 ± 260 

NC – Sample not collected due to unit operating problems (see Section 3.9). 

4-22
 

Performance Evaluation Report for Type I MSDs 

Table 4-17. Escherichia coli - Thermopure-2 

Date 

Influent Concentration 

(MPN/100mL) 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent Concentration 

(MPN/100mL) 

8:30 AM Peak 4,900,000 

4/9/2007 6,400,000 8:50 AM Peak 1,000 

12:15 PM Off Peak 1,500,000 

3:52 PM Off Peak 2,300,000 

8:30 AM Peak 3,200,000 

4/10/2007 7,700,000 11:46 AM Peak 8,600,000 

12:15 PM Off Peak 3,600,000 

3:52 PM Off Peak 3,300,000 

8:30 AM Peak 9,700,000 

4/11/2007 6,800,000 12:15 PM Off Peak 3,900,000 

2:52 PM Peak 2,600,000 

3:52 PM Off Peak 1,500,000 

8:30 AM Peak 4,300,000 

4/12/2007 20,000,000 8:50 AM Peak 4,400,000 

12:15 PM Off Peak 1,800,000 

3:52 PM Off Peak ND(20,000) 

8:30 AM Peak 7,400,000 

4/13/2007 8,000,000 12:15 PM Off Peak 2,000,000 

2:58 PM Peak 3,900,000 

3:52 PM Off Peak 2,500,000 

8:30 AM Peak 7,600,000 

4/16/2007 6,100,000 8:50 AM Peak 13,000,000 

12:15 PM Off Peak 2,400,000 

3:52 PM Off Peak 1,200,000 

8:30 AM Peak 21,000,000 

4/17/2007 19,000,000 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 18,000,000 

8:30 AM Peak 2,800,000 

4/18/2007 6,300,000 12:15 PM Off Peak <20,000 

2:52 PM Peak 260,000 

3:52 PM Off Peak 15,000,000 

8:30 AM Peak 20,000 

4/19/2007 3,700,000 8:50 AM Peak 20,000 

12:15 PM Off Peak ND(20,000) 

3:52 PM Off Peak <30,000 

8:30 AM Peak 630,000 

4/20/2007 7,400,000 12:15 PM Off Peak 20,000 

2:52 PM Peak 82,000 

3:52 PM Off Peak 20,000 

Average ± Standard 

Deviation 9,100,000 ± 5,600,000 <4,000,000 ± 5,200,000 

NC – Sample not collected due to unit operating problems (see Section 3.9). 

ND – Not detected (number in parentheses is detection limit). 

< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results). 

4-23
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-18. Enterococci - Thermopure-2 

Date 

Influent Concentration 

(MPN/100mL) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent Concentration 

(MPN/100mL) 

8:30 AM Peak ND(1,000,000) 

4/9/2007 1,300,000 8:50 AM Peak 32,000 

12:15 PM Off Peak 440,000 

3:52 PM Off Peak 730,000 

8:30 AM Peak 2,000,000 

4/10/2007 3,300,000 11:46 AM Peak 800,000 

12:15 PM Off Peak 530,000 

3:52 PM Off Peak 450,000 

8:30 AM Peak 480,000 

4/11/2007 350,000 12:15 PM Off Peak 160,000 

2:52 PM Peak 31,000 

3:52 PM Off Peak 68,000 

8:30 AM Peak 990,000 

4/12/2007 9,200,000 8:50 AM Peak 180,000 

12:15 PM Off Peak 10,000 

3:52 PM Off Peak 110,000 

8:30 AM Peak 440,000 

4/13/2007 570,000 12:15 PM Off Peak 190,000 

2:58 PM Peak 440,000 

3:52 PM Off Peak 310,000 

8:30 AM Peak 370,000 

4/16/2007 960,000 8:50 AM Peak 750,000 

12:15 PM Off Peak 200,000 

3:52 PM Off Peak 43,000 

8:30 AM Peak 870,000 

4/17/2007 370,000 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 200,000 

8:30 AM Peak 110,000 

4/18/2007 840,000 12:15 PM Off Peak <1,000 

2:52 PM Peak 4,100 

3:52 PM Off Peak 1,000 

8:30 AM Peak 39,000 

4/19/2007 1,900,000 8:50 AM Peak 3,100 

12:15 PM Off Peak ND(1,000) 

3:52 PM Off Peak <1,000 

8:30 AM Peak 170,000 

4/20/2007 720,000 12:15 PM Off Peak 2,000 

2:52 PM Peak 2,000 

3:52 PM Off Peak ND(1,000) 

Average ± 

Standard 

Deviation 

2,000,000 ± 2,700,000 <320,000 ± 410,000 

NC – Sample not collected due to unit operating problems (see Section 3.9). 
 

ND – Not detected (number in parentheses is detection limit).
 


< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
 


4-24
 

 

 

Performance Evaluation Report for Type I MSDs 

Table 4-19. Biochemical Oxygen Demand (5 day) - Thermopure-2 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow 

Effluent 

Concentration (mg/L) 

8:30 AM Peak 1,200 

4/9/2007 1,900 8:50 AM Peak 1,100 

12:15 PM Off Peak 460 

3:52 PM Off Peak 470 

8:30 AM Peak 1,200 

4/10/2007 NA 11:46 AM Peak 540 

12:15 PM Off Peak 570 

3:52 PM Off Peak 370 

8:30 AM Peak 280 

4/11/2007 530 12:15 PM Off Peak 270 

2:52 PM Peak 200 

3:52 PM Off Peak 250 

8:30 AM Peak 3,700 

4/12/2007 810 8:50 AM Peak 3,700 

12:15 PM Off Peak 910 

3:52 PM Off Peak 2,600 

8:30 AM Peak 1,700 

4/13/2007 500 12:15 PM Off Peak 1,200 

2:58 PM Peak 1,300 

3:52 PM Off Peak 1,900 

8:30 AM Peak 660 

4/16/2007 990 8:50 AM Peak 1,100 

12:15 PM Off Peak 460 

3:52 PM Off Peak 610 

8:30 AM Peak 460 

4/17/2007 820 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 630 

8:30 AM Peak 260 

4/18/2007 450 12:15 PM Off Peak 400 

2:52 PM Peak 1,300 

3:52 PM Off Peak 600 

8:30 AM Peak 380 

4/19/2007 400 8:50 AM Peak 410 

12:15 PM Off Peak 640 

3:52 PM Off Peak 350 

8:30 AM Peak 470 

4/20/2007 2,100 12:15 PM Off Peak 440 

2:52 PM Peak 1,600 

3:52 PM Off Peak 480 

Average ± 

Standard Deviation 950 ± 630 920 ± 850 

NA – Sample not analyzed due to laboratory error (see Section 6.1). 
 

NC – Sample not collected due to unit operating problems (see Section 3.9).
 


4-25
 

Performance Evaluation Report for Type I MSDs 

Table 4-20. Total Suspended Solids - Thermopure-2 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Concentration (mg/L) 

8:30 AM Peak 2,400 

4/9/2007 4,000 8:50 AM Peak 2,000 

12:15 PM Off Peak 400 

3:52 PM Off Peak 620 

8:30 AM Peak 2,700 

4/10/2007 12,000 11:46 AM Peak 880 

12:15 PM Off Peak 600 

3:52 PM Off Peak 320 

8:30 AM Peak 380 

4/11/2007 1,100 12:15 PM Off Peak 260 

2:52 PM Peak 260 

3:52 PM Off Peak 310 

8:30 AM Peak 4,900 

4/12/2007 720 8:50 AM Peak 6,000 

12:15 PM Off Peak 580 

3:52 PM Off Peak 2,400 

8:30 AM Peak 2,200 

4/13/2007 420 12:15 PM Off Peak 370 

2:58 PM Peak 660 

3:52 PM Off Peak 400 

8:30 AM Peak 960 

4/16/2007 1,100 8:50 AM Peak 1,200 

12:15 PM Off Peak 290 

3:52 PM Off Peak 400 

8:30 AM Peak 420 

4/17/2007 740 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 360 

8:30 AM Peak 260 

4/18/2007 500 12:15 PM Off Peak 360 

2:52 PM Peak 800 

3:52 PM Off Peak 410 

8:30 AM Peak 970 

4/19/2007 450 8:50 AM Peak 310 

12:15 PM Off Peak 360 

3:52 PM Off Peak 310 

8:30 AM Peak 560 

4/20/2007 3,300 12:15 PM Off Peak 530 

2:52 PM Peak 640 

3:52 PM Off Peak 310 

Average ± 

Standard 

Deviation 

2,500 ± 3,600 1,000 ± 1,300 

NC – Sample not collected due to unit operating problems (see Section 3.9). 

4-26
 

Performance Evaluation Report for Type I MSDs 

Table 4-21. Ammonia as Nitrogen - Thermopure-2 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Concentration (mg/L) 

8:30 AM Peak 11 

4/9/2007 13 8:50 AM Peak 13 

12:15 PM Off Peak 17 

3:52 PM Off Peak 21 

8:30 AM Peak 12 

4/10/2007 12 11:46 AM Peak 12 

12:15 PM Off Peak 12 

3:52 PM Off Peak 16 

8:30 AM Peak 12 

4/11/2007 14 12:15 PM Off Peak 15 

2:52 PM Peak 15 

3:52 PM Off Peak 14 

8:30 AM Peak 15 

4/12/2007 15 8:50 AM Peak 15 

12:15 PM Off Peak 17 

3:52 PM Off Peak 20 

8:30 AM Peak 18 

4/13/2007 15 12:15 PM Off Peak 16 

2:58 PM Peak 17 

3:52 PM Off Peak 18 

8:30 AM Peak 9 

4/16/2007 13 8:50 AM Peak 12 

12:15 PM Off Peak 14 

3:52 PM Off Peak 15 

8:30 AM Peak 14 

4/17/2007 14 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 16 

8:30 AM Peak 3 

4/18/2007 18 12:15 PM Off Peak 21 

2:52 PM Peak 21 

3:52 PM Off Peak 22 

8:30 AM Peak 16 

4/19/2007 19 8:50 AM Peak 18 

12:15 PM Off Peak 23 

3:52 PM Off Peak 22 

8:30 AM Peak 15 

4/20/2007 21 12:15 PM Off Peak 23 

2:52 PM Peak 25 

3:52 PM Off Peak 23 

Average ± 

Standard 

Deviation 

15 ± 3.0 16 ± 4.5 

NC – Sample not collected due to unit operating problems (see Section 3.9). 

4-27
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-22. Total Kjeldahl Nitrogen - Thermopure-2 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Concentration (mg/L) 

8:30 AM Peak 89 

4/9/2007 170 8:50 AM Peak 130 

12:15 PM Off Peak 62 

3:52 PM Off Peak 69 

8:30 AM Peak 110 

4/10/2007 290 11:46 AM Peak 48 

12:15 PM Off Peak 55 

3:52 PM Off Peak 37 

8:30 AM Peak 42 

4/11/2007 62 12:15 PM Off Peak 39 

2:52 PM Peak 37 

3:52 PM Off Peak 34 

8:30 AM Peak 100 

4/12/2007 230 8:50 AM Peak 92 

12:15 PM Off Peak 73 

3:52 PM Off Peak 110 

8:30 AM Peak 59 

4/13/2007 41 12:15 PM Off Peak 49 

2:58 PM Peak 50 

3:52 PM Off Peak 50 

8:30 AM Peak 35 

4/16/2007 73 8:50 AM Peak 45 

12:15 PM Off Peak 49 

3:52 PM Off Peak 51 

8:30 AM Peak 51 

4/17/2007 37 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 48 

8:30 AM Peak 21 

4/18/2007 75 12:15 PM Off Peak 62 

2:52 PM Peak 76 

3:52 PM Off Peak 58 

8:30 AM Peak 44 

4/19/2007 46 8:50 AM Peak 42 

12:15 PM Off Peak 48 

3:52 PM Off Peak 60 

8:30 AM Peak 48 

4/20/2007 74 12:15 PM Off Peak 68 

2:52 PM Peak 58 

3:52 PM Off Peak 54 

Average ± 

Standard 

Deviation 

110 ± 89 59 ± 24 

NC – Sample not collected due to unit operating problems (see Section 3.9). 

4-28
 

 

 

Performance Evaluation Report for Type I MSDs 

Table 4-23. Nitrate/Nitrite as Nitrogen - Thermopure-2 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Concentration (mg/L) 

8:30 AM Peak 0.28 

4/9/2007 0.11 8:50 AM Peak 0.36 

12:15 PM Off Peak 0.22 

3:52 PM Off Peak 0.24 

8:30 AM Peak ND(0.05) 

4/10/2007 0.3 11:46 AM Peak ND(0.05) 

12:15 PM Off Peak ND(0.05) 

3:52 PM Off Peak ND(0.05) 

8:30 AM Peak 0.08 

4/11/2007 ND(0.05) 12:15 PM Off Peak 0.15 

2:52 PM Peak 0.17 

3:52 PM Off Peak 0.14 

8:30 AM Peak 0.23 

4/12/2007 0.08 8:50 AM Peak 0.19 

12:15 PM Off Peak 0.20 

3:52 PM Off Peak 0.24 

8:30 AM Peak 0.13 

4/13/2007 ND(0.05) 12:15 PM Off Peak 0.12 

2:58 PM Peak 0.13 

3:52 PM Off Peak 0.12 

8:30 AM Peak ND(0.05) 

4/16/2007 ND(0.05) 8:50 AM Peak ND(0.05) 

12:15 PM Off Peak ND(0.05) 

3:52 PM Off Peak ND(0.05) 

8:30 AM Peak ND(0.05) 

4/17/2007 ND(0.05) 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak ND(0.05) 

8:30 AM Peak 0.44 

4/18/2007 ND(0.05) 12:15 PM Off Peak 0.22 

2:52 PM Peak 0.13 

3:52 PM Off Peak 0.08 

8:30 AM Peak 0.25 

4/19/2007 0.07 8:50 AM Peak 0.23 

12:15 PM Off Peak 0.27 

3:52 PM Off Peak 0.14 

8:30 AM Peak 0.11 

4/20/2007 ND(0.05) 12:15 PM Off Peak 0.21 

2:52 PM Peak 0.39 

3:52 PM Off Peak 0.34 

Average ± 

Standard Deviation <0.09 ± 0.078 <0.17 ± 0.11 

NC – Sample not collected due to unit operating problems (see Section 3.9). 
 

