United States
Environmental Protection
Agency
              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

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                                                     EPA/600/R-10/008
                                                     January 2010
    PERFORMANCE EVALUATION OF TYPE I
         MARINE SANITATION DEVICES
                        by

             Eastern Research Group, Inc.
           14555 Avion Parkway, Suite 200
                Chantilly, VA20151
              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

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Performance Evaluation Report for Type I MSDs
                                        Notice

The work reported in this document was funded by the U.S. Environmental Protection Agency
(EPA) under Task Order (TO) No. 20 of Contract No. EP-C-05-059 to Eastern Research Group,
Inc. The EPA, through its Office of Research and Development, funded and  managed, or
partially  funded  and collaborated in, the research described herein. This  document has been
subjected to the Agency's peer and administrative review and has been approved for publication.
Any opinions expressed in this report are those of the author(s) and do not necessarily reflect the
views of the Agency; therefore, no official endorsement should be inferred. Any mention of trade
names or commercial products does not constitute endorsement or recommendation for use.

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Performance Evaluation Report for Type I MSDs
                                      Foreword

The U.S. Environmental Protection Agency (EPA) is charged by Congress with protecting the
Nation's land, air, and water resources. Under a mandate of national environmental laws, the
Agency strives to formulate and implement actions leading to a compatible balance between
human activities and the ability of natural systems to support and nurture life. To meet this
mandate, EPA's research program is providing data and technical support for solving
environmental problems today and building a science knowledge base necessary to manage our
ecological resources wisely, understand how pollutants affect our health, and prevent or reduce
environmental risks in the future.

The National Risk Management Research Laboratory (NRMRL) is the Agency's center for
investigation of technological and management approaches for preventing and reducing risks
from pollution that threaten human health and the environment. The focus of the Laboratory's
research program is on methods and their cost-effectiveness for prevention and control of
pollution to air,  land, water, and subsurface resources; protection of water quality in public water
systems; remediation of contaminated sites, sediments and ground water; prevention and control
of indoor air pollution; and restoration of ecosystems. NRMRL collaborates with both public  and
private sector partners to foster technologies that reduce the cost of compliance and to anticipate
emerging problems. NRMRL's research provides solutions to environmental problems by:
developing and  promoting technologies that protect and improve the environment; advancing
scientific and engineering information to support regulatory and policy decisions; and providing
the technical  support and information transfer to ensure implementation of environmental
regulations and  strategies at the national, state, and community levels.

This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the
user community and to link researchers with their clients.
                                         Sally Gutierrez, Director
                                         National Risk Management Research Laboratory
                                           11

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Performance Evaluation Report for Type I MSDs
                                 Executive Summary
       Performance tests were conducted to evaluate the effectiveness of Type I Marine
Sanitation Devices (MSDs) in reducing fecal coliform bacteria and visible floating solids (VFS).
In addition, the performance evaluation described herein also included testing for enterococci
and Escherichia coli (E. coif) indicators, biochemical oxygen demand (BODs), total suspended
solids (TSS), and nutrients (ammonia, total Kjeldahl nitrogen (TKN), nitrate/nitrite, and total
phosphorous) in both influent to and effluent from the devices. Note that this testing was not
performed for Type IMSD certification as both devices were already certified by the U.S. Coast
Guard (USCG) to meet EPA performance standards at the time of testing.
       The Electro Scan™ Model EST 12, manufactured by Raritan Engineering Company, Inc.,
and the Thermopure-2 Model TP-210, by Gross Mechanical Laboratories, Inc., were selected for
the performance tests because these manufacturers were willing to provide devices for testing,
and the devices represented the range of technologies that were commercially available at the
time of testing. Both devices use maceration to eliminate visible floating solids and disinfection
to destroy pathogens. The Electro Scan™ device  disinfects wastewater using chlorine generated
from salt water, while the Thermopure-2  device disinfects wastewater using heat.
       The Electro Scan™ system consists of a two-chamber treatment tank, system status
panel, control unit, liquid-crystal display  (LCD),  and an optional salt feed tank system that can
be added for operation in fresh or brackish water. The system creates disinfectant from salt
water. Flushing moves waste to the  maceration chamber for particle size reduction. Subsequent
flushing moves the waste to the oxidation chamber where it is mixed and brought into direct
contact with electrode plates. When these plates are submerged in salt water and supplied with
electricity, hypochlorous acid is formed, which then breaks down organic waste products by
oxidation, including bacteria. The cycle runs for about two minutes in the second chamber, and
the waste is held in the oxidation chamber until the next flushing cycle, then it is discharged.
       The Thermopure-2 system consists of three main components: the holding tank module,
SweetTank™ aeration module, and the Thermopure treatment chamber. The unit is designed to
be plumbed to either a toilet head or a preexisting remote holding tank, and all functions and
operations in the unit are automatic. Treatment is accomplished by macerating the waste in the
holding tank module, and then pumping it through the Thermopure treatment chamber where low
level heat is introduced to eliminate bacteria. No  chemicals or additives are required. In addition,
                                           in

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Performance Evaluation Report for Type I MSDs
the Thermopure-2 system does not require salt water to operate; therefore, it is equally efficient
in fresh, brackish, or salt water.

