November 8, 2010

Attention Docket ID No. EPA-HQ-OW-2010-0126

Via E-mail: ow-docket@epa.gov

CLEAN WATER ACT SECTION 312(b): NOTICE SEEKING STAKEHOLDER

INPUT ON PETITION AND OTHER REQUEST TO REVISE THE 

PERFORMANCE STANDARDS FOR MARINE SANITATION DEVICES

FEDERAL REGISTER, VOL. 75, NO. 132, JULY 12, 2010, PAGES 39683-39691

Dear Sir or Madam:

Lake Carriers’ Association represents 18 American companies that collectively operate 55 U.S.-flag 

vessels on the Great Lakes. These vessels move the raw materials that drive the U.S. economy: iron 

ore for steel production, coal for power generation, aggregate and cement for the construction 

industry.... In periods of peak demand, our members can move more than 115 million tons of cargo

per year, or well over half of all waterborne commerce on the Great Lakes.

We have polled our members and determined there are 66 Marine Sanitation Devices on their 

vessels. Almost are Type II units. The majority of vessels have one MSD. Some have two, one 

forward and one aft. The vessels with units fore and aft reflect the design of most lakers through the 

early 1970s. The pilothouse and accommodations for Deck Department personnel were located 

forward. The engine room and accommodations for the Engine Department were located aft. All 

vessels built since 1973 combine both into one structure located aft.

Attachment A lists the various types of MSDs aboard our members’ vessels and provides the name of 

the manufacturer and model number.

Attachment A also lists the Nominal Rated Capacity (Persons) for the various MSDs and the unit’s 

U.S. Coast Guard rating (Gal/Day). However, it is important to point out that the Nominal Rated 

Capacity (Persons) exceeds, in some instances vastly, the number of individuals on these vessels. 

For example, one unit, the Hamworthy ST-20, is rated for 59 persons. Another, the Scienco/Fast 

B35D, is rated for 79 persons. By law, no vessel enrolled in Lake Carriers’ Association is allowed to 

carry anywhere near that many persons. These vessels are inspected by the U.S. Coast Guard and 

issued a Certificate of Inspection (“COI”) that, among other things, specifies how many crewmembers

are required to safely operate the vessel, and then how many other “Persons Other Than Crew” are 

allowed on the vessel. The maximum number of persons allowed on our members’ vessels ranges 

from 18 to 44.

Continued.../

20325 Center Ridge Rd., Ste. 720  Rocky River, OH 44116  Fax: 440-333-999  www.lcaships.com

The Association Representing Operators of U.S.-Flag Vessels on the Great Lakes 

AMERICAN STEAMSHIP COMPANY  ANDRIE, INC.  ARMSTRONG STEAMSHIP COMPANY  BELL STEAMSHIP COMPANY

CENTRAL MARINE LOGISTICS, INC.  GRAND RIVER NAVIGATION COMPANY, INC.  GREAT LAKES FLEET/KEY LAKES, INC.

INLAND LAKES MANAGEMENT, INC.  THE INTERLAKE STEAMSHIP COMPANY  KK INTEGRATED SHIPPING  LAKES SHIPPING COMPANY

LAKE MICHIGAN CARFERRY SERVICE  PERE MARQUETTE SHIPPING  PORT CITY MARINE SERVICES  PORT CITY STEAMSHIP SERVICES

SOO MARINE SUPPLY, INC.  UPPER LAKES TOWING COMPANY, INC.  VANENKEVORT TUG & BARGE INC.

Attachment B provides contact information for the various manufacturers of these MSDs.

Lake Carriers’ Association

The Greatest Ships on the Great Lakes 

JAMES H. I. WEAKLEY, PRESIDENT

440-333-9995  weakley@lcaships.com
Lake Carriers’ Association November 8, 2010

Page 2

The request for comments asks several questions about the operation and capabilities of MSDs. We 

will leave the highly-detailed descriptions and answers to the manufacturers. For example, they can 

best opine about their units’ ability to treat nutrients. We will focus on actual shipboard operation, 

performance, and maintenance, our area of expertise. 