ND – Not detected (number in parentheses is detection limit).
 


< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
 


4-29
 

Performance Evaluation Report for Type I MSDs 

Table 4-24. Total Phosphorus - Thermopure-2 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Concentration (mg/L) 

8:30 AM Peak 33 

4/9/2007 59 8:50 AM Peak 47 

12:15 PM Off Peak 18 

3:52 PM Off Peak 21 

8:30 AM Peak 36 

4/10/2007 79 11:46 AM Peak 13 

12:15 PM Off Peak 12 

3:52 PM Off Peak 11 

8:30 AM Peak 11 

4/11/2007 15 12:15 PM Off Peak 9.8 

2:52 PM Peak 10 

3:52 PM Off Peak 9.4 

8:30 AM Peak 26 

4/12/2007 72 8:50 AM Peak 48 

12:15 PM Off Peak 17 

3:52 PM Off Peak 32 

8:30 AM Peak 13 

4/13/2007 9.6 12:15 PM Off Peak 8.4 

2:58 PM Peak 9.8 

3:52 PM Off Peak 9.5 

8:30 AM Peak 7.1 

4/16/2007 11 8:50 AM Peak 9.2 

12:15 PM Off Peak 7.3 

3:52 PM Off Peak 7.2 

8:30 AM Peak 9.5 

4/17/2007 9 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 8.5 

8:30 AM Peak 5.2 

4/18/2007 19 12:15 PM Off Peak 12 

2:52 PM Peak 19 

3:52 PM Off Peak 12 

8:30 AM Peak 9.9 

4/19/2007 14 8:50 AM Peak 11 

12:15 PM Off Peak 9.1 

3:52 PM Off Peak 9.4 

8:30 AM Peak 9.4 

4/20/2007 13 12:15 PM Off Peak 13 

2:52 PM Peak 19 

3:52 PM Off Peak 14 

Average ± 

Standard 

Deviation 

30 ± 28 15 ± 11 

NC – Sample not collected due to unit operating problems (see Section 3.9). 

4-30
 

Performance Evaluation Report for Type I MSDs 

Table 4-25. pH - Thermopure-2 

Date Influent pH Effluent Sample Collection Time Peak/Off Peak Flow Effluent pH 

8:30 AM Peak 6.3 

4/9/2007 6.2 8:50 AM Peak 6.4 

12:15 PM Off Peak 6.7 

3:52 PM Off Peak 7.1 

8:30 AM Peak 6.4 

4/10/2007 6.1 11:46 AM Peak 6.4 

12:15 PM Off Peak 6.6 

3:52 PM Off Peak 7.1 

8:30 AM Peak 6.4 

4/11/2007 6.4 12:15 PM Off Peak 6.4 

2:52 PM Peak 6.3 

3:52 PM Off Peak 6.6 

8:30 AM Peak 6.5 

4/12/2007 5.8 8:50 AM Peak 6.4 

12:15 PM Off Peak 6.5 

3:52 PM Off Peak 6.4 

8:30 AM Peak 6.7 

4/13/2007 6.2 12:15 PM Off Peak 6.5 

2:58 PM Peak 6.6 

3:52 PM Off Peak 7.0 

8:30 AM Peak 5.4 

4/16/2007 7.0 8:50 AM Peak 7.1 

12:15 PM Off Peak 7.1 

3:52 PM Off Peak 7.4 

8:30 AM Peak 6.9 

4/17/2007 5.9 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 6.7 

8:30 AM Peak 7.0 

4/18/2007 7.0 12:15 PM Off Peak 7.2 

2:52 PM Peak 6.9 

3:52 PM Off Peak 6.9 

8:30 AM Peak 7.0 

4/19/2007 6.1 8:50 AM Peak 6.7 

12:15 PM Off Peak 6.5 

3:52 PM Off Peak 7.0 

8:30 AM Peak 6.9 

4/20/2007 6.7 

12:15 PM Off Peak 7.2 

2:52 PM Peak 7.0 

3:52 PM Off Peak 7.3 

NC – Sample not collected due to unit operating problems (see Section 3.9). 

4-31
 

 

Performance Evaluation Report for Type I MSDs 

Table 4-26. Temperature – Thermopure-2 

Date 

Influent 

Temperature (°C) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Temperature (°C) 

8:30 AM Peak 39 

4/9/2007 14 8:50 AM Peak 46 

12:15 PM Off Peak 39 

3:52 PM Off Peak 38 

8:30 AM Peak 42 

4/10/2007 21 11:46 AM Peak 40 

12:15 PM Off Peak 39 

3:52 PM Off Peak 40 

8:30 AM Peak 42 

4/11/2007 21 12:15 PM Off Peak 43 

2:52 PM Peak 43 

3:52 PM Off Peak 43 

8:30 AM Peak 45 

4/12/2007 22 8:50 AM Peak 47 

12:15 PM Off Peak 43 

3:52 PM Off Peak 43 

8:30 AM Peak 43 

4/13/2007 22 12:15 PM Off Peak 39 

2:58 PM Peak 41 

3:52 PM Off Peak 41 

8:30 AM Peak 38 

4/16/2007 20 8:50 AM Peak 41 

12:15 PM Off Peak 43 

3:52 PM Off Peak 41 

8:30 AM Peak 37 

4/17/2007 21 11:46 AM Peak NC 

12:15 PM Off Peak NC 

3:52 PM Off Peak 40 

8:30 AM Peak 43 

4/18/2007 21 12:15 PM Off Peak 49 

2:52 PM Peak 47 

3:52 PM Off Peak 45 

8:30 AM Peak 49 

4/19/2007 21 8:50 AM Peak 42 

12:15 PM Off Peak 48 

3:52 PM Off Peak 49 

8:30 AM Peak 46 

4/20/2007 22 12:15 PM Off Peak 49 

2:52 PM Peak 49 

3:52 PM Off Peak 45 

Average ± Standard Deviation 20 ± 2.4 43 ± 3.5 

NC – Sample not collected due to unit operating problems (see Section 3.9). 

4-32
 

Performance Evaluation Report for Type I MSDs 

Table 4-27. Summary of Type I MSD Performance 

Analysis 

Average Influent Concentration ± Standard 

Deviation 

Average Effluent Concentration ± S

Deviation 

Electro Scan Thermopu

Fecal Coliform 9,500,000 ± 9,100,000 <82 ± 350 <4,500,000 ± 6

Visible Floating Solids -­ 190 ± 860 66 ± 260 Escherichia coli 9,100,000 ± 5,600,000 <1,400 ± 5,500 <4,000,000 ± 5Enterococci 2,000,000 ± 2,700,000 <790 ± 3,900 <320,000 ± 4Biochemical Oxygen Demand (5 day) 950 ± 630 780 ± 600 920 ± 85

Total Suspended Solids 2,500 ± 3,600 1,000 ± 860 1,000 ± 1,

Ammonia as Nitrogen 15 ± 3.0 8.2 ± 4.7 16 ± 4.5 

Total Kjeldahl Nitrogen 110 ± 89 42 ± 23 59 ± 24 

Nitrate/Nitrite as Nitrogen <0.09 ± 0.078 <2.1 ± 1.9 <0.17 ± 0

Total Phosphorus 30 ± 28 15 ± 8.4 15 ± 11 

pH 5.8 to 7.0 5.8 to 6.8 5.4 to 7.

Temperature 20 ± 2.4 21 ± 4.3 43 ± 3.5 

Conductivity 0.27 ± 0.37 22 ± 22 -­ Chlorine Residual (Free) -­ 1.0 ± 1.0 -­ 

Chlorine Residual (Total) -­ 2.7 ± 1.8 -­ 

< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results). 

4-33
 
Performance Evaluation Report for Type I MSDs 

5.0 THERMOPURE-2 RETEST 

The Thermopure-2 unit is believed to have not reached the designated threshold 

temperature sufficient to kill bacteria due to the misalignment of a thermal sensor. Per a request 

by Gross Mechanical Laboratories, Inc., a retest of a replacement Thermopure-2 device was 

conducted. The scope of the retesting was reduced from that of the original test due to a 

limitation in funding. Accordingly, challenge wastewater sampling and analysis was reduced to a 

single sample of the challenge wastewater batch prepared each day to verify the target TSS 

concentration of 500 mg/L. Effluent sampling remained at four samples per day; however, 

sample analyses were reduced to fecal coliform, visible floating solids, BOD5, and TSS. The 

duration of the performance testing was also reduced from 10 to nine days. Retesting dates were 

October 15 and 16, 2007, November 29 and 30, 2007, and December 3 through 7, 2007. 

5.1 Performance Evaluation Retesting Procedures 

Installation and Start-up 

A replacement device, shipped by the manufacturer, was received at the test site on 

October 12 and was installed on the testing platform in the same manner as the April testing. The 

same means of tilting the device during testing was used. A trial run of the system was 

completed on October 13, using fresh water following the start-up procedures provided by the 

manufacturer. The device was found to be ready for testing. 

Retesting with challenge wastewater began on October 15, using the same dosing 

schedule as the April testing. While sample effluent temperatures were higher than those 

measured during the April testing, they were not as high as the manufacturer indicated they 

should be. Test-site personnel conferred with the manufacturer, who expressed confidence in 

proper operation of the device. However, preliminary fecal coliform results from the first day of 

retesting on October 16 indicated that the unit was not performing as expected. After consulting 

with the manufacturer, retesting was halted on the morning of October 17. 

On October 18, test facility personnel assisted the manufacturer in troubleshooting the 

device. Specifically, they accessed the processor chip that controls unit operation and took 

voltage readings as the device processed 10 cycles of clean water over three hours. The 

manufacturer confirmed that the voltage readings indicated that the chip was functioning as 

5-1
 

 

Performance Evaluation Report for Type I MSDs 

designed. Based on this information, the manufacturer began evaluating whether the 

programming of the chip was causing the temperature to not reach manufacturer indicated levels. 

The test facility received a new processor chip on November 27, installed it, and verified 

proper operation by testing with fresh water. Retesting with challenge wastewater commenced 

on November 29, and continued through December 7, using the same dosing schedule as the 

April testing. 

Effluent sample temperatures were still not as high as expected. Following discussions 

with the manufacturer, test-site personnel investigated whether the temperature discrepancy 

resulted from temperature measurements taken at the sampling location rather than at the heating 

block during the treatment cycle. On November 29, test-site personnel installed a thermometer 

close to the outlet of the heating block to develop a temperature profile over several four- to fiveminute treatment cycles. Over the first 60 to 90 seconds, the temperature rose to a high point of 

85°C to 91°C. The heating element then turned off, and the temperature steadily declined over 

the next 120 to 180 seconds until it reached 75°C to 80°C at the start of pump-out. Effluent 

temperature at the end of pump-out was approximately 58°C. Based on these results, the 

manufacturer expressed confidence in proper operation of the device. 

Sewage Processing Test 

The sewage processing test was performed in the same manner as the April test. As 

shown in Table 5-1, the influent TSS concentrations during testing ranged from 230 mg/L to 

3,100 mg/L. There were three days during the testing when the influent TSS concentration was 

less than 500 mg/L; however, the average TSS concentration over the course of the test was 

1,280 mg/L with a standard deviation of ±3,600 mg/L (1,300 mg/L ± 1,100 mg/L excluding the 

October testing). 

5-2
 

Performance Evaluation Report for Type I MSDs 

Table 5-1. Influent TSS Results – Theromopure-2 Retest 

Date Influent TSS (mg/L) 

October Retesting 

10/15/2007 600 

10/16/2007 1,700 

November/December Retesting 

11/29/2007 1,000 

11/30/2007 330 

12/3/2007 230 

12/4/2007 460 

12/5/2007 1,700 

12/6/2007 3,100 

12/7/2007 2,400 

MSD Operation and Maintenance 

The device required no maintenance during the testing. 

Sample Collection 

Sample collection was performed identically with the April testing, with one exception. 

Because of the reduced number of analyses, the volume needed for each sample was reduced, 

allowing for collection of samples directly into sample bottles. This differs from the April testing 

where samples were collected into carboys, mixed, and poured off into appropriate sample 

bottles. 

Process Monitoring 

Process monitoring was the same as during the April testing. 

Field QC Measures 

Field QC samples for the Thermopure-2 retesting included duplicate samples. Equipment 

blanks were not required as the intermediate sample collection carboys were not used. 

Deviation from the Work Plan 

Performance retesting proceeded as specified in the work plan with the following 

deviations: 

5-3
 

 

 

Performance Evaluation Report for Type I MSDs 

y	 	 The scope of the retesting was reduced from that of the original test due to a limitation in 

funding. Accordingly, challenge wastewater evaluation was reduced to a single sample of 

the challenge wastewater batch prepared each day to verify the minimum target TSS 

concentration of 500 mg/L. Effluent sampling remained at four samples per day; 

however, sample analyses were reduced to fecal coliform, visible floating solids, BOD5, 

and TSS. The duration of the performance testing was also reduced from 10 days to nine 

days. 

y	 	 The device overflowed during the morning of November 29, which resulted in six missed 

doses and only 26 gallons of wastewater processed for that day. No samples were missed. 

The holding tank filled and overflowed because of the longer heating cycles resulting 

from the reprogrammed processor chip, coupled with the warm-up time required for startup each morning. 

y	 	 The reprogramming of the chip affected the peak flow rate capacity of the Thermopure-2 

device. After the overflow on November 29, the influent was allowed to back up into the 

dosing line, and the unit processed the wastewater during off-peak dosing periods. The 

full dosing volume of 32 gallons was processed in the days following November 29. 

5.2 Retest Results and Discussion 

5.2.1 Fecal Coliform 

Table 5-2 presents the fecal coliform data for the Thermopure-2 retesting. The effluent 

produced by the Thermopure-2 device during the November/December retesting ranged from 

nondetect to 3,000,000 fecal coliform bacteria MPN/100 mL with a mean concentration of 

380,000 MPN/100 mL (see Table 5-2).7

 While these results show some improvement compared 

to the April testing (range from nondetect to 30,000,000 fecal coliform bacteria MPN/100 mL 

with a mean concentration of 4,500,000 MPN/100 mL), device performance remained poor. 

