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 2010Performance 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 resear ch 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 endo rsement should be inferred. Any mention of trade names or commercial products does not constitu te endorsement or recommendation for use.

iPerformance 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 actio ns leading to a compa tible balance between human activities and the ability of natural systems to suppor t and nurture life. To meet this mandate, EPA’s research program is providi ng data and technical support for solving environmental problems today and building a sc ience knowledge base necessary to manage our ecological resources wisely, unders tand how pollutants affect our health, and prevent or reduce environmental risks in the future.
The National Risk Management Research Labora tory (NRMRL) is the Agency’s center for investigation of technological and management approaches fo r 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 prev ention and control of pollution to air, land, water, and subsurface resour ces; 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 ecosy stems. 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 pr otect and improve the environment; advancing scientific and engineering info rmation to support regulatory a nd policy decisions; and providing the technical support and information transfer to ensure implementation of environmental regulations and strategies at the na tional, state, and community levels.
This publication has been produced as part of th e Laboratory’s strategic l ong-term research plan. It is published and made available by EPA’s Of fice of Research and Development to assist the user community and to link rese archers with their clients.

Sally Gutierrez, Director National Risk Mana gement Research Laboratory

iiPerformance Evaluation Report for Type I MSDs 

## Executive Summary

Performance tests were conducted to evalua te the effectiveness of Type I Marine Sanitation Devices (MSDs) in reducing fecal colifo rm bacteria and visible floating solids (VFS). In addition, the performance evaluation described herein also included te sting for enterococci
and Escherichia coli (E. coli ) indicators, biochemical oxygen demand (BOD 5 

### ), total suspended solids (TSS), and nutrients (ammonia, total Kjel dahl nitrogen (TKN), nitr ate/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 de vices were already cer tified by the U.S. Coast Guard (USCG) to meet EPA performan ce 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 Mechan ical Laboratories, Inc ., were selected for the performance tests because th ese manufacturers were willing to provide devices for testing, and the devices represented the ra nge 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 di sinfects wastewater us ing chlorine generated from salt water, while the Thermopure-2 device disinfects wast ewater 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 wa ter. The system create s disinfectant from salt water. Flushing moves waste to the maceration chamber for particle size reduction. Subsequent flushing moves the waste to the oxidation cham ber where it is mixed and brought into direct contact with electrode plates. Wh en these plates are submerged in salt water and supplied with electricity, hypochlorous acid is formed, whic h then breaks down or ganic waste products by oxidation, including bacteria. The cy cle 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 thr ee main components: the holding tank module, SweetTankTM aeration module, and the Thermopure tr eatment 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 elimin ate bacteria. No chemicals or a dditives are required. In addition,

iiiPerformance Evaluation Report for Type I MSDs 

### the Thermopure-2 system does not require salt wate r to operate; therefore, it is equally efficient in fresh, brackish, or salt water.

Performance Testing
Performance testing was conducted using pro cedures 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 se wage rather than human sewage in a ratio of
four urinations to one defeca tion, 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 rath er included a variety of analyses of both influent and effluent samples to measure the effectiveness of each tr eatment 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 testi ng. An influent sample of the challenge wastewater was collected immediat ely prior to dosing the devices each day and analyzed for all parameters to characterize influent quality. MSDs were set-up, started, and operated, as cl osely as possible, to installation onboard a vessel and according to the devices’ operation manuals. Operational cons iderations 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 ca pacity 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 ad ditional sample taken following a peak dosing period each day, for a total of 4 samples per devi ce 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 ivPerformance 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 ha lf of the fecal coliform. The Thermopure-2 device did not reach the designated threshold te mperature sufficient eno ugh to kill bacteria, which may have occurred due to the therma l 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. Th e scope of the retesting was reduced due to a limitation of funding. The duration of the performance testing wa s 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 an other exception to USCG’s Sewage Processing Test requirements at 33 CFR 159.12 1(c) as testing was not at l east 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 wa stewater batch prepared each day, and testing of effluent samp les for fecal coliform, VFS, BOD 5 

### , and TSS. There were 28 effluent samples collected during the November/December retesting period. The effluent produced by the Ther mopure-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 V FS less than or equal to 10 % of the effluent TSS. While these results show some improveme nt 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.

vPerformance Evaluation Report for Type I MSDs


## T ABLE OF 

## C ONTENTS


### Page

1.0 I NTRODUCTION 

### .................................................................................................................1-1 1.1 Evaluation Objective............................................................................................1-1 1.2 Evaluation Description.........................................................................................1-1

2.0 T ECHNOLOGY 

### D ESCRIPTIONS AND 

### S PECIFICATIONS 

### ..........................................................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 P ERFORMANCE 

### E VALUATION 

### T ESTING 

### P ROCEDURES 

### .......................................................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 T EST 

### R ESULTS AND 

### D ISCUSSION 

### .......................................................................................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 T HERMOPURE 

### -2 R ETEST 

### ...................................................................................................5-1 5.1 Performance Evaluation Re testing 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

viPerformance Evaluation Report for Type I MSDs



### T ABLE OF 

### C ONTENTS 

### (Continued)
Page

6.0 D ATA 

### Q UALITY 

### .................................................................................................................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 M ANUFACTURER 

### R ESPONSE 

### .............................................................................................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 WA STEWATER DOSING SCHEDULE
Appendix C: AUDIT REPORT FOR TYPE I MSD TESTING

viiPerformance Evaluation Report for Type I MSDs


## L IST OF 

## T ABLES


### Page

3-1 Influent TSS Results ....................................................................................................... . 3-6
3-2 Methods, Sample Volume, Pres ervatives, 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 Nitrog en - 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 Nitroge n - Thermopure-2.......................................................................... 4-27

viiiPerformance Evaluation Report for Type I MSDs



### L IST OF 

### T ABLES 

### (Continued)
Page
4-22 Total Kjeldahl Nitrog en - 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

ixPerformance Evaluation Report for Type I MSDs


## L IST OF 

## F IGURES


### Page
2-1 Internal Components of the El ectro Scan Treatment Tank.............................................. 2-1
2-2 Electrical Hookup of Elect ro 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

xPerformance Evaluation Report for Type I MSDs


## 1.0 I NTRODUCTION



### 1.1 Evaluation Objective
This performance test was designed to evalua te the effectiveness of two Type I Marine Sanitation Devices (MSDs): the Electro S can Model EST 12, manufactured by Raritan Engineering Company, Inc., and the Therm opure-2, manufactured by Gross Mechanical Laboratories, Inc. Performance tests were conduc ted to evaluate the e ffectiveness of Type I MSDs in reducing fecal coliform bacteria and visible floating solids (VFS). In addition, the performance evaluation described herein al so included testing for enterococci and Escherichia coli (E. coli ) indicators, biochemical oxygen demand (BOD 5 

### ), total suspended solids (TSS), and nutrients (ammonia, total Kjeldahl nitrogen (TKN), nitrate/nitrite , and total phosphorous) in both
influent to and efflue nt from the devices. The performance evaluation tests were conduc ted 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 perfor mance data on these technologies so that consumers, developers, and regulators ca n 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 pr ocedures 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 practicalit y, testing was conducted us ing a feed of fresh domestic human sewage rather than human sewage in a ratio of f our urinations to one defecation, as specified at 33 CFR 159.121(c). Fu rthermore, for this evaluati on, 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 effl uent samples to measure the effectiveness
of each treatment device and to characterize influent and effluent quality. No te that this testing was not performed for Type I MSD certificati on as both devices were already certified by the USCG to meet EPA performance st andards 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. Th e scope of the retesting was reduced due to 1-1Performance Evaluation Report for Type I MSDs


### a limitation of funding. The duration of the performance testing wa s 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 an other exception to USCG’s Sewage Processing Test requirements at 33 CFR 159.12 1(c) as testing was not at l east 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 wa stewater batch prepared each day, and testing of effluent samp les for fecal coliform, VFS, BOD 5 

### , and TSS.

1-2Performance Evaluation Report for Type I MSDs


## 2.0 T ECHNOLOGY 

## D ESCRIPTIONS AND 

## S PECIFICATIONS



### 2.1 Electro Scan

2.1.1 Description
Electro Scan (Figure 2-1) is a USCG-a pproved Type I MSD manufactured by Raritan Engineering Company, Inc. The system consists of a two-chamber treatm ent 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 de vice is designed for use on vessels 65 feet or less in length and accommodates most existing marine toilets. The de vice 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 chambe r for particle size reduction. Subsequent flushing moves the waste to the oxidation cham ber where it is mixed and brought into direct contact with electrode plates. Wh en these plates are submerged in salt water and supplied with electricity, hypochlorous acid is formed, whic h then breaks down or ganic waste products, including bacteria, by ox idation. The cycle runs for approxi mately two minutes in the second chamber, and the waste is held in the oxidation chamber until the next flushing cycle, then it is discharged.