Performance Testing
       Performance testing was conducted using procedures for the Sewage Processing Test
contained in the USCG's MSD certification requirements at 33 CFR 159.121. One exception to
the USCG's Sewage Processing Test requirements is that, for reasons of practicality, testing was
conducted using a feed of fresh domestic human sewage rather than human sewage in a ratio of
four urinations to one defecation, as specified at 33 CFR 159.121(c). Furthermore, for this
evaluation, testing was not limited to fecal coliform bacteria and visible floating solids measured
in the treated effluent, but rather included a variety of analyses of both influent and effluent
samples to measure the effectiveness of each treatment device and to characterize influent and
effluent quality.
       The 10-day tests were performed at the Waco Metropolitan Area Regional Sewerage
System test facility, beginning on April 9, 2007. The site provided a ready source of fresh
wastewater and primary sludge as challenge wastewater for testing. An influent sample of the
challenge wastewater was collected immediately prior to dosing the devices each day and
analyzed for all parameters to characterize influent quality.
       MSDs were set-up, started, and operated, as  closely as possible, to installation onboard a
vessel and according to the devices' operation manuals. Operational considerations included  a
tilting schedule, a salt-feed, and a cool-down time. The devices were tested for an 8-hour period
over 10 days. Sampling personnel dosed each MSD with challenge wastewater at average
loading levels throughout each day, with peak capacity wastewater doses three times each day.
Sampling personnel collected effluent samples from the test devices at the beginning, middle,
and end of each eight-hour period, with one additional sample taken following a peak dosing
period each day, for a total of 4 samples per device per day. Effluent samples were analyzed to
characterize effluent quality and performance efficiency.

April 2007 Test Results
       The effluent produced by the Electro Scan device ranged from nondetect to > 1,600 fecal
coliform bacteria most probable number (MPN) per 100 mL with a mean concentration of 82
MPN/100 mL. The effluent from the Thermopure-2 device ranged from nondetect to 30,000,000
fecal coliform bacteria MPN/100 mL with a mean concentration of 4,500,000 MPN/100 mL. For
                                            iv

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Performance Evaluation Report for Type I MSDs
the Electro Scan device, 33 of the 40 samples had VFS less than or equal to 10% of TSS. The
Thermopure-2 device had VFS less than or equal to 10% of TSS in 36 of the 38 samples.
       The Electro Scan device removed almost all pathogen indicators (99.99% or greater). In
contrast, the Thermopure-2 device removed only half of the fecal coliform. The Thermopure-2
device did not reach the designated threshold temperature sufficient enough to kill bacteria,
which may have occurred due to the thermal sensor being misplaced, possibly during
manufacturing or shipping.

November/December 2007 Thermopure-2 Retest Results
       Because of problems encountered with the provided Thermopure-2 unit, a retest was
conducted using a replacement Thermopure-2 unit. The scope of the retesting was reduced due to
a limitation of funding. The duration of the performance testing was reduced from 10 days to 9
days.  Retesting dates were October 15 and 16, 2007, November 29 and 30, 2007, and
December 3 through 7, 2007. (This resulted in another exception to USCG's Sewage Processing
Test requirements at 33 CFR 159.121(c) as testing was not at least 10 days within a 20-day
period. Furthermore, USCG certification for the Thermopure-2 unit expired on November 6,
2007.) The retesting was reduced to TSS testing of the challenge wastewater batch prepared each
day, and testing of effluent samples for fecal coliform, VFS,  BODs, and TSS.
       There  were 28 effluent samples collected during the November/December retesting
period. The effluent produced by the Thermopure-2 device ranged from nondetect to 3,000,000
fecal coliform bacteria MPN/100 mL with a mean concentration of 380,000 fecal coliform
bacteria MPN/100 mL. Of the 28 samples, 26 had VFS less than or equal to 10 % of the effluent
TSS. While these results show some improvement compared to the April testing, device
performance remained poor. Although the cause of the poor performance is unknown, the device
pump-out volume may have exceeded the capacity of the heating chamber, which would have
mixed unheated (untreated) wastewater with treated wastewater during discharge.

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Performance Evaluation Report for Type I MSDs
                                TABLE OF CONTENTS
                                                                                  Page
1.0    INTRODUCTION	1-1
       1.1    Evaluation Objective	1-1
       1.2    Evaluation Description	1-1

2.0    TECHNOLOGY DESCRIPTIONS AND SPECIFICATIONS	2-1
       2.1    Electro  Scan	2-1
             2.1.1   Description	2-1
       2.2    Specifications	2-2
       2.3    Thermopure-2	2-6
             2.3.1   Description	2-6
             2.3.2   Specifications	2-7