Although the cause of the poor performance is unknown, the device pump-out volume may have 

7 Performance testing was not conducted in accordance with the test conditions described in 33 CFR 159.53 

(Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic human sewage 

rather than human sewage in a ratio of four urinations to one defecation, as specified in 33 CFR 159.121(c). 

5-4
 
 

 

 

Performance Evaluation Report for Type I MSDs 

exceeded the capacity of the heating chamber, which would have mixed unheated (untreated) 

wastewater with treated wastewater during discharge (see discussion in Section 7.2). 

5.2.2 Visible Floating Solids 

Table 5-3 presents the VFS data for the Thermopure-2 retesting. VFS concentrations in 

the effluent from the Thermopure-2 device during the November/December retesting ranged 

from zero to 1,000 mg/L with a mean concentration of 100 mg/L. Of the 28 collected samples, 

26 had VFS less than 10% of the effluent TSS. 8 The November/December VFS results are 

similar to those from the April testing. 

5.2.3 Biochemical Oxygen Demand and Total Suspended Solids 

Tables 5-4 and 5-5 present BOD5 and TSS data, respectively, for the Thermopure-2 

retesting. Both analytes were detected in all 28 samples. There are currently no BOD5 or TSS 

federal performance standards for Type I MSDs. 

The following table, for the purpose of comparison, shows the effluent quality from the 

Thermopure-2 device (which is not required to remove BOD5 or TSS) and EPA’s standards for 

secondary treatment for land-based publicly owned treatment works (POTWs). Note that the 

technology and capacity of Type I MSDs and POTWs are very different and must be considered 

in any comparison. 

BOD5 Comparison of Effluent from Type I MSDs to Secondary Treatment Standards 

Analyte 

Average Effluent Concentration From Thermopure-2 

EPA Secondary 

Treatment Standards 

November/December a

Retesting April Testing 

BOD5 (mg/L) 710 920 45 

TSS (mg/L) 1,100 1,000 45 

a

 40 CFR 133.102 Secondary Treatment Regulations, 7-day average. 

5.2.4 Process Monitoring 

Review of the pH results for the Thermopure-2 retesting in Table 5-6 showed there were 

no uncharacteristic pH excursions in the challenge wastewater or the treated effluent. 

8 Performance testing was not conducted in accordance with the test conditions described in 33 CFR 159.53 

(Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic human sewage 

rather than human sewage in a ratio of four urinations to one defecation, as specified in 33 CFR 159.121(c). 

5-5
 
Performance Evaluation Report for Type I MSDs 

As expected, the reprogrammed processor chip produced significantly greater effluent 

sample temperatures during the November/December retesting as compared to the original chip 

for the April testing: an average of 62°C (see Table 5-7) as compared to an average of 43°C. This 

increase in temperature is likely responsible for the somewhat improved device performance in 

removing fecal coliform (see Section 5.2.1). 

5-6
 

 

 

Performance Evaluation Report for Type I MSDs 

Table 5-2. Fecal Coliform - Thermopure-2 Retest 

Date 

Effluent Sample 

Collection Time Peak/Off Peak Flow 

Effluent Concentration 

(MPN/100mL) 

October Retesting 

10/15/2007 

8:40 AM Peak 700,000 

9:05 AM Peak 240,000 

12:20 PM Off Peak 1,300,000 

4:00 PM Off Peak 110,000 

10/16/2007 

8:35 AM Peak 9,000,000 

11:50 AM Peak 24,000,000 

12:20 PM Off Peak 3,000,000 

3:56 PM Off Peak 280,000,000 

November/December Retesting 

11/29/2007 

8:30 AM Peak 2,200,000 

8:50 PM Peak 3,000,000 

12:15 PM Off Peak 300 

3:55 PM Off Peak 2,200 

11/30/2007 

8:30 AM Peak 1,700,000 

12:15 AM Off Peak 3,000,000 

2:52 PM Peak 50 

3:52 PM Off Peak 1,700 

12/3/2007 

8:30 AM Peak 5,000 

8:55 AM Peak 4,000 

12:15 PM Off Peak 1,600 

3:52 PM Off Peak ND(2.0) 

12/4/2007 

8:30 AM Peak 14,000 

11:46 AM Peak 28,000 

12:15 PM Off Peak 3,000 

1:52 PM Off Peak 3,000 

12/5/2007 

8:30 AM Peak 5,000 

12:15 PM Off Peak 1,300 

2:52 PM Peak 2.0 

3:52 PM Off Peak 2.0 

12/6/2007 

8:30 AM Peak 300,000 

8:50 AM Peak 500 

12:15 PM Off Peak 900 

3:52 PM Off Peak 22,000 

12/7/2007 

8:30 AM Peak 130,000 

12:15 PM Off Peak 170,000 

2:52 PM Peak 800 

3:52 PM Off Peak 350 

Average ± Standard 

Deviation 

<9,100,000 ± 47,000,000 

(<380,000 ± 900,000 a

) a

 Average of November/December samples. 
 

ND – Not detected (number in parentheses is detection limit).
 


< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results). 
 

5-7
 

 

Performance Evaluation Report for Type I MSDs 

Table 5-3. Visible Floating Solids - Thermopure-2 Retest 

Date 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent TSS 

Concentration 

(mg/L) 

Effluent VFS 

Concentration 

(mg/L) 

VFS as 

% TSS 

October Retesting 

10/15/2007 

8:40 AM Peak 330 NA NA 

9:05 AM Peak 320 NA NA 

12:2 PM Off Peak 820 NA NA 

4:00 PM Off Peak 790 NA NA 

10/16/2007 

8:35 AM Peak 870 NA NA 

11:50 AM Peak 1,500 NA NA 

12:20 PM Off Peak 1,100 NA NA 

3:56 PM Off Peak 1,400 NA NA 

November/December Retesting 

11/29/2007 

8:30 AM Peak 700 0 0 

8:50 AM Peak 660 10 1.5 

12:15 PM Off Peak 680 5 0.74 

3:55 PM Off Peak 840 4 0.48 

11/30/2007 

8:30 AM Peak 430 1 0.23 

12:15 PM Off Peak 230 7 3.0 

2:52 PM Peak 140 2 0.71 

3:52 PM Off Peak 100 1 2.0 

12/3/2007 

8:30 AM Peak 480 38 7.9 

8:50 AM Peak 320 8 2.5 

12:15 PM Off Peak 190 0 0 

3:52 PM Off Peak 130 1 0.77 

12/4/2007 

8:30 AM Peak 290 1 0.34 

11:46 AM Peak 280 0 0 

12:15 PM Off Peak 180 0 0 

1:52 PM Off Peak 150 0 0 

12/5/2007 

8:30 AM Peak 3,100 20 0.65 

12:15 PM Off Peak 2,000 160 8.0 

2:52 PM Peak 1,700 120 7.1 

3:52 PM Off Peak 1,200 80 6.7 

12/6/2007 

8:30 AM Peak 2,500 220 8.8 

8:50 AM Peak 2,500 41 1.6 

12:15 PM Off Peak 1,300 1,000 77 

3:52 PM Off Peak 1,100 38 3.5 

12/7/2007 

8:30 AM Peak 3,700 330 8.9 

12:15 PM Off Peak 2,600 670 26 

14:52 PM Peak 1,300 67 5.1 

3:52 PM Off Peak 1,500 20 1.3 

Average ± 

Standard 

Deviation 

1,000 ± 920 

(1,100 ± 1,000 a

) 100 ± 230 a 

a

 Average of November/December samples. 
 

NA – Samples not analyzed due to termination of October retesting.
 


5-8
 

 

Performance Evaluation Report for Type I MSDs 

Table 5-4. Biochemical Oxygen Demand (5 day) - Thermopure-2 Retest 

Date 

Effluent Sample Collection 

Time Peak/Off Peak Flow 

Effluent Concentration 

(mg/L) 

October Retesting 

10/15/2007 

8:40 AM Peak 160 

9:05 AM Peak 250 

12:20 PM Off Peak 970 

4:00 PM Off Peak 470 

10/16/2007 

8:30 AM Peak 1,100 

11:50 AM Peak 1,400 

12:20 PM Off Peak 1,500 

3:56 PM Off Peak 1,600 

November/December Retesting 

11/29/2007 

8:30 AM Peak 320 

8:50 AM Peak 320 

12:15 PM Off Peak 420 

3:55 PM Off Peak 480 

11/30/2007 

8:30 AM Peak 370 

12:15 PM Off Peak 230 

2:52 PM Peak 350 

3:52 PM Off Peak 220 

12/3/2007 

8:30 AM Peak 440 

8:50 AM Peak 300 

12:15 PM Off Peak 270 

3:52 PM Off Peak 230 

12/4/2007 

8:30 AM Peak 250 

11:46 AM Peak 200 

12:15 PM Off Peak 190 

3:52 PM Off Peak 240 

12/5/2007 

8:30 AM Peak 1,200 

12:15 PM Off Peak 1,500 

2:52 PM Peak 1,300 

3:52 PM Off Peak 980 

12/6/2007 

8:30 AM Peak 920 

8:50 AM Peak 1,400 

12:15 PM Off Peak 940 

3:52 PM Off Peak 970 

12/7/2007 

8:30 AM Peak >1,900 

12:15 PM Off Peak 1,800 

2:52 PM Peak 1,100 

3:52 PM Off Peak 1,100 

Average ± Standard 

Deviation 

760 ± 540 

(710 ± 540 a

) a

 Average of November/December samples. 
 

> - The sample was not diluted sufficiently; actual concentration is greater than the reported upper limit.
 


5-9
 

 

Performance Evaluation Report for Type I MSDs 

Table 5-5. Total Suspended Solids - Thermopure-2 Retest 

Date 

Influent 

Concentration (mg/L) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Concentration (mg/L) 

8:40 AM Peak 330 

10/15/2007 600 9:05 AM Peak 320 

12:2 PM Off Peak 820 

4:00 PM Off Peak 790 

8:35 AM Peak 870 

10/16/2007 1,700 11:50 AM Peak 1,500 

12:20 PM Off Peak 1,100 

3:56 PM Off Peak 1,400 

8:30 AM Peak 700 

11/29/2007 1,100 8:50 AM Peak 660 

12:15 PM Off Peak 680 

3:55 PM Off Peak 840 

8:30 AM Peak 430 

11/30/2007 330 12:15 PM Off Peak 230 

2:52 PM Peak 140 

3:52 PM Off Peak 100 

8:30 AM Peak 480 

12/3/2007 230 8:50 AM Peak 320 

12:15 PM Off Peak 190 

3:52 PM Off Peak 130 

8:30 AM Peak 290 

12/4/2007 460 11:46 AM Peak 280 

12:15 PM Off Peak 180 

1:52 PM Off Peak 150 

8:30 AM Peak 3,100 

12/5/2007 1,700 12:15 PM Off Peak 2,000 

2:52 PM Peak 1,700 

3:52 PM Off Peak 1,200 

8:30 AM Peak 2,500 

12/6/2007 3,100 8:50 AM Peak 2,500 

12:15 PM Off Peak 1,300 

3:52 PM Off Peak 1,100 

8:30 AM Peak 3,700 

12/7/2007 2,400 12:15 PM Off Peak 2,600 

14:52 PM Peak 1,300 

3:52 PM Off Peak 1,500 

Average ± 

Standard Deviation 

1,300 ± 1,000 

(1,300 ± 1,100 a

) 

1,000 ± 920 

(1,100 ± 1,000 a) a

 Average of November/December samples. 

5-10
 

Performance Evaluation Report for Type I MSDs 

Table 5-6. pH - Thermopure-2 Retest 

Date Influent pH 

Effluent Sample 

Collection Time 

Peak/Off Peak 

Flow Effluent pH 

October Retesting 

10/15/2007 6.4 

8:40 AM Peak 6.9 

9:05 AM Peak 6.9 

12:2 PM Off Peak 7.1 

4:00 PM Off Peak 7.0 

10/16/2007 6.7 

8:35 AM Peak 6.7 

11:50 AM Peak 6.5 

12:20 PM Off Peak 6.7 

3:56 PM Off Peak 6.6 

November/December Retesting 

11/29/2007 6.7 

8:30 AM Peak 6.1 

8:50 AM Peak 6.2 

12:15 PM Off Peak 6.1 

3:55 PM Off Peak 6.2 

11/30/2007 6.4 

8:30 AM Peak 5.9 

12:15 PM Off Peak 5.8 

2:52 PM Peak 6.5 

3:52 PM Off Peak 6.1 

12/3/2007 6.8 

8:30 AM Peak 7.0 

8:50 AM Peak 7.0 

12:15 PM Off Peak 7.0 

3:52 PM Off Peak 6.6 

12/4/2007 6.6 

8:30 AM Peak 6.8 

11:46 AM Peak 7.4 

12:15 PM Off Peak 7.1 

1:52 PM Off Peak 6.7 

12/5/2007 6.9 

8:30 AM Peak 7.3 

12:15 PM Off Peak 7.3 

2:52 PM Peak 7.3 

3:52 PM Off Peak 7.2 

12/6/2007 6.9 

8:30 AM Peak 6.8 

8:50 AM Peak 7.5 

12:15 PM Off Peak 7.1 

3:52 PM Off Peak 7.2 

12/7/2007 7.0 

8:30 AM Peak 6.9 

12:15 PM Off Peak 6.9 

14:52 PM Peak 7.1 

3:52 PM Off Peak 7.4 

5-11
 

 

 

Performance Evaluation Report for Type I MSDs 

Table 5-7. Temperature – Thermopure-2 Retest 

Date 

Influent 

Temperature (°C) 

Effluent Sample 

Collection Time 

Peak/Off 

Peak Flow 

Effluent 

Temperature (°C) 

October Retesting 

10/15/2007 28 

8:40 AM Peak 56 

9:05 AM Peak 57 

12:2 PM Off Peak 66 

4:00 PM Off Peak 58 

10/16/2007 27 

8:35 AM Peak 63 

11:50 AM Peak 61 

12:20 PM Off Peak 57 

3:56 PM Off Peak 53 

November/December Retesting 

11/29/2007 22 

8:30 AM Peak 46 

8:50 AM Peak 60 

12:15 PM Off Peak 65 

3:55 PM Off Peak 64 

11/30/2007 22 

8:30 AM Peak 53 

12:15 PM Off Peak 63 

2:52 PM Peak 66 

3:52 PM Off Peak 67 

12/3/2007 21 

8:30 AM Peak 68 

8:50 AM Peak 65 

12:15 PM Off Peak 67 

3:52 PM Off Peak 63 

12/4/2007 22 

8:30 AM Peak 60 

11:46 AM Peak 62 

12:15 PM Off Peak 59 

1:52 PM Off Peak 61 

12/5/2007 22 

8:30 AM Peak 51 

12:15 PM Off Peak 58 

2:52 PM Peak 61 

3:52 PM Off Peak 61 

12/6/2007 22 

8:30 AM Peak 64 

8:50 AM Peak 67 

12:15 PM Off Peak 65 

3:52 PM Off Peak 66 

12/7/2007 23 

8:30 AM Peak 59 

12:15 PM Off Peak 64 

14:52 PM Peak 55 

3:52 PM Off Peak 65 

Average ± Standard Deviation 23 ± 2.5 

(22 ± 0.58 a

) 

61 ± 5.1 

(62 ± 5.2 a) a

 Average of November/December samples. 