2-1Performance 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 numbe rs in each model name. The EST 12 model was selected for performance testing. The main comp onent 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 el ectrode pack with electrodes protruding into each chamber. The first chamber, containing the macerator, reduces the sewage into tiny particles. Salt water us ed in the flush activates the elec trode in the first chamber, which produces the disinfectant that treats the sewa ge. During subsequent flushes, the macerated sewage flows up and over the partition into the se cond 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 mixe s the waste as the second set of electrodes
continues waste disinfection. Acco rding to Raritan, the treatment tank holds about four flushes, averaging 0.75 gallons per flush. Therefore, th e 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 exis ts in salt water as sodium (Na+) and chloride (Cl-)
ions.

­ 

### NaCl --> Na + 

### + Cl

2. Through hydrolysis, water (H 2 

### O) breaks into hydrogen (H + 

### ) ions and hydroxyl (OH - 

### ) ions.

H 2 

### O --> H + 

### + OH 

### 2-2Performance Evaluation Report for Type I MSDs



### 3. The electrode pack is ener gized at the anode during the treatment cycle, and electricity passes through the conductive salt water. Hydrochloric acid (HCL), and hypochlorous acid (HOCL), a powerful bact ericide 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 + H 2 

### ↑

5. The net reaction is:

2Cl - 

### + 3OH - 

### + 3H + 

### + 2Na + 

### --> HCl + HOCl + 2NaOH + H 2 

### ↑

6. Hypochlorous acid is formed when sodi um hypochlorite (NaO Cl) reacts with

water.

NaOCl + H 2 

### O --> NaOH + HOCl

7. Hypochlorous acid reacts with contaminan ts (e.g., soil, dirt, and bacteria) giving up its oxygen; leaving hydrochloric acid.

HOCl + contaminants --> HCl + contaminants O x


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

HCl + NaOH --> H 2 

### O + NaCl

Another component of this devi ce is a credit-card-si zed 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 treatme nt as a one-touch operation. When installed with a manually operated toilet (hand pump type), an optional pump sensor kit can be

2-3Performance Evaluation Report for Type I MSDs


### installed at the toilet, which is wired to, and automatically activ ates, 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 operati onal data storage. The second board is an input/output component that allows the user to make conn ections to accessories. Power switching solenoids, fuse protection, and a leaf shunt to measure th e 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 displa y provides the user with information regarding the tr eatment cycle, such as voltage status, and historical data regarding the use of the system . It also contains a reset but ton 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 gall on (15.2 L) tank with automatic water refill and salt water injection. Standard table salt is used to make th e salt solution, and this salt water is metered to the suction line of the toilet or injected direc tly into the treatment tank. The standard formula for making salt water is 4.6 ounces (oz) of non-iodized salt per gallon of water.

2-4Performance Evaluation Report for Type I MSDs

Source: Raritan Engineering Company, Inc


### Figure 2-2. Electrical Hookup of Electro Scan Components

2-5Performance 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 M echanical Laboratories, Inc. At the time of the November/December retesting, the Ther mopure-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, SweetTa nkTM aeration module, and the Thermopure-2 treatment chamber. The device is designed to be pl umbed to either a toilet head or a preexisting remote holding tank, and all functions and operations in the device are automatic.

Source: Gross Mechani cal Laboratories, Inc


### Figure 2-3. Example Insta llation for Thermopure-2

Treatment is accomplished by macerating the wa ste in the holding tank module and then pumping it thought the Thermopure-2 treatment cham ber where low-level h eat is introduced to

2-6Performance 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 repres ent the different sizes of holding tank capacity in gallons. The TP-210 model was selected for performance testing. For the Thermopure-2 device, wastewater en ters a holding tank modul e as the toilet is flushed, where it is macerated. (F or 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 deve loped to eliminate odors in holding tanks without the use of chemicals or filters. Instea d, 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 Mechani cal Laboratories, Inc



### Figure 2-4. SweetTankTM Setup

Whenever macerated wastewater is dete cted in the holding tank module and the macerator has operated for a set amount of tim e, 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 bact eria. (Gross Mechanical Laborato ries, Inc. representatives did not provide the length of maceration time or ope rating temperature of the device.) If the two

2-7Performance Evaluation Report for Type I MSDs 

### modules are not at the same height, the de vice will not pump properly and will require the
installation of a HVL-750 3/4 in. Ve nted Loop, which is sold separately. After a treatment cycle,
the treated waste is th en pumped overboard.
When no wastewater is detected in the holding tank module, the device automatically enters stand-by mode. However, when the holding ta nk module is close to full, use of the toilets must stop as additional flushi ng will overflow the device. The treatment unit also has an operation pa nel (Figure 2-5), which gives the user information about the system. At 10% capacit y, a yellow light on the panel indicates the
initiation of treatment and discha rge, assuming the system is alr eady 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 th e panel includes alternating current (AC) and direct current (DC) power “on” indicators, a syst em 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 por t to clear blockages,
should one occur.

Source: Gross Mechani cal Laboratories, Inc


### Figure 2-5. Electrical H ookup for Thermopure-2

2-8Performance Evaluation Report for Type I MSDs 

### Warm-up time for the device (measured from th e time AC power is first applied to when the device is ready to treat and discharge) is ap proximately 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 milliamp eres (mA) of DC circuit power is used.

2-9Electro Scan device is in the foreground and Thermopure-2 device is in the background. Dosing system shown in upper left and effluent recei ving tanks in lower right. Performance Evaluation Report for Type I MSDs


## 3.0 P ERFORMANCE 

## E VALUATION 

## T ESTING 

## P ROCEDURES



### 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 wastewat er 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 system s. The size of the two devices allowed them to
be installed in a manner convenient for dosi ng and sampling. As shown in Figure 3-1, the devices were installed on plywood platforms, ta king into account the conf iguration indicated in
the manufacturers’ literature.

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

1 NSF’s facility located in An n Arbor, Michigan is curren tly 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. su bfacility currently is no t accepted as a Recognized Facility by the USCG. 

### 3-1Performance 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 insta lled 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 pe rformed along the edges of each device over the course of the testing. The tilt angl es were pre-set, but were also verified during each tilt event using an inclinometer. Figure 3-2 shows the de vices during testing in the tilted position.

Figure 3-2. Tilting Mechanism for MSDs

Dosing was accomplished through use of infrastr ucture 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 in tervals 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

3-2Performance Evaluation Report for Type I MSDs 

### bucket and then turned off the pump. Each bucke t was calibrated before implementing the test (including the volume of pipe and valve) to ensu re 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 gr avity flow to the respective test device. The Electro Scan device required a separate input signal from th e timer used to control dosing through a 12 VDC converter, sinc e 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 pol yethylene effluent re ceiving container. Treated effluent accumulated in the receiving cont ainers to ensure a sufficient effluent volume for sampling analysis. The effluent receiving c ontainers were emptied, decontaminated, and returned to service following colle ction 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 wa ter per the manufacturer’s instructions and placed into operation. No leaks were found, measur es for voltage and amperage to the device were found appropriate, and the de vice was placed into operation. The control panel fuse burned out after two cycles of operat ion and the wire size was change d 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 manufactur er 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 operati on for sewage processing.

3-3Performance 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 wa s 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 ta nk, which was found to be free of leaks, was provided by the manufacturer a nd placed into operation.

3.4 Sewage Processing Test
The sewage processing test was performe d 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 urin ations to one defecation, as specified at 33 CFR 159.121(c), for reasons of practicality. Testing was performe d over an eight-hour period for 10 days (five week days per week for two consecutive weeks). During th is period, the MSDs we re challenged with wastewater at the average loading flow, with th ree periods of each day of the MSDs processing waste at the peak capacity. The testing dates were Apr il 9 through 13, 2007, and April 16 through 20, 2007. The MSDs were tilted to an a ngle 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 pr event 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 3-4Performance Evaluation Report for Type I MSDs 

### cool-down period, as mentioned above. The tota l daily volume processed was approximately 28 gallons. The wastewater dosing sc hedule for the Electro Scan is included in Appendix B. The
Electro Scan device was dosed da ily with 28, 1-gallon doses over the entire 10-day test period.