The units on our members’ vessels are gravity fed and treat both sewage and greywater. In this 

regard the units are unique, as the requirement to treat both sewage and greywater is specific to the 

Great Lakes. Vessels operating outside the Great Lakes are not required to process their greywater 

through their MSD.

Again, almost all the MSDs on our members’ vessels are Type II.1 These units, known as biological 

aerobic sewage treatment systems, treat sewage using a combination of bacteria and air to remove 

liquid and solid waste and turn the sewage into an effluent that meets federal requirements for 

permissible discharge in areas so designated.

Great care is taken to insure the proper operation of these units. The key is of course that the 

bacteria remains alive. Therefore, use of non-biodegradable cleaners and products containing 

bleach, chlorine, and other bacteria-killing substances is banned. Soaps used for bathing and 

washing clothes must be non-toxic and biodegradable. 

All effort is made to reduce solids introduced into the system. Biodegradable, quick-dissolving toilet 

paper is employed. Following meals, plates are scraped and wiped clean before being placed in the 

dishwasher. Some vessels have installed macerators to grind up any solids that might enter the 

system.

Steps to reduce greywater include use of low-flow shower heads and high-efficiency washing 

machines.

The end result is an effluent that not only meets but exceeds Federal standards. Federal regulations 

require that the fecal coliform bacterial count be no greater than 200 per 100mL, and total suspended 

solids no more than 150 mg per liter. In reviewing test results on MSD effluent, we find fecal 

coliforms generally < 2 and total suspended solids ranging from 9 to 36.

Actually, in terms of suspended solids, the requirement for MSDs discharging into the Great Lakes is 

even stricter than the federal standard: 50 mg/l. Again, the units on our members’ vessels exceed 

that standard. 

Canada has imposed two other requirements for MSD effluent discharged into its Great Lakes

waters: Biological Oxygen Demand 5 (“BOD (5)”) and Residual Chlorine. The limit for the former is 

50 mg/l; for the latter, the range is 0.5 – 1.0 mg/l. Again a review of lab tests finds BOD (5) ranging 

from 3 to 38 and Residual Chlorine ranging from 0.12 to 0.30.

Not all of our members’ vessels have MSDs. Several vessels are equipped with holding tanks and 

then pump out to a shoreside receptacle as necessary. The reason for this is that these vessels are 

(or were) in more or less dedicated trades. The carferry BADGER, for example operates between 

just two ports – Ludington, Michigan, and Manitowoc, Wisconsin, and is underway for only four hours 

each voyage. (The vessel also only operates between May 28 and October 3.) 

The cement carrier ST. MARYS CHALLENGER only loads in one port, so is in Charlevoix, Michigan 

twice a week on average.

 1 One vessel uses maceration and treatment with chlorine.
Lake Carriers’ Association November 8, 2010

Page 3

The self-unloader JOSEPH L. BLOCK, another vessel fitted with holding tanks, was dedicated to 

hauling iron ore from Escanaba, Michigan, and Two Harbors, Minnesota, to Inland Steel’s mill in 

Indiana Harbor when launched in 1976. The vessel was at the steel mill every few days. (When 

making repeated runs from Escanaba to Indiana Harbor, the vessel was at the mill every other day.) 

Although the vessel now carries some cargo for other customers, it is still largely dedicated to serving 

what is today the ArcelorMittal mill, so the operator can still count on the vessel being at the mill well 

before the tank reaches its 14-day capacity.

However, the majority of vessels in the fleet are in much more varied trades. A ship can load iron ore 

in Duluth, Minnesota, take it to Conneaut, Ohio, then load coal in Toledo, Ohio for delivery to 

Muskegon, Michigan, then steam for Calcite, Michigan, where it will load limestone destined for 

Buffalo. It could go back north for another iron ore cargo, but this time its load port might be Two 

Harbors or Silver Bay (both in Minnesota). Vessels in these mixed trades would have to have pumpout arrangements at scores of docks if fitted with holding tanks.