3.0    PERFORMANCE EVALUATION TESTING PROCEDURES	3-1
       3.1    Test Facility	3-1
       3.2    Device Installation	3-1
       3.3    Start-Up Testing	3-3
       3.4    Sewage Processing Test	3-4
             3.4.1   Wastewater Dosing Schedules	3-4
             3.4.2   Challenge Wastewater	3-5
       3.5    MSD Operation and Maintenance	3-6
       3.6    Sample Collection	3-9
       3.7    Process Monitoring	3-11
       3.8    Field  Quality Control (QC) Measures	3-11
       3.9    Deviations from the Work Plan	3-12

4.0    TEST RESULTS AND DISCUSSION	4-1
       4.1    Fecal Coliform and Visible Floating Solids	4-1
             4.1.1   Fecal Coliform	4-1
             4.1.2   Visible Floating Solids	4-2
       4.2    Other Analyses	4-3
             4.2.1   Pathogen Indicators E. Coli and Enterococci	4-3
             4.2.2   Biochemical Oxygen Demand and Total Suspended Solids	4-4
             4.2.3   Nutrients	4-4
             4.2.4   Process Monitoring	4-5
       4.3    Type  I MSD Performance	4-5

5.0    THERMOPURE-2 RETEST	5-1
       5.1    Performance Evaluation Retesting Procedures	5-1
       5.2    Retest Results and Discussion	5-4
             5.2.1   Fecal Coliform	5-4
             5.2.2   Visible Floating Solids	5-5
             5.2.3   Biochemical Oxygen Demand and Total Suspended Solids	5-5
             5.2.4   Process Monitoring	5-5
                                          VI

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Performance Evaluation Report for Type I MSDs
                         TABLE OF CONTENTS (Continued)

                                                                           Page

6.0    DATA QUALITY	6-1
      6.1    Analytical QC	6-1
      6.2    Field QC	6-2
            6.2.1  Equipment Blanks	6-2
            6.2.2  Field Duplicates	6-3
      6.3    Testing Audit	6-4

7.0    MANUFACTURER RESPONSE	7-1
      7.1    Raritan Engineering Company, Inc	7-1
      7.2    Gross Mechanical Laboratories, Inc	7-3

Appendix A:  33 CFR 159 EXCERPTS

Appendix B:  CHALLENGE WASTEWATER DOSING SCHEDULE

Appendix C:  AUDIT REPORT FOR TYPE IMSD TESTING
                                      vn

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Performance Evaluation Report for Type I MSDs
                                   LIST OF TABLES




                                                                                  Page




3-1    Influent TSS Results	3-6




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




4-1    Fecal Coliform - Electro Scan	4-7




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




4-3    Escherichia coli - Electro Scan	4-9




4-4    Enterococci - Electro Scan	4-10




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




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




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




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




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




4-10   Total Phosphorus - Electro Scan	4-16




4-11   pH - Electro Scan	4-17




4-12   Temperature -Electro Scan	4-18




4-13   Conductivity -Electro Scan	4-19




4-14   Chlorine Residual - Electro Scan	4-20




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




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




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




4-18   Enterococci - Thermopure-2	4-24




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




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




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






                                          viii

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Performance Evaluation Report for Type I MSDs
                             LIST OF TABLES (Continued)




                                                                                Page




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




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




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




4-25   pH - Thermopure-2	4-31




4-26   Temperature - Thermopure-2	4-32




4-27   Summary of Type IMSD 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
                                          IX

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Performance Evaluation Report for Type I MSDs
                                  LIST OF FIGURES




                                                                                Page




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




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



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




2-4    SweetTank™ Setup	2-7



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




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




3-2    Tilting Mechanism for MSDs	3-2




3-3    Schematic Diagram of Sampling Points	3-9

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Performance Evaluation Report for Type I MSDs
1.0    INTRODUCTION
1.1    Evaluation Objective
       This performance test was designed to evaluate the effectiveness of two Type I Marine
Sanitation Devices (MSDs): the Electro Scan Model EST 12, manufactured by Raritan
Engineering Company, Inc., and the Thermopure-2, manufactured by Gross Mechanical
Laboratories, Inc. Performance tests were conducted to evaluate the effectiveness of Type I
MSDs in reducing fecal coliform bacteria and visible floating solids (VFS). In addition, the
performance evaluation described herein also included testing for enterococci and Escherichia
coli (E. coli) indicators, biochemical oxygen demand (BODs), total suspended solids (TSS), and
nutrients (ammonia, total Kjeldahl nitrogen (TKN), nitrate/nitrite, and total phosphorous) in both
influent to and effluent from the devices.
       The performance evaluation tests were conducted under the direction of EPA through the
support of Eastern Research Group, Inc. (ERG) and ERG's subcontractor, NSF International
(NSF). The purpose of this report is to provide objective performance data on these technologies
so that consumers, developers, and regulators can make informed decisions about purchasing and
applying the technology  in these products.