Thermopure-2 Device
As indicated in the technology descripti on, the Thermopure-2 device dosing pattern was designed based on an assumed challenge wastew ater 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 pe ak (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 wastewat er every 24 minutes. The total daily volume of wastewater processed was a pproximately 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 dosi ng. A 1/3 horsepower circulating pump, used to minimize solids settling in the ba tch tank, was turned on and allo wed to run during the 30-minute setup period before initial dosing, and conti nued operating throughout th e 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 ah ead 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 ra w 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 wate r pump to achieve the target volume for TSS
concentration.

3-5Performance Evaluation Report for Type I MSDs 

### Variations in the primary sludge solids concen trations accounted fo r 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 concentratio ns 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 fi ve 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 provi de about a 3% salt solution for in jection into the device. While it was not possible to record th e 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

3-6Performance Evaluation Report for Type I MSDs 

### of the testing, includ ing the trial run prior to th e start of the test , a total of 39 pounds of solar salt
was added to the salt tank. Operationally, maintena nce was provided several days during the test:

y Day eight – An error me ssage on the cont rol 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 pow er was turned off then back on, and the panel returned to the normal status of “R eady 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 sa lt in the salt tank should be ch ecked. A visual check of the tank found the salt dosing pump running cont inuously. The device was reset by shutting off the water and power to the pump, then re starting. The warning was repeated during the day, with about 10 pounds of salt being a dded to the tank over the course of the day. For the latter part of the day, the power to the pump ha d to be disconnected between doses to keep it from running continuously and getting control pane l operational errors. At the end of the day, power was reset to th e 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, maintena nce was provided several days during the test:

y Day two – The device wa s not pumping out e ffluent, 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 he ard running, but still with no discharge.

3-7Performance Evaluation Report for Type I MSDs 

### The device was shut down, missing four dos es, 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 shaf t 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 alar m sounded and the 10% and 75% warning lights blinke d. No cause was found for this condition, and the alarms stopped after about 20 minutes following th e 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 re moving the retainer clip and allowing the compressor to hang by the plastic air line a nd wiring. The compressor operated without
noise for the remainder of the test.

y Day seven – The same condition of warni ng 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 wa s discontinued and the manufacturer contacted. Site personnel, working with th e 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 sa mples 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 manufa cturer 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

3-8Performance Evaluation Report for Type I MSDs 

### may have been out of the water. The de vice was righted for 30 seconds and the emergency pump-out switch was activated to pr event 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 wastew ater) 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 starte d 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 requ ired to obtain sufficien t 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 Diagr am of Sampling Points

A grab sample of the challenge wastewater (mixed contents of the batch tank) was
collected from the outlet of th e recirculation pump immediately prior to dosing to the devices each day, for a total of 10 samples. Grab sample s 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 decontam inated using Alconox cleaning solution and
deionized/distilled water rinse after each use.

3-9Performance Evaluation Report for Type I MSDs 

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

Reference/Method Name Sample Volume (mL) Preservative a 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 H 2 SO 4 , 4C 28 days 353.2 Nitrate/ Nitrite 100 H 2 SO 4 , 4C 28 days 351.2 Kjeldahl nitrogen 500 H 2 SO 4 , 4C 28 days 365.2 Total phosphorus 50 H 2 SO 4 , 4C 28 days Hach #58700-00 Residual chlorine 50 None None 9221 C Fecal coliform 100 Na 2 S 2 O 3 b

, 4C 6 hour Enterolert® Enterococcus 100 Na 2 S 2 O 3 b , 4C 6 hour Colilert® E. coli 100 Na 2 S 2 O 3 b

, 4C 6 hour 33 CFR 159.125 Visible Floating Solids 1000 None None

a Sample containers were pre-preserved with chemical pres ervatives as appropriate, an d proper sample preservation was verified upon sample receipt at the laboratory. b Na 2 S 2 O 3 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 sa mples 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 c ontainers 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 bo ttles 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 we re 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 An n Arbor, Michigan is curren tly 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. su bfacility currently is no t accepted as a Recognized Facility by the USCG. 

### 3-10Performance 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 c ourse of the evaluation. Monitoring parameters were measured at regular interval s over the course of testing. Each grab sample of challenge water and effl uent was tested for pH and temperature to monitor the operating conditions of the test sy stem. Conductivity testing was also completed on
the influent and effluent wastewat er for the Electro Scan device.

y pH: Analyses for pH were performed accordin g to SM 4500-H. A three-point calibration was performed each day that th e meter was used for testing.

y Temperature: Temperature was measured according to SM 2550.

y Conductivity: Salt content of challenge water and tr eated 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 ar e required for all methods. The purpose of equipment blanks is to docum ent adequate decontamination of sampling equipment before use and to evaluate possibl e contamination caused by sampling equipment or by sampling equipment decontamination procedur es. Sampling equipment included the effluent receiving containers for each de vice 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 anal yzed 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 collec tion, handling, preparation, and 3-11Performance Evaluation Report for Type I MSDs 

### analysis. Test personnel collected field duplicate samples si multaneously 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 th e deviations below:

y Malfunction of effluent pump on the Therm opure-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 Ther mopure-2 device on day seven resulted in eighteen missed doses of challenge wastew ater and two missed effluent samples.

3-12Performance Evaluation Report for Type I MSDs


## 4.0 T EST 

## R ESULTS AND 

## D ISCUSSION 

### This section presents the data collected duri ng 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 Thermo pure-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 cont acted representatives of Gross Mechanical Laboratories, Inc., the manufacturer of the Th ermopure-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 dr illed recess in the heati ng 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 co nducted 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). 

### 4-1Performance 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 te mperatures ranging betw een 61oC and 85oC were observed, which the representative st ated was perfect working order. This compares to effluent temperatures ranging between 38o C and 49oC during the performan ce 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 assembl y. Given that the sensor is a pproximately 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 approxim ately 3/8-in., it does not appear likely that the
sensor could have sli pped out during shipping.

4.1.2 Visible Floating Solids
Table 4-2 presents the VFS data for the Elect ro Scan device, and Table 4-16 presents the VFS data for the Thermopure-2 device. Note th at two effluent samples were missed for the Thermopure-2 device as discussed in Section 3.9, resulting in a to tal 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. Siev e No. 12 (openings of 0.0661 in. or 1.68 mm). The
material retained on the sieve is dried to a cons tant weight at 103 °C and reported in mg/L. VFS is also reported as a percen tage 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 ra nged from zero to 1,600 mg/L with a mean concentration of 66 mg/L (see Table 4-16). For th e 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 co nducted 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). 

### 4-2Performance Evaluation Report for Type I MSDs 

### 1,000 mg/L. Of these, eight samples had corresp onding VFS concentrations that were 10% or less than the TSS concentration and two samples di d not. While the Electro Scan effluent sample with the highest TSS concentration had a corr esponding 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 c oncentrations that were 10% or less than the TSS concentration (including the sample with the highest TSS concen tration), 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 f ecal streptococcus and is the most efficient bacterial indicator of water quality. (Fecal strept ococcus 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 gastroin testinal illnesses associated w ith swimming. The studies support
the use of E. coli and enterococci (instead of fecal coli form) as indicators of microbiological pollution. 5 

### There are currently no E. coli or enterococci federal perf ormance standards for Type I
MSDs. Pathogen indicators generally we re not detected in the effl uent 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 concentrati ons 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. 

### 4-3Performance Evaluation Report for Type I MSDs 

### Both pathogen indicators were detected at elevated concentra tions 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 desi gnated threshold temperature sufficient to kill
bacteria.

4.2.2 Biochemical Oxygen Demand and Total Suspended Solids
Tables 4-5 and 4-6 present BOD 5 

### and TSS data, respectively, for the Electro Scan device, and Tables 4-19 and 4-20 present BOD 5 

### and TSS data, respectively, for the Thermopure-2
device. BOD 5 

### and TSS were detected in all effluent samples for both devices. There are currently
no BOD 5 

### or TSS federal performance standards for Type I MSDs. The following table, for the purpose of compar ison, shows the effluent quality from the Type I MSDs (which are not required to remove BOD 5 

### or TSS) and EPA’s standards for secondary treatment for land-based publicly ow ned treatment works (POTWs). Note that the technology and capacity of Type I MSDs and POTWs are very differe nt and must be considered in any comparison.

BOD 5 

### 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 BOD 5 (mg/L) 780 920 45 TSS (mg/L) 1,000 1,000 45

a 40 CFR 133.102 Secondary Treatme nt 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 da ta 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 fo r both devices. There are currently no nutrient federal performance standards for Type I MSDs.