The purchase price of an MSD ranges from $10,000 to $40,000 per unit. MSDs are not an “off the 

shelf” item. The manufacturer may have the unit in stock, but if not, production and delivery could 

easily take 8-10 weeks.

MSDs are not compact. For example, the Scienco/Fast MX-5 measures 12 feet in length, six feet in 

width, and six feet in height. A small unit, a Humphrey 10AB, is 4 feet long, 2 feet, 4 inches in width, 

and 6.5 feet in height. 

The cost of installation on an existing self-propelled vessel is estimated to range from $30,000 to 

$90,000 depending on the difficulty of the task.2

 The $30,000 figure assumes the MSD is in a 

location that is readily accessible (given the cramped engineering spaces on commercial vessels, the 

word “easily” is rarely appropriate) and most of the existing black and greywater piping can be reused. In the case of the $90,000 figure, shipyard workers have to cut thru the shell (hull) of the 

vessel to remove the existing equipment and then install a new unit and significant re-piping follows.3

Installation of an MSD requiring only minor modifications to existing piping and wiring would probably 

take 4 to 5 working days (straight time). If time was of the essence, a two-shift-a-day schedule could 

probably result in a 3-day operation. The opposite end of the scale is as much as ten days for 

installing a unit in a difficult-to-reach location.

MSDs are like the vessels they serve; a well-maintained unit can last indefinitely. While some of our 

members have replaced units after 20 years of service, others have overhauled units. Such 

overhauls include replacement of internal media and pumps.

Since 1999, our members’ vessels have participated in the Marine Sanitation Device Great Lakes 

Industry Voluntary Testing Program developed by LCA. Under this policy, the U.S. Coast Guard is 

requested to examine maintenance records and testing records and interview crewmembers to 

determine if the MSD(s) is functioning properly. If there is reason to believe the unit is malfunctioning, 

 2 We have decided to not base costs on new construction. Due to vast changes in the steel industry and manufacturing in 

general, there has been very little new construction for the Lakes in past three decades. Also, since the Lakes are fresh 

water, vessels have extremely lengthy lifespans (the ST. MARYS CHALLENGER was launched in 1906), so companies 

first modernize existing hulls before building new. Again, it must be noted space in the engine room is at a premium. This 

has implications not only for MSDs, but ballast water treatment systems. Given the current state of technology, it appears 

a ballast water treatment system that could handle lakers’ flow rates and volumes would have to be so large it could not 

be fitted into a vessel.

3 A smaller unit sized for a tug costs about $15,000 and installation is estimated to range from $5,000 to $10,000.
Lake Carriers’ Association November 8, 2010

Page 4

efforts are made to correct the problem on the spot. If that is not feasible (a part or a tool are needed 

for example), the Coast Guard will either issue form CG-835 or a Captain of the Port Order requiring 

the owner or operator to arrange for an independent laboratory to perform fecal coliform and 

suspended solid tests and send the results directly to the Coast Guard. If the Coast Guard believed 

the MSD was completely non-functional, a No Sail Order could be issued.

Under the Voluntary Testing Program, vessels with aerobic process and chlorine disinfection will 

perform the following tests and examinations and make the results available to boarding Coast Guard 

officers:

1. Vessels with USCG-certified Type I and Type II systems will perform and record the results of 

four tests on a weekly basis. These include chemical tests for dissolved oxygen and residual 

chlorine, a visual examination for clarity, and an odor test.

2. In addition to the weekly tests, vessels will send a sample of effluent for each treatment plant 

to an on-shore testing laboratory twice each year for testing (some companies test as many as 

four times per year). The laboratory will perform tests for fecal coliform and total suspended 

solids. Copies of the test reports are retained on the vessel for 12 months.