5-12
 

 

 

 

Performance Evaluation Report for Type I MSDs 

6.0 DATA QUALITY 

Quality assurance/quality control (QA/QC) procedures applicable to this Type I MSD 

performance evaluation are outlined in the Evaluation of Type I Marine Sanitation Devices 

(MSDs) Quality Assurance Project Plan (QAPP) dated March 20, 2007. This section describes 

the QC practices used to assess the precision and accuracy of the analytical data presented in 

Section 4.0. QC practices used for this performance evaluation include the analysis of matrix 

spikes, duplicate samples, and QC standard checks. 

6.1 Analytical QC 

NSF site personnel measured residual chlorine and visible floating solids onsite due to 

the relatively short holding times. Aqua-Tech Laboratories, Inc., of Bryan, Texas completed the 

chemical and biological analyses.9

 Aqua-Tech prepared written data review narratives describing 

any qualifications of the analytical data. NSF and ERG verified that contract laboratory 

performance was acceptable by conducting quality control checks of the analytical data as 

specified by the QAPP. Most of the data were determined to be of acceptable quality. The 

following data were not considered to be of acceptable quality and were excluded from the data 

set: 

Sample Analytical Parameter Reason for Exclusion 

Influent, 4/10/2007 BOD5 Sample not analyzed due to laboratory 

error. 

Electro Scan Effluent, 4/12/2007, 12:15 

PM 

E. coli 

Laboratory determined results to be 

Electro Scan Effluent, 4/12/2007, 3:48 PM E. coli inconclusive. 

Electro Scan Effluent, 4/19/2007, 8:12 AM E. coli 

Retesting Equipment Blanks, 10/15/2007, 

11/29/2007 

BOD5, TSS, Fecal coliform Equipment blanks were not required 

for Thermopure-2 retesting as samples 

were collected directly into sample 

containers. 

9

 NSF’s facility located in Ann Arbor, Michigan is currently accepted by the USCG as a Recognized Facility for the 

evaluation, inspected, and testing of marine sanitation devices under 33 CFR 159.15. However, NSF’s Waco, Texas 

and Aqua-Tech Laboratories, Inc. subfacility currently is not accepted as a Recognized Facility by the USCG. 

6-1 
Performance Evaluation Report for Type I MSDs 

6.2 Field QC 

The field QA/QC measures discussed in this subsection includes equipment blanks and 

field duplicate results, as specified in Section 6.3 of the Type I MSD QAPP. Tables are presented 

at the end of this section. 

6.2.1 Equipment Blanks 

April Testing 

NSF test-site personnel collected equipment blank QC samples to evaluate the potential 

introduction of contaminants by sample collection equipment. The sample collection equipment 

used to collect the equipment blank was identical to that used at the sampling points: effluent 

receiving containers for each device and carboys used to collect, mix, and pour the challenge 

wastewater and MSD effluent samples. Prior to collecting the equipment blanks, the sampling 

equipment was decontaminated by cleaning with Alconox cleaning solution, and then rinsed with 

distilled water. Following decontamination, fresh distilled water was added to each container and 

carboy, lids were put in place, and the equipment was vigorously shaken. This distilled water 

was decanted into sample bottles and analyzed for the same parameters as the samples collected 

using the sampling equipment. 

Table 6-1 presents the results from equipment blank analyses. The results showed no 

contamination of the influent carboy or the Electro Scan effluent receiving container. The only 

analyte detected in the equipment blanks for the Thermopure-2 effluent receiving container and 

the Electro Scan and Thermopure-2 carboys was nitrate/nitrite, with concentrations ranging from 

0.05 to 0.07 mg/L, close to the detection limit of 0.05 mg/L. The source of nitrate/nitrite is likely 

the Alconox that was used for the cleaning. Alconox contains ethylenediaminetetraacetic acid, 

which could (per the manufacturer) result in a positive reading for total nitrogen, in this case 

nitrate. Average nitrate/nitrite concentrations in the effluent samples were 2.4- to 30-times 

greater than those found in the equipment blanks; therefore, it is unlikely that equipment 

contamination had a significant impact the sample results. 

October and November/December Retesting 

Equipment blanks were not required for the Thermopure-2 retesting as samples were 

collected directly into sample bottles. 

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Performance Evaluation Report for Type I MSDs 

6.2.2 Field Duplicates 

Field duplicate samples were collected to assess the precision of the sampling and 

analysis process. Field duplicate samples were collected from the same source, at the same time, 

and then stored and analyzed independently. The relative percent difference (RPD) between the 

two duplicate sample results was calculated and compared to the target objective of 30% for each 

analyte. In the tables presenting the analytical results in Sections 4 and 5, duplicate sample 

results are presented as averages (calculation uses detection limits for non-detected results). 

April Testing 

Duplicate samples were collected as split samples poured from the same sample 

collection carboy to minimize sample waste stream variability. Two duplicate samples of the 

challenge wastewater were collected on two different days of the 10-day testing period, 

representing one set of duplicates for every batch of five challenge wastewater samples. Four 

duplicate samples were also collected of the effluent from each of the two MSDs throughout the 

10-day testing period. Effluent duplicate samples represent one set of duplicates for every batch 

of 10 effluent samples. 

Table 6-2 presents analytical results and the RPDs for these duplicate samples. 

Approximately 45% of the challenge wastewater duplicate pairs either achieved the RPD target, 

or the RPD could not be calculated because one or both of the sample results was less than the 

laboratory detection limit. Approximately 70% of the Electro Scan duplicate pairs and 

approximately 80% of the Thermopure-2 duplicate pairs either achieved the RPD target, or the 

RPD could not be calculated because one or both of the sample results was less than the 

laboratory detection limit, respectively. These results are common in complex wastewater 

samples. 

The presence of unmacerated versus macerated solids in the samples appears to affect the 

ability to achieve the RPD targets. This was demonstrated by the differences in the percentages 

of duplicate pairs that achieve the RPD target for challenge wastewater versus effluent samples. 

November/December Retesting 

As a result of the modification to the sampling procedure, duplicate samples were 

collected as sequential grab samples. This methodology introduced wastewater variability into 

the assessment of the precision of sample collection and analysis as compared to the 

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Performance Evaluation Report for Type I MSDs 

methodology used for the April testing, which used split samples. One duplicate sample of the 

challenge wastewater was collected for the series of seven challenge wastewater samples. (An 

additional challenge wastewater duplicate sample was collected during the October retesting 

period.) Two duplicate samples of the Thermopure-2 effluent were also collected during the 

nine-day retesting period, and three duplicate samples were collected for visible floating solids. 

One set of duplicates was collected for every batch of 10 to 15 effluent samples. 

Table 6-2 presents analytical results and the RPDs for these duplicate samples. All of the 

challenge wastewater duplicate pairs achieved the RPD target. Six of the 10 Thermopure-2 

duplicate pairs achieved the RPD target, while the remaining four did not. These results are 

common in complex and variable wastewater samples 

6.3 Testing Audit 

ERG conducted an audit of NSF’s Waco, Texas test facility to evaluate compliance with 

procedures, testing protocols, and analyses outlined in the Evaluation of Type I Marine 

Sanitation Devices (MSDs) Work Plan dated March 20, 2007 and the Evaluation of Type I 

Marine Sanitation Devices (MSDs) Quality Assurance Project Plan (QAPP) dated March 20, 

2007. 

During the audit, two days of performance testing and sample collection were observed. 

This included preparation of the challenge wastewater, device start-up procedures, operation of 

both devices at peak and off peak dosing cycle, handling of samples, and record keeping for both 

the Electro Scan and Thermopure-2 devices by NSF. ERG verified device operations, waste 

dosing, sample collection, field tests, field test documentation, instrument calibrations, daily 

tilting of devices, sample preservation, and transportation of the samples to the laboratory as 

outlined in the Audit Checklist provided as Figure 8-2 of the QAPP. Mechanical malfunction, 

troubleshooting, and the eventual repair of the Thermopure-2 device was also observed and 

documented on the second day of the audit. 

ERG observed some minor issues and their resolutions (as applicable) during the audit, 

but none of these issues impacted the analytical results from this Type I MSD test program. 

Further detailed observations, the audit checklists, and a list of issues and resolutions are 

provided in the Audit Report for Type I MSD Testing (Appendix C). 

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Performance Evaluation Report for Type I MSDs 

Table 6-1. Equipment Blank Results 

Analyte Unit 

Influent 

Carboy 

Electro Scan Effluent Ther

Receiving 

Container Carboy 

Receiv

Conta

April Testing Fecal Coliform MPN/100 mL ND(1.1) ND(1.1) ND(1.1) ND(1

Escherichia coli MPN/100 mL ND(1.0) ND(1.0) ND(1.0) ND(1

Enterococci MPN/100 mL ND(1.0) ND(1.0) ND(1.0) ND(1

Biochemical Oxygen Demand (5 day) mg/L ND(2) ND(2) ND(2) ND(

Total Suspended Solids mg/L ND(1) ND(1) ND(1) ND(

Ammonia as Nitrogen mg/L ND(0.05) ND(0.05) ND(0.05) ND(0

Total Kjeldahl Nitrogen mg/L ND(0.50) ND(0.50) ND(0.50) ND(0Nitrate/Nitrite as Nitrogen mg/L ND(0.05) ND(0.05) 0.06 0.0

Total Phosphorus mg/L ND(0.05) ND(0.05) ND(0.05) ND(0

ND – Not detected (number in parentheses is detection limit). 

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Performance Evaluation Report for Type I MSDs 

Table 6-2. Field Duplicate Analytical Results 

Sample 

Collection 

Date Time Analysis Unit 

Original 

Sample 

Duplicate 

Sample 

April Testing Influent 4/9/2007 8:00 AM Ammonia as Nitrogen mg/L 13 13 Influent 4/16/2007 8:00 AM Ammonia as Nitrogen mg/L 13 14 

Influent 4/9/2007 8:00 AM Biochemical Oxygen Demand (5 day) mg/L 2,100 1,800 

Influent 4/16/2007 8:00 AM Biochemical Oxygen Demand (5 day) mg/L 850 1,100 

Influent 4/9/2007 8:00 AM Enterococci MPN/100 mL 890,000 1,700,000 

Influent 4/16/2007 8:00 AM Enterococci MPN/100 mL 300,000 1,600,000 

Influent 4/9/2007 8:00 AM Escherichia coli MPN/100 mL 5,400,000 7,400,000 

Influent 4/16/2007 8:00 AM Escherichia coli MPN/100 mL 7,400,000 4,800,000 Influent 4/9/2007 8:00 AM Fecal Coliform MPN/100 mL 3,000,000 5,000,000 

Influent 4/16/2007 8:00 AM Fecal Coliform MPN/100 mL 9,000,000 3,000,000 Influent 4/9/2007 8:00 AM Nitrate/Nitrite as Nitrogen mg/L 0.13 0.09 

Influent 4/16/2007 8:00 AM Nitrate/Nitrite as Nitrogen mg/L ND(0.05) ND(0.05) Influent 4/9/2007 8:00 AM Total Kjeldahl Nitrogen mg/L 190 140 Influent 4/16/2007 8:00 AM Total Kjeldahl Nitrogen mg/L 84 62 

Influent 4/9/2007 8:00 AM Total Phosphorus mg/L 63 54 Influent 4/16/2007 8:00 AM Total Phosphorus mg/L 8.8 12 

Influent 4/9/2007 8:00 AM Total Suspended Solids mg/L 4,500 3,500 

Influent 4/16/2007 8:00 AM Total Suspended Solids mg/L 880 1,400 

Electro Scan Effluent 4/10/2007 8:12 AM Ammonia as Nitrogen mg/L 8.1 7.3 

Electro Scan Effluent 4/13/2007 1:36 PM Ammonia as Nitrogen mg/L 8.2 7.8 

Electro Scan Effluent 4/17/2007 8:12 AM Ammonia as Nitrogen mg/L 7 4.4 

Electro Scan Effluent 4/20/2007 1:36 PM Ammonia as Nitrogen mg/L 7.1 16 

Electro Scan Effluent 4/10/2007 8:12 AM Biochemical Oxygen Demand (5 day) mg/L 1,300 1,000 

Electro Scan Effluent 4/13/2007 1:36 PM Biochemical Oxygen Demand (5 day) mg/L 3,100 2,200 

Electro Scan Effluent 4/17/2007 8:12 AM Biochemical Oxygen Demand (5 day) mg/L 720 800 Electro Scan Effluent 4/20/2007 1:36 PM Biochemical Oxygen Demand (5 day) mg/L 560 1,600 

Electro Scan Effluent 4/10/2007 8:12 AM Enterococci MPN/100 mL ND(100) ND(100) 

Electro Scan Effluent 4/13/2007 1:36 PM Enterococci MPN/100 mL ND(1.1) ND(1.1) 

Electro Scan Effluent 4/17/2007 8:12 AM Enterococci MPN/100 mL ND(1.1) ND(1.1) 

Electro Scan Effluent 4/20/2007 1:36 PM Enterococci MPN/100 mL ND(10) ND(10) 

6-6
 
 

Performance Evaluation Report for Type I MSDs 

Table 6-2. Field Duplicate Analytical Results (Continued) 