4-4Performance 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 prot eins 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 unchara cteristic pH excursions in the challenge
wastewater or the treated effluent. Temperature variations for the Electro Scan de vice (see Table 4-12) re flect variations in ambient temperatures at the test site. On average, influent and effluent temp eratures were similar, which is expected as the Electro Scan device does not affect wastewater te mperature. In contrast, effluent temperatures for the Th ermopure-2 device were greater th an 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 th e designated temperature sufficient to kill
bacteria. Elevated effluent conductivity as compared to influent condu ctivity for the Electro Scan device (see Table 4-13) results fr om the salt addition required fo r the electrodes to generate chlorine residual. Successful genera tion of residual chlorine is demonstrated by the free and total chlorine residual results provide d in Table 4-14. Conductivity and ch lorine 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 concentr ations 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 te st 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 currentl y no federal performance standards for Type I MSDs for parameters other than fecal coliform and VFS. 

### 4-5Performance Evaluation Report for Type I MSDs 

### for most analyses as illustrated by high standa rd deviations. Challenge wastewater and treated effluent are not homogeneous, and sample con centrations are highly dependent on the amount solids in the individual grab samples. Such variab ility is expected with raw, complex wastewater with high amounts of solids. With th e exception of the fecal coliform, E. coli , and enterococci sample results, extreme variability in influe nt and effluent sample results preclude any meaningful assessment of MSD performance efficiency.
The Electro Scan device remove d almost all fecal coliform, E. coli , and enterococci (99.99% or greater). In contrast , the performance of the Therm opure-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 re sulted in the device not reaching the designated threshold temperature sufficient to kill bacteria.

4-6Performance 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 concen tration is greater than the reported upper limit. < - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).



### 4-7Performance 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



### 4-8Performance 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 concen tration is greater than the reported upper limit. < - Average result includes at least on e non-detect value (calculation uses de tection limits for non-detected results).



### 4-9Performance 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 concen tration is greater than the reported upper limit. < - Average result includes at least on e non-detect value (calculation uses de tection limits for non-detected results).



### 4-10Performance 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 la boratory error (see Section 6.1).



### 4-11Performance 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



### 4-12Performance 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



### 4-13Performance 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



### 4-14Performance 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 on e non-detect value (calculation uses de tection limits for non-detected results).



### 4-15Performance 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



### 4-16Performance 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



### 4-17Performance 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



### 4-18Performance 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



### 4-19Performance 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



### 4-20Performance 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 on e non-detect value (calculation uses de tection limits for non-detected results).



### 4-21Performance Evaluation Report for Type I MSDs



### Table 4-16. Visible Floati ng 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).



### 4-22Performance 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 (c alculation uses detection limits for non-detected results). 

### 4-23Performance 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 on e non-detect value (calculation uses de tection limits for non-detected results).



### 4-24Performance 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 la boratory error (see Section 6.1). NC – Sample not collected due to unit operating problems (see Section 3.9).



### 4-25Performance 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).



### 4-26Performance 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). 

### 4-27Performance 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).



### 4-28Performance 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 on e non-detect value (calculation uses de tection limits for non-detected results).



### 4-29Performance 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).



### 4-30Performance 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 no t collected due to unit operating problems (see Section 3.9).



### 4-31Performance 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 no t collected due to unit operating problems (see Section 3.9).



### 4-32Performance Evaluation Report for Type I MSDsTable 4-27. Summary of Type I MSD PerformanceAnalysisAverage Influent Concentration ± StandardDeviationAverage Effluent Concentration ± StandardDeviationUnitElectro ScanThermopure-2Fecal Coliform9,500,000± 9,100,000<82 ± 350<4,500,000 ±6,100,000MPN/100mLVisible Floating Solids-­190 ± 86066 ± 260mg/LEscherichia coli9,100,000 ± 5,600,000<1,400 ± 5,500<4,000,000 ± 5,200,000MPN/100mLEnterococci2,000,000 ± 2,700,000<790 ± 3,900<320,000 ± 410,000MPN/100mLBiochemical Oxygen Demand (5 day)950 ± 630780 ± 600920 ± 850mg/LTotal Suspended Solids2,500 ± 3,6001,000 ± 8601,000 ± 1,300mg/LAmmonia as Nitrogen15 ± 3.08.2 ± 4.716 ± 4.5mg/LTotal Kjeldahl Nitrogen110 ± 8942 ± 2359 ± 24mg/LNitrate/Nitrite as Nitrogen<0.09 ± 0.078<2.1 ± 1.9<0.17 ± 0.11mg/LTotal Phosphorus30 ± 2815 ± 8.415 ± 11mg/LpH5.8 to 7.05.8 to 6.85.4 to 7.4-­Temperature20 ± 2.421 ± 4.343 ± 3.5°CConductivity0.27 ± 0.3722 ± 22-­mS/cmChlorine Residual (Free)-­1.0 ± 1.0-­mg/LChlorine Residual (Total)-­2.7 ± 1.8-­mg/L< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).4-33Performance Evaluation Report for Type I MSDs


## 5.0 T HERMOPURE 

## -2 R ETEST 

### The Thermopure-2 unit is believed to ha ve not reached the designated threshold temperature sufficient to kill bacteria due to th e misalignment of a thermal sensor. Per a request by Gross Mechanical Laboratorie s, Inc., a retest of a repl acement Thermopure-2 device was conducted. The scope of the retes ting was reduced from that of the original test due to a limitation in funding. Accordingly, ch allenge wastewater sampling a nd analysis was reduced to a single sample of the challenge wastewater batc h prepared each day to verify the target TSS concentration of 500 mg/L. Effluent sampling re mained at four samples per day; however, sample analyses were reduced to feca l coliform, visible floating solids, BOD 5 

### , and TSS. The duration of the performance testi ng 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 manufactur er, 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 testi ng was used. A trial run of the system was completed on October 13, using fresh water follo wing the start-up procedures provided by the manufacturer. The device was found to be ready for testing. Retesting with challenge wastewater began on Octobe r 15, using the same dosing schedule as the April testing. While sample effl uent temperatures were higher than those measured during the April testing, they were not as high as the manuf acturer indicated they should be. Test-site personnel conf erred with the manufacturer, who expressed confidence in proper operation of the device. Howe ver, 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 assi sted the manufacturer in troubleshooting the device. Specifically, they accessed the processo r chip that controls unit operation and took voltage readings as the device processed 10 cy cles of clean water over three hours. The
manufacturer confirmed that th e voltage readings indicated th at the chip was functioning as

5-1Performance Evaluation Report for Type I MSDs 

### designed. Based on this information, the ma nufacturer began eval uating whether the programming of the chip was causing the temperat ure to not reach manufac turer indicated levels. The test facility received a new processor ch ip on November 27, installed it, and verified proper operation by testing with fresh water. Re testing 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 expecte d. Following discussions with the manufacturer, test-sit e personnel investigated whethe r 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 prof ile over several four- to fiveminute treatment cycles. Over the first 60 to 90 s econds, 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 a pproximately 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 concentr ations during testing ra nged from 230 mg/L to 3,100 mg/L. There were three days during the tes ting when the influent TSS concentration was less than 500 mg/L; however, the average TSS c oncentration over the cour se of the test was 1,280 mg/L with a standard de viation of ±3,600 mg/L (1,300 mg /L ± 1,100 mg/L excluding the October testing).

5-2Performance 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, th e volume needed for each sample was reduced, allowing for collection of samples directly into sa mple bottles. This differs from the April testing where samples were collected into carboys, mi xed, 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 rete sting included duplicate samples. Equipment blanks were not required as the intermedia te sample collection carboys were not used.

Deviation from the Work Plan
Performance retesting proceeded as specifi ed in the work plan with the following
deviations:

5-3Performance 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 eval uation 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 sampli ng remained at four samples per day; however, sample analyses were reduced to fecal coliform, visibl e floating solids, BOD 5 

### , and TSS. The duration of the performance testi ng was also reduced from 10 days to nine days.

y The device overflowed during the morning of N ovember 29, which resulted in six missed doses and only 26 gallons of wastewater pro cessed 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 pro cessed the wastewater during off-peak dosing periods. The full dosing volume of 32 gallons was proce ssed 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 Thermopur e-2 retesting. The effluent produced by the Thermopure-2 device during th e November/December retesting ranged from nondetect to 3,000,000 fecal coliform bacteria MP N/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 co nducted 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). 