3. Coast Guard personnel may examine sewage treatment systems for proper operation 

whenever they are aboard a vessel. They may examine weekly test logs and test lab reports. 

Engineering Department personnel are responsible for maintenance and operation of the MSD. For 

Scienco/Fast systems, scheduled maintenance can include the following:

As Required

1. Check chlorinator and dechlor feed tubes. Replenish tablets as required. Care must be taken 

that the tablets do not break. Therefore, rather than drop tablets into the feed tubes, the feed 

tubes are removed and tablets added from the end.

Weekly

1. Lubricate Roots blower bearings.

2. Check wet well sight glass for clear water.

3. Check regenerative blower inlet filter and clean as required.

Monthly

1. Check Roots blower vee drive belt tension and alignment.

2. Check dissolved oxygen (DO) in effluent or in wet well as applicable.

3. Check chlorine residual (total available chlorine) in effluent or in wet well as applicable and 

adjust as required. Residual should be between 1.0 mg/l and 2.0 mg/l.

Every Three Months

1. Air scour, pump out, and refill media tank.

Dissolved Oxygen

DO should be not less than 2.0 mg/l at any time including period of peak flow at change of watch. If it 

is low:
Lake Carriers’ Association November 8, 2010

Page 5

1. Open media tank and inspect airlift operation. All should be pumping at a high rate and 

causing turbulent flow at the surface of the water.

2. Shut off power to the Roots blower motor, remove the belt guard, grab the blower sheave and 

check for end play. If any significant end play is detected, the blower head plates are worn 

and the blower must be repaired or replaced.

Maintenance on a Hamworthy MSD and other manufacturers’ units is similar. For example, there are 

daily checks of air pressure and removal of sludge from the aeration tank. The chlorine content of the 

effluent is checked on a weekly basis and adjustments made when necessary. The quantity of 

suspended solids in the aeration compartment is checked on a monthly basis.

The EPA seeks information on other countries’ laws. We will leave discussion of Canadian laws and 

regulations to our colleagues in Ottawa, Canadian Shipowners Association.

The EPA asks if it should consider revisions to the performance standards and what should be the 

basis for such a decision. We believe it is unnecessary to re-address the performance standards for 

commercial vessels’ MSDs. Section 312(b)(1) of the Clean Water Act directs the EPA to “promulgate 

Federal standards of performance for marine sanitation devices ... which shall be designed to 

prevent the discharge of untreated or inadequately treated sewage into or upon the navigable 

waters (emphasis added)....” The Federal acceptable level of fecal coliform colonies (“CFU”) above 

which water quality is said to be diminished is that which is applied to our members’ MSDs: no more 

than 200 per 100 milliliters (“ml”) of water. As noted elsewhere, lab test results show that the effluent 

from our members’ MSDs falls well below that level. In general, there are less than 2 CFU per 100 

ml. 

Is there any evidence that this standard somehow fails water quality in the Great Lakes? To our 

knowledge the answer to that question is “No.”

Even if this standard were somehow to represent a shortcoming, we would hope the EPA would 

determine and focus on the source of inadequately treated effluent. We do not think commercial 

vessels and the comparatively small amount of effluent they generate poses any threat given the high 

standards to which the effluent is treated and the vastness of the Great Lakes. The Lakes are 

estimated to contain 64 quadrillion gallons of water. Our members have 55 vessels. Counting the 

crew and then allowing for other persons such as cadets, repairmen, and the occasional guests, there 

are perhaps 1,300 people on the vessels at a given time. There are single office buildings that have 

more people in them than are found on the entire U.S.-flag Great Lakes fleet.