Sample 

Collection 

Date Time Analysis Unit 

Original 

Sample 

Duplicate 

Sample 

Electro Scan Effluent 4/10/2007 8:12 AM Escherichia coli MPN/100 mL ND(100) ND(100) Electro Scan Effluent 4/13/2007 1:36 PM Escherichia coli MPN/100 mL ND(10) ND(1.1) Electro Scan Effluent 4/17/2007 8:12 AM Escherichia coli MPN/100 mL ND(11) 11 

Electro Scan Effluent 4/20/2007 1:36 PM Escherichia coli MPN/100 mL ND(10) ND(10) Electro Scan Effluent 4/10/2007 8:12 AM Fecal Coliform MPN/100 mL ND(1.1) ND(1.1) Electro Scan Effluent 4/13/2007 1:36 PM Fecal Coliform MPN/100 mL 3.3 ND(1.1) 

Electro Scan Effluent 4/17/2007 8:12 AM Fecal Coliform MPN/100 mL 1.1 ND(1.1) 

Electro Scan Effluent 4/20/2007 1:36 PM Fecal Coliform MPN/100 mL ND(1.1) ND(1.1) Electro Scan Effluent 4/10/2007 8:12 AM Nitrate/Nitrite as Nitrogen mg/L 1.1 1.4 

Electro Scan Effluent 4/13/2007 1:36 PM Nitrate/Nitrite as Nitrogen mg/L 1.5 1.4 

Electro Scan Effluent 4/17/2007 8:12 AM Nitrate/Nitrite as Nitrogen mg/L 1.6 1.3 

Electro Scan Effluent 4/20/2007 1:36 PM Nitrate/Nitrite as Nitrogen mg/L 1.2 1.2 

Electro Scan Effluent 4/10/2007 8:12 AM Total Kjeldahl Nitrogen mg/L 34 39 

Electro Scan Effluent 4/13/2007 1:36 PM Total Kjeldahl Nitrogen mg/L 54 45 

Electro Scan Effluent 4/17/2007 8:12 AM Total Kjeldahl Nitrogen mg/L 46 50 

Electro Scan Effluent 4/20/2007 1:36 PM Total Kjeldahl Nitrogen mg/L 54 85 

Electro Scan Effluent 4/10/2007 8:12 AM Total Phosphorus mg/L 25 41 Electro Scan Effluent 4/13/2007 1:36 PM Total Phosphorus mg/L 14 11 Electro Scan Effluent 4/17/2007 8:12 AM Total Phosphorus mg/L 11 12 Electro Scan Effluent 4/20/2007 1:36 PM Total Phosphorus mg/L 16 24 Electro Scan Effluent 4/10/2007 8:12 AM Total Suspended Solids mg/L 3,100 3,400 Electro Scan Effluent 4/13/2007 1:36 PM Total Suspended Solids mg/L 1,200 730 

Electro Scan Effluent 4/17/2007 8:12 AM Total Suspended Solids mg/L 800 1,200 

Electro Scan Effluent 4/20/2007 1:36 PM Total Suspended Solids mg/L 1,000 1,100 

Electro Scan Effluent 4/12/2007 8:24 AM Visible Floating Solids mg/L 67 110 

Electro Scan Effluent 4/13/2007 1:36 PM Visible Floating Solids mg/L 310 41 

Electro Scan Effluent 4/16/2007 3:48 PM Visible Floating Solids mg/L 120 140 

Electro Scan Effluent 4/18/2007 1:36 M Visible Floating Solids mg/L 140 72 

Thermopure-2 Effluent 4/11/2007 12:15 PM Ammonia as Nitrogen mg/L 16 15 

Thermopure-2 Effluent 4/12/2007 3:52 PM Ammonia as Nitrogen mg/L 20 20 Thermopure-2 Effluent 4/18/2007 12:15 PM Ammonia as Nitrogen mg/L 20 23 

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Performance Evaluation Report for Type I MSDs 

Table 6-2. Field Duplicate Analytical Results (Continued) 

Sample 

Collection 

Date Time Analysis Unit 

Original 

Sample 

Duplicate 

Sample 

Thermopure-2 Effluent 4/19/2007 3:52 PM Ammonia as Nitrogen mg/L 22 22 Thermopure-2 Effluent 4/11/2007 12:15 PM Biochemical Oxygen Demand (5 day) mg/L 300 240 

Thermopure-2 Effluent 4/12/2007 3:52 PM Biochemical Oxygen Demand (5 day) mg/L 2,200 2,900 

Thermopure-2 Effluent 4/18/2007 12:15 PM Biochemical Oxygen Demand (5 day) mg/L 340 460 

Thermopure-2 Effluent 4/19/2007 3:52 PM Biochemical Oxygen Demand (5 day) mg/L 300 400 

Thermopure-2 Effluent 4/11/2007 12:15 PM Enterococci MPN/100 mL 180,000 130,000 

Thermopure-2 Effluent 4/12/2007 3:52 PM Enterococci MPN/100 mL 110,000 100,000 Thermopure-2 Effluent 4/18/2007 12:15 PM Enterococci MPN/100 mL 1,000 ND(1,000) 

Thermopure-2 Effluent 4/19/2007 3:52 PM Enterococci MPN/100 mL 1,000 ND(1,000) 

Thermopure-2 Effluent 4/11/2007 12:15 PM Escherichia coli MPN/100 mL 5,100,000 2,700,000 Thermopure-2 Effluent 4/12/2007 3:52 PM Escherichia coli MPN/100 mL ND(20,000) ND(20,000) Thermopure-2 Effluent 4/18/2007 12:15 PM Escherichia coli MPN/100 mL ND(20,000) 20,000 

Thermopure-2 Effluent 4/19/2007 3:52 PM Escherichia coli MPN/100 mL ND(20,000) 40,000 

Thermopure-2 Effluent 4/11/2007 12:15 PM Fecal Coliform MPN/100 mL 3,000,000 2,400,000 

Thermopure-2 Effluent 4/12/2007 3:52 PM Fecal Coliform MPN/100 mL 9,000,000 3,000,000 

Thermopure-2 Effluent 4/18/2007 12:15 PM Fecal Coliform MPN/100 mL ND(2,000) ND(2,000) 

Thermopure-2 Effluent 4/19/2007 3:52 PM Fecal Coliform MPN/100 mL 4,000 ND(2,000) 

Thermopure-2 Effluent 4/11/2007 12:15 PM Nitrate/Nitrite as Nitrogen mg/L 0.15 0.15 

Thermopure-2 Effluent 4/12/2007 3:52 PM Nitrate/Nitrite as Nitrogen mg/L 0.24 0.24 Thermopure-2 Effluent 4/18/2007 12:15 PM Nitrate/Nitrite as Nitrogen mg/L 0.25 0.19 

Thermopure-2 Effluent 4/19/2007 3:52 PM Nitrate/Nitrite as Nitrogen mg/L 0.12 0.15 

Thermopure-2 Effluent 4/11/2007 12:15 PM Total Kjeldahl Nitrogen mg/L 32 46 

Thermopure-2 Effluent 4/12/2007 3:52 PM Total Kjeldahl Nitrogen mg/L 82 140 Thermopure-2 Effluent 4/18/2007 12:15 PM Total Kjeldahl Nitrogen mg/L 62 63 

Thermopure-2 Effluent 4/19/2007 3:52 PM Total Kjeldahl Nitrogen mg/L 70 50 

Thermopure-2 Effluent 4/11/2007 12:15 PM Total Phosphorus mg/L 9.7 10 Thermopure-2 Effluent 4/12/2007 3:52 PM Total Phosphorus mg/L 28 37 

Thermopure-2 Effluent 4/18/2007 12:15 PM Total Phosphorus mg/L 11 12 

Thermopure-2 Effluent 4/19/2007 3:52 PM Total Phosphorus mg/L 9.3 9.4 

Thermopure-2 Effluent 4/11/2007 12:15 PM Total Suspended Solids mg/L 250 260 Thermopure-2 Effluent 4/12/2007 3:52 PM Total Suspended Solids mg/L 2,200 2,700 

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Performance Evaluation Report for Type I MSDs 

Table 6-2. Field Duplicate Analytical Results (Continued) 

Sample 

Collection 

Date Time Analysis Unit 

Original 

Sample 

Duplicate 

Sample 

Thermopure-2 Effluent 4/18/2007 12:15 PM Total Suspended Solids mg/L 360 360 

Thermopure-2 Effluent 4/19/2007 3:52 PM Total Suspended Solids mg/L 280 340 

Thermopure-2 Effluent 4/10/2007 8:30 AM Visible Floating Solids mg/L 100 100 

Thermopure-2 Effluent 4/11/2007 8:30 AM Visible Floating Solids mg/L 0 0 

Thermopure-2 Effluent 4/17/2007 3:52 PM Visible Floating Solids mg/L 2.0 13 

Thermopure-2 Effluent 4/19/2007 12:15 PM Visible Floating Solids mg/L 1.0 8.0 

Thermopure-2 Effluent 4/20/2007 3:52 PM Visible Floating Solids mg/L 0 0 

October Retesting Influent 10/15/2007 8:05 AM TSS mg/L 650 560 

November/December Retesting Influent 11/29/2007 8:00 AM TSS mg/L 1,100 1,000 

Thermopure-2 Effluent 12/5/2007 12:15 PM TSS mg/L 1,800 2,200 

Thermopure-2 Effluent 12/5/2007 12:15 PM BOD5 mg/L 1,500 1,600 

Thermopure-2 Effluent 12/5/2007 12:15 PM Fecal coliform mg/L 1,600 900 

Thermopure-2 Effluent 12/5/2007 8:30 AM Visible floating solids mg/L 0 40 Thermopure-2 Effluent 12/6/2007 15:52 PM TSS mg/L 1,200 1100 

Thermopure-2 Effluent 12/6/2007 15:52 PM BOD5 mg/L 1,000 910 

Thermopure-2 Effluent 12/6/2007 15:52 PM Fecal coliform mg/L 22,000 22,000 

Therompure-2 Effluent 12/6/2007 8:50 AM Visible floating solids mg/L 0 82 Therompure-2 Effluent 12/7/2007 2:52 PM Visible floating solids mg/L 94 39 

ND – Not detected (number in parentheses is detection limit).< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).

6-9
 
 

Performance Evaluation Report for Type I MSDs 

7.0 MANUFACTURER RESPONSE 

A draft performance evaluation report was provided to the two MSD technology 

manufacturers on May 30, 2008. Sections 7.1 and 7.2 present the submissions received from 

Raritan Engineering Company, Inc. and Gross Mechanical Laboratories, Inc., respectively, 

together with a response to the manufacturer’s comments. This final report incorporates 

manufacturer comments as appropriate. 

7.1 Raritan Engineering Company, Inc. 

Raritan Submission 

It is our understanding that the purpose of this testing was to determine whether or not 

standards that have remained unchanged since 1975 should be reviewed. It is Raritan’s 

contention that technology exists to treat waste to a much higher standard than the current 1975 

standards reflect. The original law stated that standards would be reviewed every five years. Our 

interpretation of this review was that it would help to encourage the use of continually improved 

on-board treatment as a viable alternative for conscientious boaters. 

As it relates to the testing performed it must also be stated that there are substantial 

differences in small recreational vessel waste streams as compared to larger commercial vessels 

and high occupancy vessels such as cruise ships. 33 CFR Sec.159.121 Sewage Processing test 

does indicate the difference in the two waste streams and it appears testing was done based on 

section (d) not section (c). Section (c) describes the type of system the Electroscan is and all 

previous testing had been done based on section (c). Based on the fact that the Electroscan was 

tested as a unit that continually processes sewage the system was overloaded, Electroscan should 

have been tested per Coast Guard specifications section (c) of 33 CFR 159.121. In light of that 

fact the system performed flawlessly with respect to Fecal Coliform, Escherichia coli and 

Enterococci. These three pathogen indicators were used because they are the most efficient 

bacterial indicator of water quality. (Fecal streptococcus is a subgroup of fecal coliform used to 

differentiate human versus animal sources of these microbiologicals.) Epidemiological studies 

suggest a positive relationship between high concentrations of E. coli and enterococci in ambient 

waters and incidents of gastrointestinal illnesses associated with swimming. The results suggest 

use of this on-board device is compatible with recreational waters. 

7-1
 

Performance Evaluation Report for Type I MSDs 

The VFS test that was performed must be questioned based on the simple fact the system 

was overloaded. Normal loading as indicated in the report is based on section (d) of 33 CFR 

159.121 and the Electroscan should have been tested based on section (c) of 33 CFR 159.121. 

Section (d) specified a minimum of 500 mg/L and the average was 2,500 mg/L. We do not agree 

that the system does not meet current requirements as it was not tested based on requirements. 

This also brings into question the results of TSS, VFS and BOD5 as all tend to be inter-related. 

There are several days where the influent concentration is less than the effluent concentration 

which is not possible. This is documented in Table 4-5 for BOD5 where influent was 810 mg/L 

on 4/12/2007 while effluent concentrations were 920, 1,400, 1,300 and 1,100. In addition to that 

anomaly it is a documented fact that chlorination reduces BOD5 therefore we do not fully agree 

with the statement on page 4-8 that “Consequently, it is likely that apparent BOD5 and TSS 

removals are solely a phenomenon of the wastewater, sampling, and analytical variability and 

not actual removal by Type I devices.” If we discard the erroneous data of table 4-5 where 

effluent is higher than influent total BOD5 reduction is 58.9%. 

Raritan believes this testing is a step in the right direction for all users of recreational 

vessels. The intention of the law in 1975 was quite clear - continual improvement. By changing 

standards more companies will see the benefit of providing treatment on-site rather than risk 

illegal discharges. 

Response to Raritan Submission 

The performance evaluations of Type I MSDs were conducted in accordance with the 

Sewage Processing Test contained in the regulations at 33 CFR 159.121. One exception to the 

USCG’s Sewage Processing Test requirements is that, for reasons of practicality, testing was 

conducted using a feed of fresh domestic human sewage rather than human sewage in a ratio of 

four urinations to one defecation, as specified in Section (c). Furthermore, for this evaluation, 

testing was not limited to fecal coliform bacteria and visible floating solids measured in the 

treated effluent, but rather included a variety of analyses of both influent and effluent samples to 

measure the effectiveness of each treatment device and to characterize influent and effluent 

quality. In every other regard, the Raritan device was tested using the 33 CFR 159.121 protocols, 

including Section (c). The Raritan device was not tested in accordance to Section (d), as this 

device does not process or discharge sewage continuously, nor was the device modified in any 

way to operate continuously. 