### 5-4Performance Evaluation Report for Type I MSDs 

### exceeded the capacity of the he ating chamber, which would have mixed unheated (untreated)
wastewater with treated wast ewater during discharge (see di scussion in Section 7.2).

5.2.2 Visible Floating Solids
Table 5-3 presents the VFS data for the Ther mopure-2 retesting. VFS concentrations in the effluent from the Thermopure-2 device du ring the November/December retesting ranged from zero to 1,000 mg/L with a mean concentrat ion 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 BOD 5 

### and TSS data, respectively, for the Thermopure-2 retesting. Both analytes were detected in all 28 samples. There are currently no BOD 5 

### or TSS federal performance standards for Type I MSDs. The following table, for the purpose of compar ison, shows the effluent quality from the Thermopure-2 device (which is not required to remove BOD 5 

### or TSS) and EPA’s standards for secondary treatment for land-based publicly ow ned treatment works (POTWs). Note that the technology and capacity of Type I MSDs and POTWs are very differe nt and must be considered in any comparison.

BOD 5 

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

Analyte Average Effluent Concen tration From Thermopure-2 EPA Secondary Treatment Standards a November/December Retesting April Testing BOD 5 (mg/L) 710 920 45 TSS (mg/L) 1,100 1,000 45

a 40 CFR 133.102 Secondary Treatme nt 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 cha llenge 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 co nducted 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). 

### 5-5Performance 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 Tabl e 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).

5-6Performance 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).



### 5-7Performance 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.



### 5-8Performance 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 concen tration is greater than the reported upper limit.



### 5-9Performance 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.



### 5-10Performance 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



### 5-11Performance 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.



### 5-12Performance Evaluation Report for Type I MSDs


## 6.0 D ATA 

## Q UALITY 

### Quality assurance/quality control (QA/QC) pr ocedures applicable to this Type I MSD performance evaluation are outlined in the Evaluation of Type I Ma rine 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 performa nce evaluation include th e 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 Labor atories, Inc., of Bryan, Texas completed the chemical and biological analyses. 9 

### Aqua-Tech prepared written da ta review narratives describing any qualifications of the analytical data. N SF 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 acce ptable quality and were excluded from the data

set:

Sample Analytical Parameter Reason for Exclusion Influent, 4/10/2007 BOD 5 Sample not analyzed due to laboratory

error. Electro Scan Effluent, 4/12/2007, 12:15 PM E. coli Laboratory determined results to be inconclusive. Electro Scan Effluent, 4/12/2007, 3:48 PM E. coli Electro Scan Effluent, 4/19/2007, 8:12 AM E. coli Retesting Equipment Blanks, 10/15/2007, 11/29/2007 BOD 5 , 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 An n Arbor, Michigan is curren tly 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. su bfacility currently is no t accepted as a Recognized Facility by the USCG. 

### 6-1Performance 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 specifi ed 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 collectio n equipment. The sample collection equipment used to collect the equipment blank was identical to that used at the sa mpling points: effluent receiving containers for each device and carboys used to colle ct, mix, and pour the challenge
wastewater and MSD effluent sa mples. 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 equipmen t 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 equipm ent blank analyses. The results showed no contamination of the influent carboy or the El ectro 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 nitr ate/nitrite, with concen trations 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. Al conox contains ethylenedia minetetraacetic 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 th e Thermopure-2 retesting as samples were collected directly into sample bottles.

6-2Performance 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. Th e relative percent difference (RPD) between the two duplicate sample results was calculated and co mpared 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 us es detection limits for non-detected results).

April Testing
Duplicate samples were colle cted as split samples poured from the same sample collection carboy to minimize sample waste stre am variability. Two duplicate samples of the challenge wastewater were collected on two di fferent days of the 10-day testing period, representing one set of duplicates for every batc h of five challenge wastewater samples. Four duplicate samples were also collected of the effl uent from each of the two MSDs throughout the 10-day testing period. Effluent duplicate samples re present 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. Thes e 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 dem onstrated by the differences in the percentages of duplicate pairs that achieve th e RPD target for challenge wastew ater versus effluent samples.

November/December Retesting

As a result of the modification to the sa mpling procedure, duplicate samples were collected as sequential grab samples. This me thodology introduced wastew ater variability into the assessment of the precision of sample co llection and analysis as compared to the
6-3Performance 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 th ree duplicate samples were collect ed 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 th e 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 eval uate 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 pr ocedures, 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 de vice operations, waste dosing, sample collection, field te sts, field test documentation, instrument calibrations, daily tilting of devices, sample preservation, and trans portation 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 th e Thermopure-2 device was also observed and documented on the second day of the audit.
ERG observed some minor issues and their re solutions (as applicable) during the audit, but none of these issues impacted the analytical results from this Type I MSD test program.
Further detailed observati ons, the audit checklists, and a list of issues and resolutions are provided in the Audit Report for Type I MSD Testing (Appendix C).