1.2    Evaluation Description
       A Type IMSD is a flow-through system designed for vessels of 65 feet or less in length,
with capability for maceration and disinfection of waste prior to discharge. The Type I MSDs
underwent performance evaluation testing using procedures for the Sewage Processing Test
contained in the USCG's MSD certification requirements at 33 CFR 159.121 (see Appendix A).
One exception is that, for reasons of practicality, testing was conducted using a feed of fresh
domestic human sewage rather than human sewage in a ratio of four urinations to one defecation,
as specified at  33 CFR 159.121(c). Furthermore, for this evaluation, testing was not limited to
fecal coliform  bacteria and visible floating solids measured in the treated effluent, but rather
included a variety of analyses of both influent and effluent samples to measure the effectiveness
of each treatment device and to characterize influent and effluent quality. Note that this testing
was not performed for Type I MSD certification as both devices were already certified by the
USCG to meet EPA performance standards at the time of testing.
       Because of problems encountered with the provided Thermopure-2 unit, a retest was
conducted using a replacement Thermopure-2 unit. The scope of the retesting was reduced due to
                                          1-1

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Performance Evaluation Report for Type I MSDs
a limitation of funding. The duration of the performance testing was reduced from 10 days to 9
days. Retesting dates were October 15 and 16, 2007, November 29 and 30, 2007, and
December 3 through 7, 2007. (This resulted in another exception to USCG's Sewage Processing
Test requirements at 33 CFR 159.121(c) as testing was not at least 10 days within a 20-day
period. Furthermore, USCG certification for the Thermopure-2 unit expired on November 6,
2007.) The retesting was reduced to TSS testing of the challenge wastewater batch prepared each
day, and testing of effluent samples for fecal coliform, VFS, BOD5, and TSS.
                                          1-2

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Performance Evaluation Report for Type I MSDs
2.0    TECHNOLOGY DESCRIPTIONS AND SPECIFICATIONS
2.1    Electro Scan
2.1.1   Description
       Electro Scan (Figure 2-1) is a USCG-approved Type IMSD manufactured by Raritan
Engineering Company, Inc. The system consists of a two-chamber treatment tank, system status
panel, control unit, LCD, and an optional salt feed tank system that can be added for operation in
fresh or brackish water. The device is designed for use on vessels 65 feet or less in length and
accommodates most existing marine toilets. The device creates disinfectant from salt water.
                                 cross-over
                                                      Overboard
                         From toilet
                                Macerator

                               Electrode pack
Mixer
                           Source: Raritan Engineering Company, Inc
          Figure 2-1. Internal Components of the Electro Scan Treatment Tank

       Flushing moves waste to the maceration chamber for particle size reduction. Subsequent
flushing moves the waste to the oxidation chamber where it is mixed and brought into direct
contact with electrode plates. When these plates are submerged in salt water and supplied with
electricity, hypochlorous acid is formed, which then breaks down organic waste products,
including bacteria, by oxidation. The cycle runs for approximately two minutes in the second
chamber, and the waste is held in the oxidation chamber until the next flushing cycle, then it is
discharged.
                                          2-1

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Performance Evaluation Report for Type I MSDs
2.2    Specifications
       The Electro Scan has three models, EST12, EST24, and EST32, each with different volts
of direct current as represented by the numbers in each model name. The EST 12 model was
selected for performance testing. The main component of the system is the 3-gallon, or 11.4-L,
treatment tank with dimensions of 13.5 x 9.25 x 16 inches (in.). The treatment tank is divided
into two 1.5 gallon chambers. The dividing partition contains an electrode pack with electrodes
protruding into each chamber. The first chamber, containing the macerator, reduces the sewage
into tiny particles. Salt water used in the flush activates the electrode in the first chamber, which
produces the disinfectant that treats the sewage. During subsequent flushes, the macerated
sewage flows up and over the partition into the second chamber via a cross-over pipe. Because of
this design, any settled solids remain in the first chamber for continued maceration and
treatment. The second chamber continuously mixes the waste as the second set of electrodes
continues waste disinfection. According to Raritan, the treatment tank holds about four flushes,
averaging 0.75 gallons per flush. Therefore, the waste undergoes approximately four treatment
cycles before being discharged. A complete treatment cycle lasts about 3.75 minutes.
       The following are the chemical reactions that occur in the treatment chambers:

       1.     The process starts with salt water in the treatment tank. Sodium chloride (NaCl) is
             a strong electrolyte that exists in salt water as sodium (Na+) and chloride (C1-)
             ions.

                                          NaCl -> Na+ + Cl'
       2.     Through hydrolysis, water (H2O) breaks into hydrogen (H+) ions and hydroxyl
             (OH') ions.

                                          H2O --> H+ + OH"
                                          2-2

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Performance Evaluation Report for Type I MSDs
       3.     The electrode pack is energized at the anode during the treatment cycle, and
             electricity passes through the conductive salt water. Hydrochloric acid (HCL), and
             hypochlorous acid (HOCL), a powerful bactericide and oxidizing agent, and are
             produced on the surface of the plates, liberating two electrons (e").

                                 2(T + OH' + H+ --> HC1 + HOC1 + 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+ + 2OJf -> 2 NaOH + H2|
       5.     The net reaction is:

                       2Cr + 3OH' + 3H+ + 2Na+ --> HC1 + HOC1 + 2NaOH + H2|
       6.     Hypochlorous acid is formed when sodium hypochlorite (NaOCl) reacts with
             water.