7-2
 

Performance Evaluation Report for Type I MSDs 

The dosing schedule was well within the average and peak capacity of the Raritan unit as 

indicated in the unit documentation (see Appendix B of this report for the challenge wastewater 

dosing schedule). Specifically, peak flow was designated by Raritan as 1 gallon flush of 

wastewater every six minutes, and a 30-minute cool-down period after every four to five flushes. 

Off-peak (average) process flow was based on an assumption of four passengers each using the 

toilet five times in an eight-hour day with 1-gallon per flush. Raritan product specifications 

indicate a unit capacity of 575 gallons per day, and a maximum total flush volume of 1.5 gallons 

per flush; these compare to the test conditions of a total daily dose volume of 28 gallons and a 

total flush volume of 1 gallon per flush. 

Anomalies between influent and effluent results were due to the non-homogeneity and 

high variability of the influent feed and treated effluent (see Section 4.3). Such problems are 

expected with raw, complex wastewater with high amounts of unmacerated solids. 

7.2	 Gross Mechanical Laboratories, Inc. 

Gross Mechanical Laboratories (GROCO) Submission – 7/15/08 

This is in response to ERG’s Performance Evaluation Report (draft) of Type I MSDs. 

While we recognize the good intent of this evaluation, GROCO respectfully objects to the test 

procedure employed for the re-test, and questions the results. Following are our objections in 

several specific areas of concern: 

1.	 The dosing system that was employed clearly overloaded Thermopure-2, forcing 

untreated sewage through the system and causing unacceptable fecal coliform 

bacteria counts in the effluent. As stated on page 5-1 paragraph-2, the retest 

dosing was conducted using the same dosing schedule as in the April test. Page 5­

4 indicates that Thermopure-2 overflowed, further supporting our claim that the 

dosing schedule exceeded system capacity. In normal operation, audible and 

visual alarms alert the user that the holding tank is at (approximately) 75% 

capacity, but the automatic dosing procedure employed during the retest ignored 

the built-in warnings. Additionally, by forcing unprocessed sewage through the 

system, related symptoms such as low temperature measurements reported on 

Page 5-2 may have been caused. Such readings may be attributed to siphoning of 

7-3
 

Performance Evaluation Report for Type I MSDs 

sewage past a clogged or sticking vacuum breaker (part of the plumbing system to 

and from the treatment block), and caused by the forced over-dosing. 

2.	 Table 4-15 shows effluent samples contained a greater fecal coliform bacteria 

count than the influent. This is not possible. 

3.	 Project 0214.00.020 appears to have been conducted in consideration of 

33CFR159.121 (d) as it pertains to large vessel systems. Type-I MSDs are 

intended for use aboard small vessels (smaller than 65-feet in length). 

Thermopure-2 includes a holding tank that effectively stores influent received at a 

rate that is in excess of treatment capacity, thereby avoiding system overload as 

experienced during the retest. In the “real world” of small vessel toilet systems, as 

little as 1-quart of flush water is required per flush. Testing with peak capacity 

dosing is not appropriate. 

4.	 Prior to sending a Thermopure-2 unit for retest in November, 2007 GROCO 

submitted effluent samples to an independent lab for fecal coliform bacteria 

count. Using test method SM209221E, the results indicated consistently <2 MPN. 

On July 8, 2008 we submitted additional samples to the same lab and received 

similarly consistent satisfactory results. 

We here-by request that a retest of Thermopure-2 be conducted. 

Additional Gross Mechanical Laboratories Submission – 8/14/08 

Following are answers to questions from your August 13 e-mail: 

1.	 The heater block used in GROCO’s in-house tests is identical to the heater block 

submitted to ERG. This is a production item for us; one which we have 

manufactured for years without change. The effluent flow volume in our test is 

also identical to that of the unit you received for the re-test. Thermopure-2 control 

software limits pump run time so as not to exceed the volume of the heater block. 

The resulting effluent measures approximately 500 ml. 

7-4
 

Performance Evaluation Report for Type I MSDs 

2.	 Attached are copies of results from Chesapeake Labs, Inc. The report from 

November 14, 2007 was the result of effluent sampling following our software 

correction, prior to the re-test. The report from July 8, 2008 tests samples from the 

same GROCO test unit from which the November 2007 samples were produced. 

These were tested after receiving your re-test test report indicating that we were 

not eliminating fecal coliform bacteria. 

3.	 Unit testing and sampling was conducted in-house. GROCO has a fully 

operational unit which has been in operation for approximately 10-years. The test 

unit receives “live” raw sewage from a marine toilet used by me, not diluted or 

otherwise controlled test influent. There is no question that the influent used 

contains ample fecal coliform bacteria. The test unit is not tilted, and our test 

procedure is simply that the system is used “normally” as follows: 

a.	 the toilet is used and flushed 

b.	 the Thermopure-2 unit holding tank receives the influent 

c.	 the level sensor recognizes increased holding tank level and turns on the 

heater 

d.	 when the appropriate level of heat has been achieved, waste is processed 

and discharged 

e.	 all samples were collected by me personally, as received directly from the 

discharge hose from the treatment block. Samples were captured into 

sterile sample bottles furnished by Chesapeake Labs. Immediately after 

catching each sample, the bottles were capped, placed into a cooler with 

ice, and delivered within 1-hour to Chesapeake Labs. for testing in 

compliance with Fecal Coliform Method SM209221E. 

Our test unit does not consider average flow or peak flow; “real world” rates of usage are 

employed, and the rate of processing effluent does not change with the rate of influent. The 

holding tank portion of Thermopure-2 is fully capable of handling additional influent volume as 

might be imposed during peak flow conditions. 

If additional information is required please contact me. 

7-5
 

Performance Evaluation Report for Type I MSDs 

Response to GROCO Submissions 

The dosing schedule is well within the average and peak capacity of the Thermopure-2 

unit as indicated in the unit documentation (see Appendix B of this report for the challenge 

wastewater dosing schedule). Specifically, peak flow was as designated by the manufacturer as 

50 gallons per eight-hour day or about 1 gallon every 10 minutes, based on an assumed challenge 

wastewater temperature of 68°F (20°C). Off-peak (average) process flow was based on an 

assumption of four passengers each using the toilet five times in an eight-hour day. This resulted 

in an off-peak flow of 20 gallons in an eight-hour day or 1 gallon of wastewater every 24 

minutes. Thermopure-2 product specifications indicate a maximum treatment capacity ranging 

from 40 gallons per day (65°F flush water) to 60 gallons per eight-hour day (80°F flush water); 

there is no specified total flush volume. These compare to the test conditions of a total daily dose 

volume of 32 gallons and a total flush volume of 1 gallon per flush. Flush water temperature was 

68°F (20°C) during April 2007 testing, and 72°F (22°C) during November/December 2007 

testing. 

The Thermopure-2 holding tank overflowed briefly during one combined “tilt” 

event/peak flow dose. Neither the dosing schedule, nor the dosed volumes administered, 

exceeded the treatment capacity of the unit as specified by unit documentation. 

The design of the Thermopure-2 unit and placement of components, piping, and 

connections make it extremely unlikely that wastewater could be forced or siphoned through the 

system. First, movement of untreated wastewater out of the holding tank into the treatment block 

occurs only when the macerator pump located inside the holding tank operates to transfer fluid to 

the treatment block. Therefore, while the dosing system moves wastewater into the holding tank, 

it does not move or “force” wastewater through the remainder of the system. Gross Mechanical 

Laboratories, Inc. confirms this in their August 14 response: “the rate of processing effluent does 

not change with the rate of influent. The holding tank portion of Thermopure-2 is fully capable 

of handling additional influent volume as might be imposed during peak flow conditions.” 

Second, the treatment system design incorporates discharge vented loops, which are essentially 

atmospheric vacuum breakers that function to prevent siphoning of fluids. These vented loops 

were installed in accordance with the configuration indicated in the manufacturer’s literature. A 

Gross Mechanical Laboratories, Inc. representative visited the test facility and verified proper 

device installation (see Section 4.1.1). Third, as experienced during day eight of the original test, 

a malfunction caused the vacuum breaker to leak when under pump pressure and did not allow 

7-6
 

Performance Evaluation Report for Type I MSDs 

siphoning. Fourth, the sample technician monitored all unit discharges during testing, and no 

siphoning or other inappropriate discharges were observed. 

Anomalies between influent and effluent results were due to the non-homogeneity and 

high variability of the influent feed and treated effluent (see Section 4.3). Such problems are 

expected with raw, complex wastewater with high amounts of unmacerated solids. 

The performance evaluations of Type I MSDs were conducted in accordance with the 

Sewage Processing Test contained in the regulations at 33 CFR 159.121. One exception to the 

USCG’s Sewage Processing Test requirements is that, for reasons of practicality, testing was 

conducted using a feed of fresh domestic human sewage rather than human sewage in a ratio of 

four urinations to one defecation, as specified in Section (c). Furthermore, for this evaluation, 

testing was not limited to fecal coliform bacteria and visible floating solids measured in the 

treated effluent, but rather included a variety of analyses of both influent and effluent samples to 

measure the effectiveness of each treatment device and to characterize influent and effluent 

quality. Specific to the retesting, testing that was not at least 10 days within a 20-day period. In 

every other regard, the Raritan device was tested using the 33 CFR 159.121 protocols, including 

Section (c). The Raritan device was not tested in accordance to Section (d), as this device does 

not process or discharge sewage continuously, nor was the device modified in any way to operate 

continuously. 

The Sewage Processing Test contained in the regulations at 33 CFR 159.121 specifies 

that systems must process sewage at peak capacity during three periods of each day of testing. 

Although the cause of the unit not performing to the specified manufacturer’s standard is 

unknown, the cause may be a discrepancy between the unit’s design pump-out flow, versus 

actual pump-out flow. In their August 14 submission, Gross Mechanical Laboratories, Inc, states 

that the “Thermopure-2 control software limits pump run time so as not to exceed the volume of 

the heater block” and that “the resulting effluent measures approximately 500 ml.” Actual pumpout volumes measured by test facility personnel using a graduated cylinder were a constant 1,000 

mL to 1,200 mL over the two-second pump-out period. An actual pump-out volume of more than 

twice the design rate suggests that unheated (untreated) wastewater may have been pumped out 

along with treated wastewater, which could account for the unit not performing to specified 

manufacturer’s standard. 

7-7
 

Performance Evaluation Report for Type I MSDs 

Appendix A 
 

33 CFR 159 Excerpts 
 
Performance Evaluation Report for Type I MSDs 

33 CFR § 159.53 General requirements. 

A device must: 

(a) Under the test conditions described in §§159.123 and 159.125, produce an effluent having a 

fecal coliform bacteria count not greater than 1,000 per 100 milliliters and no visible floating 

solids (Type I), 

(b) Under the test conditions described in §§159.126 and 159.126a, produce an effluent having a 

fecal coliform bacteria count not greater than 200 per 100 milliliters and suspended solids not 

greater than 150 milligrams per liter (Type II), or 

(c) Be designed to prevent the overboard discharge of treated or untreated sewage or any waste 

derived from sewage (Type III). 

33 CFR § 159.121 Sewage processing test. 

(a) The device must process human sewage in the manner for which it is designed when tested in 

accordance with this section. There must be no sewage or sewage-treating chemicals remaining 

on surfaces or in crevices that could come in contact with a person using the device or servicing 

the device in accordance with the instructions supplied under §159.57(b)(7). 

(b) During the test the device must be operated and maintained in accordance with the 

manufacturer's instructions. Any initial start-up time specified by the manufacturer must be 

allowed before test periods begin. For 1 hour of each 8-hour test period, the device must be tilted 

to the maximum angles specified by the manufacturer under §§159.55 and 159.57. 

(c) Except for devices described in paragraph (d) of this section, the devices must process and 

discharge or store human sewage over at least an 8-consecutive hour period on at least 10 days 

within a 20-day period. The device must receive human sewage consisting of fecal matter, urine, 

and toilet paper in a ratio of four urinations to one defecation with at least one defecation per 

person per day. Devices must be tested at their average rate of capacity as specified in §159.57. 

In addition, during three periods of each day the system must process sewage at the peak 

capacity for the period of time it is rated at peak capacity. 

(d) A device that processes and discharges continuously between individual use periods or a 

large device, as determined by the Coast Guard, must process and discharge sewage over at least 

10-consecutive days at the average daily capacity specified by the manufacturer. During three 

periods of each day the system must process sewage at the peak capacity for the period of time it 

is rated at peak capacity. The sewage for this test must be fresh, domestic sewage to which 

primary sludge has been added, as necessary, to create a test sewage with a minimum of 500 

milligrams of suspended solids per liter. 

A-1 
 
Performance Evaluation Report for Type I MSDs 

33 CFR § 159.123 Coliform test: Type I devices. 

(a) The arithmetic mean of the fecal coliform bacteria in 38 of 40 samples of effluent discharged 

from a Type I device during the test described in §159.121 must be less than 1000 per 100 

milliliters when tested in accordance with 40 CFR Part 136. 

(b) The 40 samples must be taken from the device as follows: During each of the 10-test days, 

one sample must be taken at the beginning, middle, and end of an 8-consecutive hour period with 

one additional sample taken immediately following the peak capacity processing period. 

33 CFR § 159.125 Visible floating solids: Type I devices. 

During the sewage processing test (§159.121) 40 effluent samples of approximately 1 liter each 

shall be taken from a Type I device at the same time as samples taken in §159.123 and passed 

expeditiously through a U.S. Sieve No. 12 as specified in ASTM E 11 (incorporated by 

reference, see §159.4). The weight of the material retained on the screen after it has been dried to 

a constant weight in an oven at 103 °C must be divided by the volume of the sample and 

expressed as milligrams per liter. This value must be 10 percent or less of the total suspended 

solids as determined in accordance with 40 CFR Part 136 or at least 38 of the 40 samples. 