6-4Performance Evaluation Report for Type I MSDsTable 6-1. Equipment Blank ResultsAnalyteUnitInfluentCarboyElectro Scan EffluentThermopure-2 EffluentReceivingContainerCarboyReceivingContainerCarboyApril TestingFecal ColiformMPN/100 mLND(1.1)ND(1.1)ND(1.1)ND(1.1)ND(1.1)Escherichia coliMPN/100 mLND(1.0)ND(1.0)ND(1.0)ND(1.0)ND(1.0)EnterococciMPN/100 mLND(1.0)ND(1.0)ND(1.0)ND(1.0)ND(1.0)Biochemical Oxygen Demand (5 day)mg/LND(2)ND(2)ND(2)ND(2)ND(2)Total Suspended Solidsmg/LND(1)ND(1)ND(1)ND(1)ND(1)Ammonia as Nitrogenmg/LND(0.05)ND(0.05)ND(0.05)ND(0.05)ND(0.05)Total Kjeldahl Nitrogenmg/LND(0.50)ND(0.50)ND(0.50)ND(0.50)ND(0.50)Nitrate/Nitrite as Nitrogenmg/LND(0.05)ND(0.05)0.060.050.07Total Phosphorusmg/LND(0.05)ND(0.05)ND(0.05)ND(0.05)ND(0.05)ND – Not detected (number in parentheses is detection limit).6-5Performance Evaluation Report for Type I MSDsTable 6-2. Field Duplicate Analytical ResultsSampleCollectionDateTimeAnalysisUnitOriginalSampleDuplicateSampleAverageConcentrationRelative %DifferenceApril TestingInfluent4/9/20078:00AMAmmoniaas Nitrogenmg/L1313130.80%Influent4/16/20078:00 AMAmmoniaas Nitrogenmg/L1314133.0%Influent4/9/20078:00AMBiochemical Oxygen Demand (5 day)mg/L2,1001,8001,90016%Influent4/16/20078:00 AMBiochemical Oxygen Demand (5 day)mg/L8501,10099029%Influent4/9/20078:00AMEnterococciMPN/100 mL890,0001,700,0001,300,00064%Influent4/16/20078:00 AMEnterococciMPN/100 mL300,0001,600,000960,000140%Influent4/9/20078:00AMEscherichia coliMPN/100 mL5,400,0007,400,0006,400,00031%Influent4/16/20078:00AMEscherichia coliMPN/100 mL7,400,0004,800,0006,100,00043%Influent4/9/20078:00 AMFecal ColiformMPN/100 mL3,000,0005,000,0004,000,00050%Influent4/16/20078:00 AMFecal ColiformMPN/100 mL9,000,0003,000,0006,000,000100%Influent4/9/20078:00AMNitrate/Nitriteas Nitrogenmg/L0.130.090.1136%Influent4/16/20078:00 AMNitrate/Nitrite asNitrogenmg/LND(0.05)ND(0.05)ND(0.05)NCInfluent4/9/20078:00 AMTotal Kjeldahl Nitrogenmg/L19014017032%Influent4/16/20078:00 AMTotal Kjeldahl Nitrogenmg/L84627330%Influent4/9/20078:00 AMTotal Phosphorusmg/L63545915%Influent4/16/20078:00 AMTotalPhosphorusmg/L8.8121135%Influent4/9/20078:00 AMTotal Suspended Solidsmg/L4,5003,5004,00024%Influent4/16/20078:00 AMTotal Suspended Solidsmg/L8801,4001,10044%Electro Scan Effluent4/10/20078:12 AMAmmonia as Nitrogenmg/L8.17.37.710%Electro Scan Effluent4/13/20071:36 PMAmmonia as Nitrogenmg/L8.27.88.04.9%Electro Scan Effluent4/17/20078:12 AMAmmonia as Nitrogenmg/L74.45.745%Electro Scan Effluent4/20/20071:36 PMAmmonia as Nitrogenmg/L7.1161277%Electro Scan Effluent4/10/20078:12AMBiochemical Oxygen Demand (5day)mg/L1,3001,0001,20024%Electro Scan Effluent4/13/20071:36PMBiochemical Oxygen Demand (5day)mg/L3,1002,2002,60033%Electro Scan Effluent4/17/20078:12 AMBiochemical Oxygen Demand (5 day)mg/L7208007609.5%Electro Scan Effluent4/20/20071:36 PMBiochemical Oxygen Demand(5 day)mg/L5601,6001,10095%Electro Scan Effluent4/10/20078:12 AMEnterococciMPN/100 mLND(100)ND(100)ND(100)NCElectro Scan Effluent4/13/20071:36 PMEnterococciMPN/100 mLND(1.1)ND(1.1)ND(1.1)NCElectro Scan Effluent4/17/20078:12 AMEnterococciMPN/100 mLND(1.1)ND(1.1)ND(1.1)NCElectro Scan Effluent4/20/20071:36 PMEnterococciMPN/100 mLND(10)ND(10)ND(10)NC6-6Performance Evaluation Report for Type I MSDsTable 6-2. Field Duplicate Analytical Results (Continued)SampleCollectionDateTimeAnalysisUnitOriginalSampleDuplicateSampleAverageConcentrationRelative %DifferenceElectro Scan Effluent4/10/20078:12 AMEscherichia coliMPN/100 mLND(100)ND(100)ND(100)NCElectro Scan Effluent4/13/20071:36 PMEscherichia coliMPN/100 mLND(10)ND(1.1)ND(5.6)NCElectro Scan Effluent4/17/20078:12 AMEscherichia coliMPN/100 mLND(11)11<11NCElectro Scan Effluent4/20/20071:36 PMEscherichia coliMPN/100 mLND(10)ND(10)ND(10)NCElectro Scan Effluent4/10/20078:12 AMFecal ColiformMPN/100 mLND(1.1)ND(1.1)ND(1.1)NCElectro Scan Effluent4/13/20071:36 PMFecal ColiformMPN/100 mL3.3ND(1.1)<2.2NCElectro Scan Effluent4/17/20078:12 AMFecal ColiformMPN/100 mL1.1ND(1.1)<1.1NCElectro Scan Effluent4/20/20071:36 PMFecal ColiformMPN/100 mLND(1.1)ND(1.1)ND(1.1)NCElectro Scan Effluent4/10/20078:12 AMNitrate/Nitrite as Nitrogenmg/L1.11.41.226%Electro Scan Effluent4/13/20071:36 PMNitrate/Nitrite as Nitrogenmg/L1.51.41.46.4%Electro Scan Effluent4/17/20078:12 AMNitrate/Nitrite as Nitrogenmg/L1.61.31.421%Electro Scan Effluent4/20/20071:36 PMNitrate/Nitrite as Nitrogenmg/L1.21.21.22.5%Electro Scan Effluent4/10/20078:12 AMTotal Kjeldahl Nitrogenmg/L34393714%Electro Scan Effluent4/13/20071:36 PMTotal Kjeldahl Nitrogenmg/L54454917%Electro Scan Effluent4/17/20078:12 AMTotal Kjeldahl Nitrogenmg/L46504812%Electro Scan Effluent4/20/20071:36 PMTotal Kjeldahl Nitrogenmg/L54856945%Electro Scan Effluent4/10/20078:12 AMTotal Phosphorusmg/L25413348%Electro Scan Effluent4/13/20071:36 PMTotal Phosphorusmg/L14111330%Electro Scan Effluent4/17/20078:12 AMTotal Phosphorusmg/L1112117.0%Electro Scan Effluent4/20/20071:36 PMTotal Phosphorusmg/L16242041%Electro Scan Effluent4/10/20078:12 AMTotal Suspended Solidsmg/L3,1003,4003,30010%Electro Scan Effluent4/13/20071:36 PMTotal Suspended Solidsmg/L1,20073096048%Electro Scan Effluent4/17/20078:12 AMTotal Suspended Solidsmg/L8001,2001,00042%Electro Scan Effluent4/20/20071:36 PMTotal Suspended Solidsmg/L1,0001,1001,00016%Electro Scan Effluent4/12/20078:24 AMVisible Floating Solidsmg/L671108645%Electro Scan Effluent4/13/20071:36 PMVisible Floating Solidsmg/L31041180150%Electro Scan Effluent4/16/20073:48 PMVisible Floating Solidsmg/L12014013014%Electro Scan Effluent4/18/20071:36 MVisible Floating Solidsmg/L1407211065%Thermopure-2 Effluent4/11/200712:15 PMAmmonia as Nitrogenmg/L1615156.0%Thermopure-2 Effluent4/12/20073:52 PMAmmonia as Nitrogenmg/L2020203.0%Thermopure-2 Effluent4/18/200712:15 PMAmmonia as Nitrogenmg/L20232114%6-7Performance Evaluation Report for Type I MSDsTable 6-2. Field Duplicate Analytical Results (Continued)SampleCollectionDateTimeAnalysisUnitOriginalSampleDuplicateSampleAverageConcentrationRelative %DifferenceThermopure-2 Effluent4/19/20073:52 PMAmmonia as Nitrogenmg/L2222220.93%Thermopure-2 Effluent4/11/200712:15 PMBiochemical Oxygen Demand (5 day)mg/L30024027023%Thermopure-2 Effluent4/12/20073:52PMBiochemical Oxygen Demand (5day)mg/L2,2002,9002,60024%Thermopure-2 Effluent4/18/200712:15 PMBiochemical Oxygen Demand (5 day)mg/L34046040030%Thermopure-2 Effluent4/19/20073:52 PMBiochemical Oxygen Demand (5 day)mg/L30040035030%Thermopure-2 Effluent4/11/200712:15 PMEnterococciMPN/100 mL180,000130,000160,00029%Thermopure-2 Effluent4/12/20073:52 PMEnterococciMPN/100 mL110,000100,000110,00012%Thermopure-2 Effluent4/18/200712:15 PMEnterococciMPN/100 mL1,000ND(1,000)<1,000NCThermopure-2 Effluent4/19/20073:52 PMEnterococciMPN/100 mL1,000ND(1,000)<1,000NCThermopure-2 Effluent4/11/200712:15 PMEscherichia coliMPN/100 mL5,100,0002,700,0003,900,00062%Thermopure-2 Effluent4/12/20073:52 PMEscherichia coliMPN/100 mLND(20,000)ND(20,000)ND(20,000)NCThermopure-2 Effluent4/18/200712:15 PMEscherichia coliMPN/100 mLND(20,000)20,000<20,000NCThermopure-2 Effluent4/19/20073:52 PMEscherichia coliMPN/100 mLND(20,000)40,000<30,000NCThermopure-2 Effluent4/11/200712:15 PMFecalColiformMPN/100 mL3,000,0002,400,0002,700,00022%Thermopure-2 Effluent4/12/20073:52 PMFecalColiformMPN/100 mL9,000,0003,000,0006,000,000100%Thermopure-2 Effluent4/18/200712:15 PMFecal ColiformMPN/100 mLND(2,000)ND(2,000)ND(2,000)NCThermopure-2 Effluent4/19/20073:52 PMFecalColiformMPN/100 mL4,000ND(2,000)<3,000NCThermopure-2 Effluent4/11/200712:15 PMNitrate/Nitrite as Nitrogenmg/L0.150.150.150.00%Thermopure-2 Effluent4/12/20073:52 PMNitrate/Nitrite as Nitrogenmg/L0.240.240.240.00%Thermopure-2 Effluent4/18/200712:15 PMNitrate/Nitrite as Nitrogenmg/L0.250.190.2227%Thermopure-2 Effluent4/19/20073:52 PMNitrate/Nitrite as Nitrogenmg/L0.120.150.1422%Thermopure-2 Effluent4/11/200712:15 PMTotal Kjeldahl Nitrogenmg/L32463935%Thermopure-2 Effluent4/12/20073:52 PMTotal Kjeldahl Nitrogenmg/L8214011051%Thermopure-2 Effluent4/18/200712:15 PMTotal Kjeldahl Nitrogenmg/L6263622.9%Thermopure-2 Effluent4/19/20073:52 PMTotal Kjeldahl Nitrogenmg/L70506033%Thermopure-2 Effluent4/11/200712:15 PMTotal Phosphorusmg/L9.710102.0%Thermopure-2 Effluent4/12/20073:52 PMTotal Phosphorusmg/L28373226%Thermopure-2 Effluent4/18/200712:15 PMTotal Phosphorusmg/L1112126.8%Thermopure-2 Effluent4/19/20073:52 PMTotal Phosphorusmg/L9.39.49.41.9%Thermopure-2 Effluent4/11/200712:15 PMTotal Suspended Solidsmg/L2502602603.9%Thermopure-2 Effluent4/12/20073:52 PMTotalSuspended Solidsmg/L2,2002,7002,40023%6-8Performance Evaluation Report for Type I MSDsTable 6-2. Field Duplicate Analytical Results (Continued)SampleCollectionDateTimeAnalysisUnitOriginalSampleDuplicateSampleAverageConcentrationRelative %DifferenceThermopure-2 Effluent4/18/200712:15 PMTotal Suspended Solidsmg/L3603603600.00%Thermopure-2 Effluent4/19/20073:52 PMTotal Suspended Solidsmg/L28034031019%Thermopure-2 Effluent4/10/20078:30 AMVisible Floating Solidsmg/L1001001000.00%Thermopure-2 Effluent4/11/20078:30 AMVisible Floating Solidsmg/L0000.00%Thermopure-2 Effluent4/17/20073:52 PMVisible Floating Solidsmg/L2.0137.5150%Thermopure-2 Effluent4/19/200712:15 PMVisible Floating Solidsmg/L1.08.04.5160%Thermopure-2 Effluent4/20/20073:52 PMVisible Floating Solidsmg/L0000.00%October RetestingInfluent10/15/20078:05AMTSSmg/L65056060014.9November/December RetestingInfluent11/29/20078:00AMTSSmg/L1,1001,0001,1009.52Thermopure-2 Effluent12/5/200712:15PMTSSmg/L1,8002,2002,00020.0Thermopure-2 Effluent12/5/200712:15 PMBOD5mg/L1,5001,6001,6006.45Thermopure-2 Effluent12/5/200712:15 PMFecal coliformmg/L1,6009001,30056.0Thermopure-2 Effluent12/5/20078:30 AMVisible floating solidsmg/L04020200Thermopure-2 Effluent12/6/200715:52 PMTSSmg/L1,20011001,2008.70Thermopure-2 Effluent12/6/200715:52 PMBOD5mg/L1,0009109709.42Thermopure-2 Effluent12/6/200715:52 PMFecal coliformmg/L22,00022,00022,0000.00Therompure-2 Effluent12/6/20078:50 AMVisible floating solidsmg/L08241200Therompure-2 Effluent12/7/20072:52 PMVisible floating solidsmg/L94396782.7ND – 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).6-9Performance Evaluation Report for Type I MSDs