                                   NaOCl + H2O -> NaOH + HOC1
       7.     Hypochlorous acid reacts with contaminants (e.g., soil, dirt, and bacteria) giving
             up its oxygen; leaving hydrochloric acid.

                            HOC1 + contaminants --> HC1 + contaminants Ox
       8.     The hydrochloric acid reacts with the sodium hydroxide to form  sodium chloride
             and water.

                                     HC1 + NaOH --> H2O + NaCl

       Another component of this device is a credit-card-sized system status panel (Figure 2-2),
which contains a touch pad button for starting the treatment cycle and labeled light-emitting
diode (LED) indicators to show proper operation or the nature of a possible fault. When installed
with an electric toilet, flushing the toilet initiates waste treatment as a one-touch operation. When
installed with a manually operated toilet (hand pump type),  an optional pump sensor kit can be
                                          2-3

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Performance Evaluation Report for Type I MSDs
installed at the toilet, which is wired to, and automatically activates, the Electro Scan treatment
process.
       The control module (Figure 2-2), containing two boards, serves as the system's central
control. The main microprocessor/memory board contains system programming, logic circuitry,
treatment monitoring, and operational data storage. The second board is an input/output
component that allows the user to make connections to accessories. Power switching solenoids,
fuse protection, and a leaf shunt to measure the current flowing through the electrodes are built-
in.
       The LCD display unit (Figure 2-2) is the new feature of the system, which distinguishes
the EST 12 model from the older generation Lectra/San device. The display provides the user
with information regarding the treatment cycle, such as voltage status, and historical data
regarding the use of the system. It also contains a reset button if a system error occurs.
       Finally, there is an optional salt feed tank, which is used when the boat is operating in
freshwater or brackish waters. The feed tank is available in three models: 2 gallon (7.6 L) tank, 4
gallon (15.2 L) tank, and a 4 gallon (15.2 L) tank with automatic water refill and salt water
injection. Standard table salt is used to make the salt solution, and this salt water is metered to
the suction line of the toilet or injected directly into the treatment tank. The standard formula for
making salt water is 4.6 ounces (oz) of non-iodized salt per gallon  of water.
                                           2-4

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Performance Evaluation Report for Type I MSDs
                                     cross-over
                                                            Overboard
                            From toils
                                  Electrode pack
                                 LCD Display
                                                   Mixer
                     Svstem~Status
                                           Control Unit
 B*d
Orange
                                                            .
                                                        J*J
                                          Main Fuse/
                                          Circuit Breaker
                                          ,/	
                                                             *!,<*-Bhtk-J
                                                             •ins *—Jled —
                                                             •SiC c  Grange-
                                                             fi^j -*-«Me—
                               Source: Raritan Engineering Company, Inc


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

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Performance Evaluation Report for Type I MSDs
2.3    Thermopure-2
2.3.1   Description
       At the time of the April 2007 performance test, the Thermopure-2 (Figure 2-3) was a
USCG-approved Type IMSD manufactured by Gross Mechanical Laboratories, Inc. At the time
of the November/December retesting, the Thermopure-2 was not longer USCG-approved as the
USCG certification expired on November 6, 2007. The system consists of three main
components: The holding tank module, SweetTank™ aeration module, and the Thermopure-2
treatment chamber. The device is designed to be plumbed to either a toilet head or a preexisting
remote holding tank, and all functions  and operations in the device are automatic.







TBEAT116NT \.
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1 "•. Tlh r. TANK
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REMOTE



                                                               P-UM3IN3 B=TWEEr< DISCHARGE
                                                                 SEACOCK AND =|SAL LCOa
                                                                 aur B= A STR4|Oi-r GRSP
                                                                  i'SO lB-f;F5RFF BFWISi
     Source: Gross Mechanical Laboratories, Inc
                   Figure 2-3. Example Installation for Thermopure-2

       Treatment is accomplished by macerating the waste in the holding tank module and then
pumping it thought the Thermopure-2 treatment chamber where low-level heat is introduced to
                                          2-6

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Performance Evaluation Report for Type I MSDs
eliminate bacteria. No chemicals or additives are required. In addition, the Thermopure-2 device
does not require salt water to operate, so it is equally efficient in fresh or brackish water.