Then too, the vessels are dispersed about the Lakes, so there’s no great concentration of either 

vessels or effluent. On October 15, 2010, we polled our members and found the fleet distributed as 

follows:

Lake Superior 14

Lake Michigan 17

Lake Huron 12

Lake Erie 5

Lake Ontario 1
Lake Carriers’ Association November 8, 2010

Page 6

You will note the total – 49 – is less than we have listed for our Association. With the economy still 

not fully recovered from the recession, a number of vessels have not operated this year. One, the 

carferry BADGER, has ended its season.4

In contrast, there are 4.3 million registered recreational vessels in the eight Great Lakes. While 

certainly not all are operated on the Great Lakes, rec boats vastly outnumber commercial vessels, 

even when Canadian lakers and ocean-going vessels are factored into the equation. At a given time 

there are perhaps 175 freighters of all flags on the Lakes. On a nice summer weekend, there are 

likely a million or more pleasure craft on the Lakes.

How many land-based water sources discharge into the Lakes? We will not venture a guess, but it is 

elementary that shoreside sources discharge much greater volumes than the U.S.-flag Lakes fleet, 

and even all the commercial vessels combined.

The Friends of the Earth Petition asks the EPA to establish monitoring, recordkeeping, and reporting 

requirements. We believe this unnecessary given that MSD testing and maintenance are entered in 

the vessel’s log book, which must be made available to the Coast Guard upon request. A tidal wave

of recordkeeping and forms has swept over the maritime industry in the past decade or so. We would 

like to spare our crews any unnecessary paperwork so they can focus on what they do best –

operating vessels safety and efficiently. Data on the operation and maintenance of our MSDs is 

already available.

In closing, we would like to stress that Lake Carriers’ Association has consistently shown a great 

respect for the environment. Decades ago, when there were hundreds of ships in operation, most of 

which were coal-fired, we established a Smoke Abatement Committee to address the problem. In 

the early 1990s, we were – voluntarily – the first maritime organization in North America to develop 

and implement measures to address the spread of non-indigenous species introduced via the ballast 

water on ocean-going vessels. Our VOLUNTARY BALLAST WATER MANAGEMENT PLAN FOR 

THE CONTROL OF RUFFE IN LAKE SUPERIOR PORTS was hailed by U.S Fish & Wildlife service 

as being “on the cutting edge of technology.” Rightfully so. Even though the twin ports of Duluth, 

Minnesota / Superior, Wisconsin, can handle more than 1,100 vessels in a given year, only two 

populations of ruffe have been found outside Lake Superior, and one, that in Alpena, Michigan, has 

apparently died out.

We later developed and implemented Best Management Practices for ballasting operations 

Lakeswide. We even instituted specific measures meant to address an outbreak of Viral 

Hemorrhagic Septicemia.

Since our vessels are registered in the United States and owned and operated by American 

companies, we are subject to the full range of U.S. laws. But that is not the only the reason we take 

our environmental responsibilities seriously. The Great Lakes region is where we live and raise our 

families. We want safe drinking water and clean beaches as much as the next person and our 

members operate their vessels in a manner that reflects that desire.

If the EPA chooses to revise the standards for MSDs, we ask that the most serious consideration be 

given to grandfathering existing units. The standards to which these units operate are

 4 While the BADGER is truly a seasonal operation, nearly all commercial vessels are in service less than 365 days a year. 

Most vessels get underway in the last week of March or first week of April and then begin to lay-up in late December, with 

most back in their winter berth by mid-January. There was one integrated tug/barge unit in the liquid-bulk trade that 

operated year-round, but its trade patterns have changed. The Lakes are more or less closed from late January until 

early March.

protective of 

Great Lakes water quality. If new technology allows for even higher standards, we must determine if 
Lake Carriers’ Association November 8, 2010

Page 7

the cost equals the benefit. As noted earlier, there are 66 MSDs on our members’ vessels. If we use 

an average purchase price of $25,000 and installation cost of $60,000, we are looking at spending 

$5,610,000 to retrofit the fleet. That is a significant expense and one that should be incurred only if 

there is a demonstrable need. It is important to note that Section 312(b)(1) of the Clean Water Act 

requires consideration of the economic costs. Again, though, we believe the current standard is 

protective of Great Lakes water quality, so industry, the EPA, and others all should use their talents 

and resources to address issues that do pose a threat to the environment. 