## 7.0 M ANUFACTURER 

## R ESPONSE 

### 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 th e purpose of this testing was to determine whether or not standards that have remained unchanged sin ce 1975 should be review ed. 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 st andards 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 str eams as compared to larger commercial vessels and high occupancy vessels such as cruise ships. 33 CFR Sec.159.121 Se wage Processing test
does indicate the difference in the two waste st reams and it appears testing was done based on section (d) not section (c). Sect ion (c) describes the type of sy stem the Electroscan is and all previous testing had been done ba sed on section (c). Based on the fact that the Electroscan was tested as a unit that continually processes sewa ge the system was overl oaded, 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 strept ococcus 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 gastroin testinal illnesses associated w ith swimming. The results suggest use of this on-board device is compatible with recreational waters.

7-1Performance Evaluation Report for Type I MSDs 

### The VFS test that was performe d 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 te sted based on secti on (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 requireme nts as it was not tested based on requirements. This also brings into question the results of TSS, VFS and BOD 5 

### as all tend to be inter-related. There are several days where the influent concentr ation is less than the effluent concentration which is not possible. This is documented in Table 4-5 for BOD 5 

### 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 BOD 5 

### therefore we do not fully agree with the statement on page 4-8 that “Cons equently, it is likely that apparent BOD 5 

### and TSS removals are solely a phenomenon of the wastewater, sampling, and analytical variability and not actual removal by Type I devices.” If we di scard the erroneous data of table 4-5 where effluent is higher than influent total BOD 5 

### reduction is 58.9%. Raritan believes this testing is a step in th e right direction for a ll users of recreational vessels. The intention of the law in 1975 was qui te clear - continual im provement. 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 re gulations 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 se wage rather than human sewage in a ratio of
four urinations to one defecati on, 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 include d a variety of analyses of both in fluent and effluent samples to
measure the effectiveness of each treatment devi ce and to characterize influent and effluent quality. In every other regard, the Raritan devi ce was tested using the 33 CFR 159.121 protocols, including Section (c). The Rarita n device was not tested in accord ance to Section (d), as this device does not process or discha rge sewage continuously, nor was the device modified in any way to operate continuously.

7-2Performance 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 documentati on (see Appendix B of this report for the challenge wastewater dosing schedule). Specifically, peak flow was designated by Ra ritan 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 ga llons 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 re sults were due to th e non-homogeneity and high variability of the influent feed and treate d 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 eval uation, 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 cl early overloaded Thermopure-2, forcing untreated sewage through the system and causing unacceptable fecal coliform
bacteria counts in the effluent. As st ated 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 overflowe d, further supporting our claim that the dosing schedule exceeded system capac ity. In normal operation, audible and
visual alarms alert the user that the holding tank is at (approximately) 75% capacity, but the automatic dosing proce dure employed during the retest ignored the built-in warnings. Additionally, by fo rcing unprocessed sewage through the system, related symptoms such as low temperature measurements reported on Page 5-2 may have been caused. Such read ings may be attributed to siphoning of

7-3Performance 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), a nd caused by the forced over-dosing.

2. Table 4-15 shows effluent samples contai ned 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 larg e 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 eff ectively stores influe nt received at a rate that is in excess of treatment cap acity, thereby avoiding system overload as experienced during the retest. In the “real wo rld” of small vessel toilet systems, as little as 1-quart of flush water is requir ed 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 indepe ndent lab for fecal coliform bacteria count. Using test method SM209221E, the resu lts indicated consistently <2 MPN. On July 8, 2008 we submitted additional samples to the same lab and received similarly consistent sa tisfactory results.

We here-by request that a rete st of Thermopure-2 be conducted.

Additional Gross Mechanical L aboratories 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.

7-4Performance 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 effl uent sampling following our software correction, prior to the re-t est. 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-t est test report indicating that we were not eliminating fecal coliform bacteria.

3. Unit testing and sampling was conduc ted in-house. GROCO has a fully operational unit which has been in operati on for approximately 10-years. The test unit receives “live” raw sewage from a ma rine toilet used by me, not diluted or
otherwise controlled test influent. There is no questi on that the influent used contains ample fecal coliform bacteria. Th e 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 ta nk 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 doe s not change with the rate of influent. The holding tank portion of Thermopure-2 is fully capa ble of handling additional influent volume as might be imposed during peak flow conditions. If additional information is required please contact me.

7-5Performance Evaluation Report for Type I MSDs 

### Response to GROCO Submissions
The dosing schedule is well within the aver age 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). Spec ifically, peak flow was as de signated 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 ei ght-hour day or 1 gallon of wastewater every 24 minutes. Thermopure-2 product specifications in dicate 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 comp are to the test conditions of a total daily dose volume of 32 gallons and a tota l flush volume of 1 gallon per fl ush. 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 wast ewater could be forced or siphoned through the system. First, movement of untr eated wastewater out of the hold ing 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 th e 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 holdi ng 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 desi gn incorporates discharge vented loops, which are essentially atmospheric vacuum breakers that function to pr event siphoning of fluids. These vented loops were installed in accordance with the configurati on indicated in the manufacturer’s literature. A Gross Mechanical Laboratories, In c. representative visited the te st facility and verified proper device installation (see Section 4.1.1). Third, as e xperienced during day eight of the original test,
a malfunction caused the vacuum breaker to leak when under pump pressure and did not allow 7-6Performance 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 re sults were due to th e non-homogeneity and high variability of the influent feed and treate d 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 MS Ds were conducted in accordance with the Sewage Processing Test contained in the re gulations 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 se wage rather than human sewage in a ratio of
four urinations to one defecati on, 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 include d a variety of analyses of both in fluent and effluent samples to
measure the effectiveness of each treatment devi ce 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 test ed using the 33 CFR 159.1 21 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 capac ity 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 betwee n the unit’s design pump-out flow, versus actual pump-out flow. In their August 14 submission, Gross Mechanical Laborat ories, 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 a pproximately 500 ml.” Actual pumpout volumes measured by test facility personnel using a graduated cylinde r were a constant 1,000 mL to 1,200 mL over the two-second pump-out pe riod. 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 acco unt for the unit not performing to specified
manufacturer’s standard.