2.3.2  Specifications
       The Thermopure-2 device is available in four models: TP-210, TP-215, TP-220, and TP-
230. The last two digits of the model name represent the different sizes of holding tank capacity
in gallons. The TP-210 model was selected for performance testing.
       For the Thermopure-2 device, wastewater enters a holding tank module as the toilet is
flushed, where it is macerated. (For installations with a remote holding tank, waste is pulled into
the Thermopure-2 holding tank module and treated in a series of batches). When wastewater
enters the holding tank module, the SweetTank Odor Neutralization System™ also begins
working. The SweetTank™ (Figure 2-4) is a unit that was developed to eliminate odors in
holding tanks without the use of chemicals or filters. Instead, SweetTank™ 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.
                                        VfchJ- 10
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                          IS ALvW ft.
                         SUBWtRftJ
                            Source: Gross Mechanical Laboratories, Inc
                             Figure 2-4. SweetTank™ Setup

       Whenever macerated wastewater is detected in the holding tank module and the
macerator has operated for a set amount of time, the treatment system pumps the batch of
wastewater from the treatment chamber into the Thermopure-2 chamber where heat is applied to
the wastewater to eliminate bacteria. (Gross Mechanical Laboratories, Inc. representatives did
not provide the length of maceration time or operating temperature of the device.) If the two

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Performance Evaluation Report for Type I MSDs
modules are not at the same height, the device will not pump properly and will require the
installation of a HVL-750 3/4 in. Vented Loop, which is sold separately. After a treatment cycle,
the treated waste is then pumped overboard.
       When no wastewater is detected in the holding tank module, the device automatically
enters stand-by mode. However, when the holding tank module is close to full, use of the toilets
must stop  as additional flushing will overflow the device.
       The treatment unit also has an operation panel (Figure 2-5), which gives the user
information about the system. At 10% capacity, a yellow light on the panel indicates the
initiation of treatment and discharge, assuming the system is already at adequate temperatures.
At 75% capacity, a flashing yellow light and audible alarm goes off to warn users the system is
close to maximum capacity. Other functions of the panel includes alternating current (AC) and
direct current (DC) power "on" indicators, a system failure alarm, a hold switch that disables the
system temporarily, and a mute button. Lastly, a flush kit is installed after the treatment unit
which facilitates winterization and maintenance, and provides an access port to clear blockages,
should one occur.
                                   SWEETTANK
                                    AERATOR
                            Source: Gross Mechanical Laboratories, Inc
                     Figure 2-5. Electrical Hookup for Thermopure-2
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Performance Evaluation Report for Type I MSDs
       Warm-up time for the device (measured from the time AC power is first applied to when
the device is ready to treat and discharge) is approximately six minutes at 15 amperes (A) of AC
power. The use of the pumps in the system is an additional 16 A of DC power. During periods of
time when the system is on stand-by, 150 milliamperes (mA) of DC circuit power is used.
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Performance Evaluation Report for Type I MSDs
3.0    PERFORMANCE EVALUATION TESTING PROCEDURES
3.1    Test Facility
       NSF conducted the performance tests at its Waco, Texas test facility, located at the Waco
Metropolitan Area Regional Sewerage System (WMARSS) treatment facility.1 The site provided
a ready source of fresh wastewater and primary sludge to provide a challenge wastewater for
testing.

3.2    Device Installation
       NSF test-site personnel reviewed the documentation for the two devices to determine the
best approach for setup and testing of the systems. The size of the two devices allowed them to
be installed in a manner convenient for dosing and sampling. As shown in Figure 3-1, the
devices were installed on plywood platforms,  taking into account the configuration indicated in
the manufacturers' literature.
Electro Scan device is in the foreground and Thermopure-2 device is in the background. Dosing system shown in
upper left and effluent receiving tanks in lower right.

                 Figure 3-1. Thermopure-2 and Electro Scan Installation
1 NSF's facility located in Ann Arbor, Michigan is currently accepted by the USCG as a Recognized Facility for the
evaluation, inspected, and testing of marine sanitation devices under 33 CFR 159.15. However, NSF's Waco, Texas
and Aqua-Tech Laboratories, Inc. subfacility currently is not accepted as a Recognized Facility by the USCG.	
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Performance Evaluation Report for Type I MSDs
       The devices were anchored to the platform to accommodate tilting during testing to an
angle of 30° from the horizontal along one side of the devices (specified by both manufacturers
as maximum roll/pitch angle). Hinges were installed in the middle of the platform in both the
length and width directions to permit pivoting of the equipment to the required angle. With this
platform, tilting of the equipment could be performed along the edges of each device over the
course of the testing. The tilt angles were pre-set, but were also verified during each tilt event
using an inclinometer. Figure 3-2 shows the devices during testing in the tilted position.
                        Figure 3-2. Tilting Mechanism for MSDs

       Dosing was accomplished through use of infrastructure dedicated to each test device.
Each test device had a separate dosing pump, dosing manifold, programmable electronic timer,
dosing bucket, motorized ball valve, return flow line and dose counter in place to allow dosing
on separate test schedule intervals and dosing volumes as determined by the overall test
schedule. In each dosing sequence event, the timer closed the drain valve, activated the dosing
pump, and ran the pump for a set run time to allow complete volume dosing for each dosing
                                           3^2

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Performance Evaluation Report for Type I MSDs
bucket and then turned off the pump. Each bucket was calibrated before implementing the test
(including the volume of pipe and valve) to ensure an exact volume for each dosing event. The
excess dose water overflow pumped to each device for dosing was allowed to flow as gravity
return flow to the batch tank. After a set period to allow the water level to equilibrate, the timer
activated the  drain valve allowing the dose to gravity flow to the respective test device. The
Electro Scan  device required a separate input signal from the timer used to control dosing
through a 12 VDC converter, since the dosing would not be from an actual toilet input.  The
Thermopure-2 device, operating off the liquid level in the holding tank, required no special
interface with the control panel.
       Each device also had a separate 10-gallon polyethylene effluent receiving container.
Treated effluent accumulated in the receiving containers to ensure a sufficient effluent volume
for sampling  analysis. The effluent receiving containers were emptied, decontaminated, and
returned to service following collection of each effluent sample.