Note: 33 U.S.C. 1321(b)(3) prohibits discharge of harmful quantities of oil into or upon the 

navigable waters of the United States or adjoining shorelines or into or upon the waters of the 

contiguous zone. Under 40 CFR 110.3 and 110.4 such discharges of oil include discharges 

which: 

(a) Violate applicable water quality standards, or 

(b) Cause a film or sheen upon or discoloration of the surface of the water or adjoining 

shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon 

adjoining shorelines. If a sample contains a quantity of oil determined to be harmful, the Coast 

Guard will not certify the device. 

A-2 
 
Performance Evaluation Report for Type I MSDs 

Appendix B 
 

CHALLENGE WASTEWATER DOSING SCHEDULE
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

NSF International Waco Test Facility 
 

Marine Sanitation Device Evaluation 2007 
 

Dosing and Sample Schedule for Test Device #1 - The Electro Scan Device
 


Dose # Time Description Tilt a Sample b 

Peak 

Flow 

Dose # 

OffPeak 

Dose # 

 07:45 Challenge 

wastewater batch 

1 08:00 Peak Flow Dose #1-Infl. 1 

2 08:06 2 

3 08:12 #ES-1 (beginning) 3 

4 08:18 4 

5 08:24 #ES-2pm; #ES-2pth 5 

08:30 End of processing 

08:24 dose 

 08:30-09:00 30-min. Cool Down T1-mw-1 

6 09:00 Off-Peak Dose (1 

HR) 

T2-tw-1 1 

7 09:24 T3-ww-1 2 

8 09:48 3 

9 10:12 Peak Flow Dose 6 

10 10:18 7 

11 10:24 8 

12 10:30 9 

13 10:36 #ES-2ptu 10 

10:42 End of processing 

10:36 dose 

 10:42-11:12 30-min. Cool Down T4-thw-1 

14 11:12 Off-Peak Dose (2 

HRs) 

T1-mw-2 4 

15 11:36 T2-tw-2 5 

16 12.00 6 

17 12.15 #ES-3m (mid-day Mon. 

/Tues. /Thurs.); 

ES-2m (Wed/Fri.)

 7 

 12:30 Lab Pickup 

18 12:48 8 

19 13:12 Peak Flow Dose 11 

20 13:18 12 

21 13:24 13 

22 13:30 14 

23 13:36 #ES-3pw; #ES-3pf 15 

13:42 End of processing T3-ww-2 

B-1 
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

NSF International Waco Test Facility 
 

Marine Sanitation Device Evaluation 2007 
 

Dosing and Sample Schedule for Test Device #1 - The Electro Scan Device
 


Dose # Time Description Tilt a Sample b 

Peak 

Flow 

Dose # 

OffPeak 

Dose # 

13:26 dose 

 13:42-14:12 30-min. Cool Down T4-thw-2 

24 14:12 Off-Peak Dose (2 

HRs) 

9 

25 14:36 10 

26 15:00 T5-fw-1 

T5-fw-2 

11 

27 15:24 12 

28 15:48 #ES-4e (end of day) 13 

15:54 End of processing 

15:48 dose 

 16:30 Lab Pickup 

Dose 

Volumes 

15 

Gallons 

13 

Gallons 

TTL 

Dose 

Volume 

28 Gallons 

TTL Influent Sample Volume 6 Liters 

TTL Effluent Sample Volume 48 Liters 

a Tilting: Based upon tilting the device for one hour each day at a 30° angle from horizontal axis along each side and 

end of the device, alternating each day to ensure tilting on each side or end at least twice during the test: Tilt#1 = 

Device tilted 30° to the left of vertical axis as viewed from the inlet end elevation (to the 10:00 o’clock position); #2 

= 30° to right of vertical axis as viewed from the inlet end elevation (to the 2:00 o’clock position); #3 = Device tilted 

30° to the left of vertical axis as viewed from the inlet side elevation (to the 10:00 o’clock position); #4 = Device 

tilted 30° to the right of vertical axis as viewed from the inlet side elevation (to the 2:00 o’clock position). T1-mw-1 

= Tilt #1, Mon. /week #1, T1-mw-2 = Tilt #1, Mon. /week #2, etc. 

b

 Sample # & Description: #1 = Influent prior to dosing; #ES-1 = Effluent at beginning of dosing; #ES-2pm = Effl. 

following peak dosing on Monday; #ES-2pth = Effl. following peak dosing on Thurs.; #ES-2ptu = Effluent 

following peak dosing on Tues.; ES-3m = Effl. at mid-day on Mon/Tues/Thurs; ES-2m = Effl. at mid-day on 

Wed/Fri; #2e = Effluent at end of dosing; #ES-3pw = Effl. following peak dosing on Wed.; #ES-3pf = Effl. 

following peak dosing on Fri. 

B-2 
 
 

 

 

 

 

 

 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

NSF International Waco Test Facility 
 

Marine Sanitation Device Evaluation 2007 
 

Dosing and Sample Schedule for Test Device #2 - The Thermopure Device
 


Dose # Time Description Tilt a Sample b 

Peak 

Flow 

Dose # 

Off-Peak 

Dose # 

07:45 Challenge Wastewater Batch #1 Infl 

1 08:00 Peak Flow Dose (1 HR) 1 

2 08:10 2 

3 08:20 3 

4 08:30 #TP-1 (beginning) 4 

5 08:40 5 

6 08:50 T1-mw-1 #TP-2pm; #TP-2pth 6 

08:56 End of processing 08:50 dose 

7 08:56 Off-Peak Dose (2 HR) T2-tw-1 1 

8 09:20 T3-ww-1 2 

9 09:44 3 

10 10:08 4 

11 10:32 5 

12 10:56 Peak Flow Dose (1 HR) 7 

13 11:06 8 

14 11:16 9 

15 11:26 10 

16 11:36 11 

17 11:46 #TP-2ptu 12 

End of processing 11:46 dose T4-thw-1 

18 11:52 Off-Peak Dose (2 HR) T1-mw-2 6 

19 12:16 T2-tw-2 #TP-3m (mid-day 

Mon/Tues/Thurs); 

#TP-2m Wed/Fri

 7 

 12:30 Lab Pickup 

20 12:40 8 

21 13:04 9 

22 13:28 10 

23 13:52 Peak Flow Dose (1 HR) T3-ww-2 13 

24 14.02 T4-thw-2 14 

25 14.12 15 

26 14:22 16 

27 14:32 17 

28 14:42 18 

29 14:52 #TP-3pw; #TP-3pf 19 

End of processing 14:52 dose 

B-3 
 
 

 

 

 

 

 

 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

NSF International Waco Test Facility 
 

Marine Sanitation Device Evaluation 2007 
 

Dosing and Sample Schedule for Test Device #2 - The Thermopure Device
 


Dose # Time Description Tilt a Sample b 

Peak 

Flow 

Dose # 

Off-Peak 

Dose # 

30 14:58 Off-Peak Dose (1 HR) 11 

 15:00 T5-fw-1 

T5 fw-2 

31 15:22 12 

32 15:46 13 

15:52 End of processing 15:46 dose #TP-4e (end of day)

 16:30 Lab Pickup 

Dose 

Volumes 

by Flow 

19 

Gallons 

13 

Gallons 

TTL Dose Volume 32 Gallons 

TTL Influent Sample Volume 6 Liters 

TTL Effluent Sample Volume 48 Liters 

a Tilting: Based upon tilting the device for one hour each day at a 30° angle from horizontal axis along each side and 

end of the device, alternating each day to ensure tilting on each side or end at least twice during the test: Tilt#1 = 

Device tilted 30° to the left of vertical axis as viewed from the inlet end elevation (to the 10:00 o’clock position); #2 

= 30° to right of vertical axis as viewed from the inlet end elevation (to the 2:00 o’clock position); #3 = Device tilted 

30° to the left of vertical axis as viewed from the inlet side elevation (to the 10:00 o’clock position); #4 = Device 

tilted 30° to the right of vertical axis as viewed from the inlet side elevation (to the 2:00 o’clock position). T1-mw-1 

= Tilt #1, Mon./week #1, T1-mw-2 = Tilt #1, Mon./week #2, etc. 

b

 Sample # & Description: #1 = Influent prior to dosing; #TP-1 = Effluent at beginning of dosing; #TP-2pm = Effl. 

following peak dosing on Monday; #TP-2pth = Effl. following peak dosing on Thurs.; #TP-2ptu = Effluent 

following peak dosing on Tues.; TP-3m = Effl. at mid-day on Mon/Tues/Thurs; #TP-2m = Effl. mid-day on 

Wed/Fri; #TP-4e = Effluent at end of dosing; #TP-3pw = Effl. following peak dosing on Wed.; #TP-3pf = Effl. 

following peak dosing on Fri. 

B-4 
 
Performance Evaluation Report for Type I MSDs 

Appendix C 
 

AUDIT REPORT FOR TYPE I MSD TESTING 
 
 

 

Performance Evaluation Report for Type I MSDs 

MEMORANDUM 
 

TO: Ray Frederick, EPA 

FROM: Kathleen Wu, ERG 

DATE: May 10, 2007 

SUBJECT: Audit Report for Type I MSD Testing 

INTRODUCTION 

ERG, in support of EPA’s STREAMS Program Task Order #20, is evaluating the 

effectiveness of Type I MSDs. The two devices identified are Gross Mechanical Laboratories’ 

Thermopure-2 device and Raritan Engineering Company’s Electro Scan device. ERG prepared a 

Work Plan and a Quality Assurance Project Plan to evaluate these devices and subcontracted the 

setup and testing phase of the project to NSF International. 

AUDIT 

Kathleen Wu, ERG Scientist, conducted an audit of NSF International’s test facility to 

evaluate compliance with procedures, testing protocols, and analyses outlined in the Evaluation 

of Type I Marine Sanitation Devices (MSDs) Work Plan dated March 20, 2007 and the 

Evaluation of Type I Marine Sanitation Devices (MSDs) Quality Assurance Project Plan (QAPP) 

dated March 20, 2007. The audit was conducted at the Waco Metropolitan Area Regional 

Sewage System (WMARSS) Treatment Facility in Waco, Texas and at Aqua-Tech Laboratories, 

Inc. in Bryan, Texas. The first two days of the audit, April 9, 2007 to April 10, 2007, were spent 

at the test facility, while the last day, April 11, 2007, was spent in the lab. 

Date Location Sample Description Sampling/Laboratory Personnel 

4/09/2007 WMARSS 

Waco, Texas 

Influent, peak, and off peak samples 

from Electro Scan and Thermopure2 devices 

David Jumper, NSF 

Dustin Patton, NSF 

Jim Patton, NSF 

4/10/2007 WMARSS 

Waco, Texas 

Influent, peak, and off peak samples 

from Electro Scan and Thermopure2 devices 

David Jumper, NSF 

Dustin Patton, NSF 

Jim Patton, NSF 

4/11/2007 Aqua-Tech 

Laboratories Bryan, 

Texas 

Microbiological and TSS samples 

from Electro Scan and Thermopure2 devices 

June Brien, Aqua-Tech 

John Brien, Aqua-Tech 

During the audit, Ms. Wu observed two days of performance testing and sample 

collection. This included preparation of the challenge wastewater, device start-up procedures, 

operation of both devices at peak and off peak dosing cycle, handling of samples, and record 

keeping for both the Electro Scan and Thermopure-2 device by NSF International. She verified 

device operations, waste dosing, sample collection, field tests, field test documentation, 

instrument calibrations, daily tilting of devices, sample preservation, and transportation of the 

C-1 
 

Performance Evaluation Report for Type I MSDs 

Memorandum 

10 May 2007 

Page 2 

samples to the laboratory. She was also present during the mechanical malfunction, 

troubleshooting, and eventual repair of the Thermopure-2 device on the second day of the audit. 

The Audit evaluated the following elements: 

y	 	 Overall level of organization, professionalism, and understanding of the project; 

y	 	 Start-up and operation of both devices at peak and off peak dosing cycles per 
 

manufacturer instructions for 8 hours per day; 
 

y	 	 Set-up and preparation of challenge wastewater from the influent tank through the dosing 

system prior to testing; 

y	 	 Compliance and understanding of all activities and goals described in the Work Plan; 

y	 	 Compliance with all procedures outlined in the QAPP; 

y	 	 Documentation of samples, analysis activity, and observations; 

y	 	 Condition of field test equipment and materials; 

y	 	 Appropriate transport of the samples to the laboratory; and 

y	 	 Overall satisfaction with environment and procedures of the laboratory. 

AUDIT RESULTS 

Ms. Wu recorded her observations on the Type I MSD Testing Audit Checklists provided 

in Attachment 1. 

The site manager prepared appropriate challenge wastewater that was fed to the devices 

using an automated the dosing system following testing procedure guidelines. Facility personnel 

operated each device at start-up, during peak and off peak flows, and at the end of the testing day 

per manufacturer instructions and requirements of the Work Plan. Moreover, sample collection, 

field tests, sample handling, and paperwork requirements were administered according to the 

Work Plan and QAPP. 

Samples were transported to Aqua-Tech Laboratories, where Ms. Wu spent her third day 

of the audit observing lab procedures, documentation, and reporting, and reviewing preliminary 

TSS and E. coli results. She reviewed the lab’s documentation process and obtained the most 

recent audit report conducted by the state of Texas. Review of Aqua-Tech’s audit revealed three 

positive findings and two negative findings in their quality assurance program. Negative findings 

were resolved with corrective actions. 