7-7Performance Evaluation Report for Type I MSDs



### Appendix A
33 CFR 159 ExcerptsPerformance 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 th an 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 discharg e 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. Ther e must be no sewage or sewage-treating chemicals remaining on surfaces or in crevices that could come in c ontact with a person using the device or servicing the device in accordance with the in structions supplied under §159.57(b)(7).
(b) During the test the device must be opera ted 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 hu man sewage consisting of fecal matter, urine, and toilet paper in a ratio of f our urinations to one defecation with at least one defecation per person per day. Devices must be tested at thei r 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 con tinuously between individu al use periods or a large device, as determined by the Coast Guard, mu st process and discharg e 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 sewa ge at the peak capacity for the period of time it is rated at peak capacity. The se wage for this test must be fr esh, 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-1Performance Evaluation Report for Type I MSDs 

### 33 CFR § 159.123 Coliform test: Type I devices.
(a) The arithmetic mean of the f ecal coliform bacteria in 38 of 40 samples of effluent discharged from a Type I device during the test de scribed 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 devi ce 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 fo llowing the peak capaci ty processing period.
33 CFR § 159.125 Visible floa ting solids: Type I devices.
During the sewage processing test (§159.121) 40 effl uent 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 re tained on the screen afte r 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 Stat es 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 wate r quality standards, or
(b) Cause a film or sheen upon or discolorati on of the surface of th e water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surf ace of the water or upon adjoining shorelines. If a sample contains a quant ity of oil determined to be harmful, the Coast Guard will not certify the device.

A-2Performance Evaluation Report for Type I MSDs



### Appendix B

CHALLENGE WASTEWATER DOSING SCHEDULEPerformance 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-1Performance 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 fr om 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 th e 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-2Performance 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-3Performance 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 fr om 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 th e 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-4Performance Evaluation Report for Type I MSDs



### Appendix C

AUDIT REPORT FOR TYPE I MSD TESTINGPerformance 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

I NTRODUCTION


### ERG, in support of EPA’s STREAMS Progr am 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 pr oject to NSF International.

A UDIT


### Kathleen Wu, ERG Scientist, conducted an aud it 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) Qualit y 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, whil e the last day, April 11, 20 07, was spent in the lab.

Date Location Sample Description Sampling/Laboratory Personnel 4/09/2007 WMARSS Waco, Texas Influent, peak, and off peak samplesfrom 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 samplesfrom 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 samplesfrom Electro Scan and Thermopure2 devices June Brien, Aqua-Tech John Brien, Aqua-Tech



### During the audit, Ms. Wu observed two da ys of performance testing and sample collection. This included prepara tion of the challenge wastewat er, device start-up procedures, operation of both devices at peak and off peak dosing cycle, ha ndling of samples, and record keeping for both the Electro Scan and Thermopure -2 device by NSF International. She verified device operations, waste dosing, sample collectio n, field tests, field test documentation, instrument calibrations, daily tilting of devices, sample preservation, and transportation of the C-1Performance 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 th e second day of the audit.
The Audit evaluated the following elements:

y Overall level of organization, professiona lism, and understanding of the project;

y Start-up and operation of bot h devices at peak and off peak dosing cycles per manufacturer instructions for 8 hours per day;

y Set-up and preparation of challenge wastewat er from the influent tank through the dosing system prior to testing;

y Compliance and understanding of all activities and goals desc ribed in the Work Plan;

y Compliance with all procedur es outlined in the QAPP;

y Documentation of samples, anal ysis activity, and observations;

y Condition of field test eq uipment and materials;

y Appropriate transport of the sa mples to the laboratory; and

y Overall satisfaction with environmen t and procedures of the laboratory.

A UDIT 

### R ESULTS



### Ms. Wu recorded her observations on the T ype I MSD Testing Aud it Checklists provided in Attachment 1.
The site manager prepared appr opriate challenge wastewater that was fed to the devices using an automated the dosing system following te sting 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 a nd 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 Labor atories, where Ms. Wu spent her third day of the audit observing lab procedures, documen tation, and reporting, and reviewing preliminary TSS and E. coli results

. She reviewed the lab’s documenta tion 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-2Performance Evaluation Report for Type I MSDs



### Memorandum 10 May 2007 Page 3

Ms. Wu obs erved the following minor issues a nd their resolutions (i f 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 beginni ng of the day and the target treatment temperature for each treatment cycle. The am bient 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 sche duled. Additionally, as testing progressed and continued on subsequent days, this issu e was observed less and less as ambient temperatures increased.

y Each treatment device had its own designate d sampling equipment to minimize cross contamination between samples. This equi pment included the field test container, sampling container, Alconox solution, effluent sampling tap, and all container lids, which were originally labeled with its designate d 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 we re transferred to new sheets.

y At around noon on the second day of performa nce testing, the Thermopure-2 device’s 75% capacity warning light came on. Troubl eshooting identified the problem as mechanical failure of the pump to the treatment chamber and a blown fuse. NSF personnel replaced both and resumed treatmen t within 40 minutes. In all, 3 one-gallon doses during the peak flow of the Thermopur e-2 device were missed. No partially treated or untreated wastewater passe d through the device, and sampling times were not affected.

C-3Performance Evaluation Report for Type I MSDs



### Attachment 1

AUDIT CHECKLISTS FOR THERMOPU RE-2 AND ELECTRO SCAN DEVICES

C-4Performance 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 9 th 

### and 10 th 

### , 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 descri bed 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 batt ery power to the dosing and treatment devices. 

# X □

Are MSD maintenance instructions cond ucted 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-5Performance Evaluation Report for Type I MSDs 

### Type I MSD Testing Audit Checkli st 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 de vices with three periods each day when devices are dosed at their peak capacities?
The dosing system is designed to dose fo r 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 a ll 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-6Performance Evaluation Report for Type I MSDs 

### Type I MSD Testing Audit Checkli st for Thermopure-2 (Continued)

Sampling Procedure Yes No Are the challenge wastewater samples co llected 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 co mposite or mix influent samples. 

# X □

Are the effluent samples collected with a clean pitcher that is thoroughly decontaminated using Alconox solution and ri nsing 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 po ured into sample bottles. 

# X □

Are flow rates monitored and accurate for the collection type?
The automatic dosing system is programme d 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 appropr iate 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 in formation: NSF, device name, sample number, analyte, volume, date, time, and name of sampler. 

# X □

Are sample collection containers and volu mes 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-7Performance Evaluation Report for Type I MSDs 

### Type I MSD Testing Audit Checkli st 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 acco rding 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 Devi ce), 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 appropriate ly stored between sample aliquots? 

# X □ Are the correct QC samples and duplicate samples collected? 

# X □

C-8Performance Evaluation Report for Type I MSDs 

### Type I MSD Testing Audit Checkli st for Thermopure-2 (Continued)

Sampling Procedure Yes No
Are all equipment blanks and field dupl icates 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 samp ling and already processed by the lab. 

# X □

Are the processes and sample information, su ch 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-9Performance 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 9 th 

### and 10 th 

### 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 descri bed 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 batt ery 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 cond ucted 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-10Performance 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 de vices 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-11Performance Evaluation Report for Type I MSDs 

### Type I MSD Testing Audit Checklist for Electroscan (Continued)

Sampling Procedure Yes No Are the challenge wastewater samples co llected 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 prep ared 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 ri nsing 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 po ured into sample bottles. 

# X □

Are flow rates monitored and accurate for the collection type?
The automatic dosing system is programme d 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 appropr iate 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 in formation: NSF, device name, sample number, analyte, volume, date, time, and name of sampler. 

# X □

Are sample collection containers and volu mes appropriate for planned analysis per Table 2 of the work plan? 

# X □

C-12Performance 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 acco rding 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 temper ature, 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 hou rs after the first sample is taken. 

# X □

Is the field test container appropriate ly stored between sample aliquots? 

# X □

C-13Performance 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 dupl icates 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 test ing and already processed by the lab. 

# X □

Are the processes and sample information, su ch 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