3.3    Start-Up Testing
       A trial run of the devices was completed prior to the start of sewage processing to ensure
everything was operating properly. The testing included preparing the challenge wastewater and
following the start-up instructions provided by the manufacturers.

Electro Scan Device
       The Electro Scan device was filled with salt water per the manufacturer's instructions and
placed into operation. No leaks were found, measures for voltage and amperage to the device
were found appropriate, and the device was placed into operation. The control panel fuse burned
out after two  cycles of operation and the wire size was changed to address the matter. The
change did not remedy the problem, as the control panel  indicated "low amp error," which
prompted site personnel to talk with the manufacturer. It was intended to use a 110 VAC/12
VDC converter (manufacturer's manual indicated that an unfiltered power supply was needed),
but discussion with the manufacturer indicted that the batteries were needed to provide  a pure
power supply. Four 850 cranking amp automobile batteries were used for the power supply,
which prevented the error message over each eight-hour test period. The device was then deemed
to be in proper operation for sewage processing.
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Performance Evaluation Report for Type I MSDs
Thermopure-2 Device
       The Thermopure-2 device was filled to 10% of the holding tank volume with fresh water.
The start-up procedures provided in the manufacturer's literature were followed, and the device
was found to be ready for testing. However, when the trial run with wastewater was completed,
two leaks were found in the tank top. The first was a leak at the interface of the holding tank and
the plate holding the macerator pump. The cap nuts used to secure the plate to the tank were
tightened to compress the rubber gasket between the tank and plate, but the leak was not stopped,
possibly from an uneven mold or bad seam. The second leak was from a thermally-welded
adapter for the pump-out fitting.  A replacement tank, which was found to be free of leaks, was
provided by the manufacturer and placed into operation.

3.4    Sewage Processing Test
       The sewage processing test was performed in accordance with 33 CFR 159.121, except
testing was conducted using a feed of fresh domestic human sewage rather than human sewage
in a ratio of four urinations to one defecation, as specified at 33 CFR 159.121(c), for reasons of
practicality. Testing was performed over an eight-hour period for 10 days (five week days per
week for two consecutive weeks). During this period, the MSDs were challenged with
wastewater at the average loading flow, with three periods of each day of the MSDs processing
waste at the peak capacity. The testing dates were April 9 through  13, 2007, and April 16
through 20, 2007. The MSDs were tilted to an angle of 30° for a one-hour period each day.

3.4.1   Wastewater Dosing Schedules
Electro Scan Device
       The peak flow process designated by Raritan is 1 gallon flush of wastewater every six
minutes and a 30-minute cool-down period after every four to five flushes. This averages to a
peak flow of 40 gallons in an eight-hour day. Flushing wastewater through the device at a faster
rate than the suggested peak flow would result in the discharge of untreated or partially treated
wastewater, as the device has no failsafe to prevent such discharge. The off-peak (average)
process flow was based on the assumption of four passengers each using the toilet five times in
an eight-hour day. This resulted in the off-peak flow of 20 gallons  in an eight-hour day, which
was the average loading flow that was used during certification of the device. The dosing
schedule allowed six minutes for processing each flush, with five cycles before a 30-minute

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Performance Evaluation Report for Type I MSDs
cool-down period, as mentioned above. The total daily volume processed was approximately 28
gallons. The wastewater dosing schedule for the Electro Scan is included in Appendix B. The
Electro Scan device was dosed daily with 28, 1-gallon doses over the entire 10-day test period.

Thermopure-2 Device
       As indicated in the technology description, the Thermopure-2 device dosing pattern was
designed based on an assumed challenge wastewater temperature of 68° Fahrenheit (20°
Celsius). At this temperature, the peak flow rate was 50 gallons per eight-hour day or about  1
gallon every 10 minutes. The off peak (average) process flow was based on an assumption of
four passengers each using the toilet five times in an eight-hour day. This resulted in the off-peak
flow of 20 gallons in an eight-hour day or 1 gallon of wastewater every 24 minutes. The total
daily volume of wastewater processed was approximately 32 gallons. The wastewater dosing
schedule for the Thermopure-2 device is also included in Appendix B.  The Thermopure-2 device
was dosed daily with 32, 1-gallon doses for nine of the 10-day test period. On days two (4/10)
and seven (4/17), the device received 28 and 14 doses, respectively, because of operational
problems with the device (see Section 3.5).