C-2 
 
Performance Evaluation Report for Type I MSDs 

Memorandum 

10 May 2007 

Page 3 

Ms. Wu observed the following minor issues and their resolutions (if applicable) during 

the audit, none of which should have any impact on the analytical results or quality of the data 

obtained from this Type I MSD test program. 

y	 	 On the first day of testing, the Thermopure-2 device required more time than predicted to 

reach warm-up temperature at the beginning of the day and the target treatment 

temperature for each treatment cycle. The ambient temperature in Waco, Texas was cold 

(approximately 39°F). However, neither the dosing nor sampling schedule was delayed as 

the treatment system design includes a holding tank that stores influent wastewater in 

queue for the treatment chamber. There was more than enough effluent flow from the 

device to allow sampling to proceed as scheduled. Additionally, as testing progressed and 

continued on subsequent days, this issue was observed less and less as ambient 

temperatures increased. 

y	 	 Each treatment device had its own designated sampling equipment to minimize cross 

contamination between samples. This equipment included the field test container, 

sampling container, Alconox solution, effluent sampling tap, and all container lids, which 

were originally labeled with its designated treatment device. As sampling progressed, 

these labels were being constantly rinsed with Alconox solution and deionized water and 

began to peel off. The samplers reprinted all the labels and covered them with clear 

plastic tape to maintain their integrity. 

y	 	 Field test data sheets and total chlorine residual data sheets were originally formatted in a 

way that did not facilitate data collection over multiple days. New data sheets were 

designed to correct this error. Previously collected data were transferred to new sheets. 

y	 	 At around noon on the second day of performance testing, the Thermopure-2 device’s 

75% capacity warning light came on. Troubleshooting identified the problem as 

mechanical failure of the pump to the treatment chamber and a blown fuse. NSF 

personnel replaced both and resumed treatment within 40 minutes. In all, 3 one-gallon 

doses during the peak flow of the Thermopure-2 device were missed. No partially treated 

or untreated wastewater passed through the device, and sampling times were not affected. 

C-3 
 
Performance Evaluation Report for Type I MSDs 

Attachment 1 
 

AUDIT CHECKLISTS FOR THERMOPURE-2 AND ELECTRO SCAN DEVICES 
 

C-4 
 
 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist 

MSD Names Thermopure-2, Groco 

Auditor Kathleen Wu, ERG 

Date(s) of Audit April 9th and 10th, 2007 

Samplers David Jumper, Dustin Patton, & Jim H. Patton Ph.D., NSF 

Testing Procedures Yes No 

Is the MSD setup performed in accordance with manufacturer instructions to simulate, 

as close as possible, installation onboard a vessel? 

The device was bolted and strapped down to elevated wood boards that had the 

influent tank on the highest board and with each progressive step of the treatment 

system at a lower elevation. 

The piping chosen was designed to withstand 250°F. 

X □

Are MSDs started and operated as described in the devices’ operating manuals? 

Correct voltages were used as monitored by a voltmeter. 

The device was started by first preparing the challenge wastewater and 

recirculation loop and then connecting battery power to the dosing and treatment 

devices. 

X □

Are MSD maintenance instructions conducted according to the devices’ operating 

manuals? 

No short term maintenance operations are required by the device. 

X □

Are challenge wastewater batches prepared with a minimum concentration of 500 

mg/L TSS? 

Preliminary TSS results in the influent on the first day of sampling were 

approximately 4000 mg/L. 

X □

Is challenge waste water continuously mixed to ensure consistent feed? 

A pump circulates challenge wastewater out of and then back into the influent 

tank through a recirculation hose. 

X □

C-5 
 
 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist for Thermopure-2 (Continued) 

Testing Procedures Yes No 

Are the devices dosed for a minimum of 8 hours each day? Is the dosing pattern based 

on the design hydraulic capacity of the devices with three periods each day when 

devices are dosed at their peak capacities? 

The dosing system is designed to dose for 8 hours each day. On the second day of 

testing, the pump on the Thermopure-2 device that draws wastewater from the 

holding tank to the treatment chamber experienced a mechanical failure. The 

dosing system was shut down for about 45 minutes during its peak flow to prevent 

the device from overflowing. Although all samples were collected as scheduled, 

three one-gallon doses were missed. 

□ X 

Is there a mechanism to allow tilting of the device to an angle of 22.5° from horizontal 

along one side? 

The device was designed to allow tilting in all directions. The tilting angle was 

approximately 30°. 

X □

Are the devices periodically tilted during testing? X □

Are any operational problems and maintenance provided recorded in a field log book? 

All operational problems were summarized and recorded site personnel. 

X □

C-6 
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist for Thermopure-2 (Continued) 

Sampling Procedure Yes No 

Are the challenge wastewater samples collected immediately prior to dosing the 

device? If more than one challenge wastewater batch is dosed in one day, are the batch 

samples appropriately composited, mixed, and transferred to appropriate sample 

containers? 

Only one challenge wastewater batch was prepared each day and dosed to both 

devices, so there was no need to composite or mix influent samples. 

X □

Are the effluent samples collected with a clean pitcher that is thoroughly 

decontaminated using Alconox solution and rinsing with deionized/distilled water after 

each use? 

The device had two dedicated effluent containers, which were used to transport 

samples to the lab to be poured into sample bottles. 

X □

Are flow rates monitored and accurate for the collection type? 

The automatic dosing system is programmed to switch between peak and off peak 

as specific times. The system can be programmed to the minute. 

X □

Is the Electro Scan allowed to cool down for 30 minutes after 4 to 5 cycles? 

Not Applicable for Thermopure-2. □ □

Are the sampling locations appropriate (i.e., off the recirculation loop on the feed tank 

and a sample tap on the effluent piping from each device)? X □

Are the effluent samples taken at the appropriate time intervals (i.e., beginning, middle, 

and end of daily dosing period with one additional during peak dosing period)? X □

Are the sample containers used to collect the samples appropriately labeled? 

Sample labels listed the following information: NSF, device name, sample 

number, analyte, volume, date, time, and name of sampler. 

X □

Are sample collection containers and volumes appropriate for planned analysis per 

Table 2 of the work plan? X □

Are the sample labels adequate to prevent tampering, abrasion, smearing, or loss 

during transit? 

Labels were plastic and printed with water proof ink. Anything hand written was 

done with indelible ink. 

X □

C-7 
 
 

 

 

 

 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist for Thermopure-2 (Continued) 

Sampling Procedure Yes No 

Are the sample containers for analysis appropriately stored between sample aliquots 

(e.g., kept on ice and stored in a cooler to minimize the impact of possible inadvertent 

contamination or tampering)? 

Samples were kept in a refrigerator with a temperature setting of 4°C. 

X □

Are samplers following good sampling practices (i.e., being careful not to touch the 

inside of sample container and lid, wearing new gloves for each sample to prevent 

cross contaminations, etc.)? X □

Are all collected samples preserved according to Table 2 of the work plan? 

Aqua-Tech pre-preserved the sample containers per Table 2. X □

Is residual chlorine tested promptly following sample collection? 

Not applicable for Thermopure-2, which does not use chlorine. □ □

Is a container, separate from the sample container, used to collect sample for 

conducting pH, temperature, and salinity (Electro Scan device only) field tests on each 

sample aliquot? 

The device had a dedicated field test container that was cleaned with Alconox and 

deionized water after each use. 

A probe was used to measure temperature, pH, conductivity (even though it was 

not required for the Thermopure-2 Device), and dissolved oxygen for each 

sample. 

X □

Is the pH meter rinsed adequately between sampling points? Verify that the pH meter 

has been calibrated. 

The pH meter was calibrated at the start of each day and sits in pH of 4 buffer 

solution when not in use. 

X □

Are microbiological samples transported to the lab within 6 hours of collection? 

Samples were picked up within 5-6 hours after the first sample is taken. 

X □

Is the field test container appropriately stored between sample aliquots? X □

Are the correct QC samples and duplicate samples collected? X □

C-8 
 
 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist for Thermopure-2 (Continued) 

Sampling Procedure Yes No 

Are all equipment blanks and field duplicates prepared, collected, and stored 

appropriately after sampling? 

Field duplicates were stored with regular samples and treated as such. Equipment 

blanks were taken the week before sampling and already processed by the lab. 

X □

Are the processes and sample information, such as flow rates (peak and off peak) and 

field measurements and sample collection times recorded appropriately in a field log 

book? 

These were all programmed into the dosing system. A print out of the detailed 

schedule was provided, listing dosing times, times for peak/off peak flows, sample 

collection time, tilting times, etc 

X □

Are the sample bottles maintained on ice and packed well enough to avoid breakage 

during transport to the laboratory? 

Bottles were all plastic, placed in zip-lock bags in the coolers, and covered with 

ice. 

X □

C-9 
 
 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist 

MSD Names Electro Scan, Raritan 

Auditor Kathleen Wu, ERG 

Date(s) of Audit April 9th and 10th 2007 

Samplers David Jumper, Dustin Patton, & Jim H. Patton Ph.D., NSF 

Testing Procedures Yes No 

Is the MSD setup performed in accordance with manufacturer instructions to simulate, 

as close as possible, installation onboard a vessel? 

The device was bolted and strapped down to elevated wood boards that had the 

influent tank on the highest board and with each progressive step of the treatment 

system at a lower elevation. 

Flexible hosing used to allow for tilting. On a vessel the piping would likely be 

rigid. 

X □

Are MSDs started and operated as described in the devices’ operating manuals? 

Correct voltages were used as monitored by a voltmeter. 

The device was started by first preparing the challenge wastewater and 

recirculation loop and then connecting battery power to the dosing and treatment 

devices. 

The salt water feed system was installed as described in the manual. The salt used 

was 98% pure water softening tablets. 

X □

Are MSD maintenance instructions conducted according to the devices’ operating 

manuals? 

No short term maintenance operations are required by the device. 

X □

Are challenge wastewater batches prepared with a minimum concentration of 500 

mg/L TSS? 

Preliminary TSS results for the influent on the first day of sampling were 

approximately 4,000 mg/L. 

X □

C-10 
 
 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist for Electroscan (Continued) 

Testing Procedures Yes No 

Is challenge waste water continuously mixed to ensure consistent feed? 

A pump circulates challenge wastewater out of and then back into the influent 

tank through a recirculation hose. 

X □

Are the devices dosed for a minimum of 8 hours each day? Is the dosing pattern based 

on the design hydraulic capacity of the devices with three periods each day when 

devices are dosed at their peak capacities? 

The dosing system is designed to dose for 8 hours each day. 

X □

Is there a mechanism to allow tilting of the device to an angle of 22.5° from horizontal 

along one side? 

The device was designed to allow tilting in all directions. The tilting angle was 

approximately 30°. 

X □

Are the devices periodically tilted during testing? X □

Are any operational problems and maintenance provided recorded in a field log book? 

All operational problems were summarized and recorded by samplers. X □

C-11 
 
 

 

 

 

 

 

 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist for Electroscan (Continued) 

Sampling Procedure Yes No 

Are the challenge wastewater samples collected immediately prior to dosing the 

device? If more than one challenge wastewater batch is dosed in one day, are the batch 

samples appropriately composited, mixed, and transferred to appropriate sample 

containers? 

Only one challenge wastewater batch is prepared each day in one influent holding 

tank and dosed to both devices automatically, so there was no need to composite 

or mix influent samples. 

X □

Are the effluent samples collected with a clean pitcher that is thoroughly 

decontaminated using Alconox solution and rinsing with deionized/distilled water after 

each use? 

The device had two dedicated effluent containers, which were used to transport 

samples to the lab to be poured into sample bottles. 

X □

Are flow rates monitored and accurate for the collection type? 

The automatic dosing system is programmed to switch between peak and off peak 

as specific times. The system can be programmed to the minute. 

X □

Is the Electro Scan allowed to cool down for 30 minutes after 4 to 5 cycles? 

The cool-down cycles specified by the operating manual were preprogrammed 

into the dosing schedule. 

X □

Are the sampling locations appropriate (i.e., off the recirculation loop on the feed tank 

and a sample tap on the effluent piping from each device)? X □

Are the effluent samples taken at the appropriate time intervals (i.e., beginning, middle, 

and end of daily dosing period with one additional during peak dosing period)? X □

Are the sample containers used to collect the samples appropriately labeled? 

Sample labels listed the following information: NSF, device name, sample 

number, analyte, volume, date, time, and name of sampler. 

X □

Are sample collection containers and volumes appropriate for planned analysis per 

Table 2 of the work plan? X □

C-12 
 
 

 

 

 

 

 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist for Electroscan (Continued) 

Sampling Procedure Yes No 

Are the sample labels adequate to prevent tampering, abrasion, smearing, or loss 

during transit? 

Labels were plastic and printed with water proof ink. Anything hand written was 

done with indelible ink. 

X □

Are the sample containers for analysis appropriately stored between sample aliquots 

(e.g., kept on ice and stored in a cooler to minimize the impact of possible inadvertent 

contamination or tampering)? 

Samples were kept in a refrigerator with a temperature setting of 4°C. 

X □

Are samplers following good sampling practices (i.e., being careful not to touch the 

inside of sample container and lid, wearing new gloves for each sample to prevent 

cross contaminations, etc.)? X □

Are all collected samples preserved according to Table 2 of the work plan? 

Aqua-Tech pre-preserved the sample containers per Table 2. X □

Is residual chlorine tested promptly following sample collection? X □

Is a container, separate from the sample container, used to collect sample for 

conducting pH, temperature, and salinity (Electro Scan device only) field tests on each 

sample aliquot? 

The device had a dedicated field test container that was cleaned with Alconox and 

deionized water after each use. 

A probe was used to measured temperature, pH, conductivity, and dissolved 

oxygen for each sample. 

X □

Is the pH meter rinsed adequately between sampling points? Verify that the pH meter 

has been calibrated. 

The pH meter was calibrated at the start of each day and sits in pH of 4 buffer 

solution when not in use. 

X □

Are microbiological samples transported to the lab within 6 hours of collection? 

Samples were picked up within 5-6 hours after the first sample is taken. X □

Is the field test container appropriately stored between sample aliquots? X □

C-13 
 
 

 

 

 

Performance Evaluation Report for Type I MSDs 

Type I MSD Testing Audit Checklist for Electroscan (Continued) 

Sampling Procedure Yes No 

Are the correct QC samples and duplicate samples collected? X □

Are all equipment blanks and field duplicates prepared, collected, and stored 

appropriately after sampling? 

Field duplicates were stored with regular samples and treated as such. Equipment 

blanks were taken the week before testing and already processed by the lab. 

X □

Are the processes and sample information, such as flow rates (peak and off peak) and 

field measurements and sample collection times recorded appropriately in a field log 

book? 

These were all programmed into the dosing system. A printout of a detailed 

schedule was provided, listing dosing times, times for peak/off peak flows, sample 

collection time, tilting times, etc 

X □

Are the sample bottles maintained on ice and packed well enough to avoid breakage 

during transport to the laboratory? 

Bottles were all plastic, placed in zip-lock bags in the coolers, and covered with 

ice. 

X □

C-14