Thank you for the opportunity to comment. If you need additional information, we will do our best to 

provide it in as timely a manner as possible.

Sincerely,

James H. I. Weakley

President

G:\WEAKLEY\0-LETTER\2010\2010 MSD EPA.docx
Lake Carriers’ Association November 8, 2010

Page 8

Marine Sanitation Devices Installed on U.S.-Flag Lakers

Attachment A

Manufacturer Model #

Nominal Rated Capacity

(Persons)

U.S. Coast Guard Rating

(Gal/Day)

Ahead Tank AT-16D 16 88

American Land and 

Marine Sanitation, Inc. Humphrey 10AB Available from USCG 5,760

Biogest (Type 1) 25A Available from USCG Available from USCG

Hamworthy STA2 Super Trident 18 824

Hamworthy ST-20 59 3,584

Owens Kleen Tank n/a 25 500

Red Fox RF-200-FP-FG 5 200

Red Fox RF-500M 25 500

Red Fox RF-750M 38 750

Scienco/Fast 12DM 16 360

Scienco/Fast 13M-DC 9 420

Scienco/Fast 18DM 16 540

Scienco/Fast 18M 17 900

Scienco/Fast 25DM 35 750

Scienco/Fast 32D4S 32 5,800

Scienco/Fast 38D4 38 5,700

Scienco/Fast 38D4S 60 5,700

Scienco/Fast 40DM 32 1,200

Scienco/Fast 40D4 40 3,240

Scienco/Fast 40D4S2 40 3,240

Scienco/Fast 50D4 50 1,200

Scienco/Fast 50DM 43 1,500

Scienco/Fast 50DMS 44 1,500

Scienco/Fast B35D 79 2,475

Scienco/Fast D3 47 2,700

Scienco/Fast D3M 30 1,300

Scienco/Fast D4M 45 2,775

Scienco/Fast L-1X 6 130

Scienco/Fast L-2X 10 190

Scienco/Fast L-3X 13 255

Scienco/Fast L-4X 19 380

Scienco/Fast M-2 15 3,057

Scienco/Fast MX-2 21 450

Scienco/Fast M-4 17 1,440

Scienco/Fast MX-5 21 1,700
Lake Carriers’ Association November 8, 2010

Page 9

Attachment B

Contact Information for Manufacturers of MSDs on LCA Vessels

(Listed Alphabetically)

Lafayette, LA 70503

Ahead Sanitation Systems

Phone: (337) 237-5011

Fax: (337) 837-7785

Web site: www.aheadtank.com

E-Mail: headflusher@aheadtank.com

1174 Camp Street

American Land and Marine Sanitation, Inc.

New Orleans, LA 70130

Phone: (504) 525-6304

Ceased operations. Spare parts still available.

Biogest (subsidiary of American Shipbuilding Company)

1011 Highway 6 South

Hamworthy, Inc.

Suite 208

Houston, TX 77077

Phone: (281) 759-3280

Fax: (281) 759-8308

Web site: www.hamworthy.com

E-Mail: usa@hamworthy.com

Ceased operations. Spare parts still available.

Koehler-Dayton (Enviromac)

1917 Dulles Drive

Owens Manufacturing and Specialty Co., Inc.

Lafayette, LA 70506

Phone: (337) 991-9580

Fax: (337) 991-9566

Web site: www.owenskleentank.com

E-Mail: Sales@owenskleentank.com

1513 B Chemin Agreable Rd.

RedFox Environmental Services

Youngsville, LA 70592

Phone: (337) 856-3709

Fax: (337) 856-9151

Web site: www.redfoxenviro.com

E-Mail: info@redfoxenviro.com

12977 Maurer Industrial Drive

Scienco/Fast

Sunset Hills, MO 63127-1515

Phone: (314) 645-6540

Fax: (314) 645-6131

Web site: www.sciencofast.com

E-Mail: solutions@sciencofast.com