3.4.2   Challenge Wastewater
       A single batch of challenge water was mixed each morning in a 300 gallon batch tank,
approximately 30 minutes ahead of initial dosing. A 1/3 horsepower circulating pump, used  to
minimize solids settling in the batch tank, was turned on and allowed to run during the 30-minute
setup period before initial dosing, and continued operating throughout the day until dosing was
discontinued. In order to achieve the target 500 mg/L TSS minimum influent, trial runs
bracketing the ratio of primary sludge solids to raw influent ahead of testing indicated an
approximate ratio of 1/3 primary sludge to 2/3 raw wastewater. Raw influent was pumped
directly into the batch tank from a drawoff point just after the raw water inlet screen to the Waco
plant. The primary sludge solids were added to the batch tank using a hose attached to a pressure
fitting in the primary sludge line from the primary clarifiers to the plant digester. The batch tank
contained a predetermined volume level that was marked on the tank to which the tank was filled
with return solids flow from the raw water pump to achieve the target volume for TSS
concentration.
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Performance Evaluation Report for Type I MSDs
       Variations in the primary sludge solids concentrations accounted for variations in the
challenge water TSS concentration encountered during the testing. The batch was made daily
based on the best estimate of the site personnel to meet the targeted 500 mg/L concentration;
however, the actual concentration each day was determined after the dosing was completed. As
shown in Table 3-1, the influent TSS concentrations during the testing ranged from 420 mg/L to
more than 12,000 mg/L. The average influent TSS concentration over the course of the test was
2,500 mg/L with a standard deviation of ±3,600 mg/L.
                             Table 3-1. Influent TSS Results
Date
4/9/07
4/10/07
4/11/07
4/12/07
4/13/07
4/16/07
4/17/07
4/18/07
4/19/07
4/20/07
Influent TSS (mg/L)
4,000
12,000
1,100
720
420
1,100
740
500
450
3,300
3.5    MSP Operation and Maintenance
Electro Scan Device
       There was no routine maintenance required during the testing, as treatment/electrode
cleaning is recommended every six months. The device was flushed with two doses of fresh
water prior to the weekend following the first five days of testing. The power and salt feed
device were turned off for the weekend and restarted on the following Monday. The same
process was followed at the end of testing.
       The four-gallon salt feed tank was used for the testing. The manual instructions for the
salt tank indicated that the tank be filled with up to 10 pounds of solar salt, which would mix
with a fresh  water supply to provide about a 3% salt solution for injection into the device. While
it was not possible to record the amount of salt water actually injected into the device, the
amount of solar salt added to the tank was recorded over the 10 days of the test. Over the course
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Performance Evaluation Report for Type I MSDs
of the testing, including the trial run prior to the start of the test, a total of 39 pounds of solar salt
was added to the salt tank.
       Operationally, maintenance was provided several days during the test:

   •   Day eight - An error message on the control panel (MAC MOTOR OVERLD) occurred.
       NSF  site personnel removed the macerator motor screws to access the macerator shaft
       and turned the shaft by hand to free it up. The motor was returned to service with no
       further messages. An error message (ELECTROD OVERLD) on the control panel was
       investigated, including wiring checks. The power was turned off then back on, and the
       panel returned to the normal status of "Ready to Flush." The problem may have been
       related to the salt concentration in the device.

   •   Day nine - An error message (LOW ELECTRODE AMPS) appeared on the control
       panel, indicating that the salt in the salt tank should be checked. A visual check of the
       tank found the salt dosing pump running continuously. The device was reset by shutting
       off the water and power to the pump, then restarting. The warning was repeated during
       the day, with about 10 pounds of salt being added to the tank over the course of the day.
       For the latter part of the day, the power to the pump had to be disconnected between
       doses to keep it from running continuously  and getting control panel operational errors.
       At the end of the day, power was reset to the control panel and the salt tank was cleaned,
       flushed, and restocked with salt for the next day. The device operated as it had prior to
       the problems on day nine.

Thermopure-2 Device
       The only  routine maintenance required during the testing was weekly flushing of the
device, which was completed on Friday of each week. This maintenance involved filling the
holding tank to 75% capacity with fresh water and  allowing the device to process normally.
       Operationally, maintenance was provided several days during the test:

   •   Day two - The device was not pumping out effluent, with the tank filling the holding
       tank, and the 10% and 75% alarm lights and audible alarm activating. All electrical
       connections were checked; however, the fuse blew three times. The emergency discharge
       button was actuated and the pump could be heard running, but still with no discharge.

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Performance Evaluation Report for Type I MSDs
       The device was shut down, missing four doses, and the pump assembly was replaced,
       which corrected the problem. Disassembly of the failed pump revealed that the retaining
       bolt securing the impeller to  the pump shaft had come out, allowing the pump shaft to
       turn without turning the impeller.

       Day four - When the device  was tilted (to 30°) the audible alarm sounded and the 10%
       and 75% warning lights blinked. No cause was found for this condition, and the alarms
       stopped after about 20 minutes following the device being returned to the upright
       position. The heater light also did not light during this time.

       Day six - The air compressor provided with the Sweet Tank component began making a
       rattling noise, which was resolved by removing the retainer clip and allowing the
       compressor to hang by the plastic air line and wiring. The compressor operated without
       noise for the remainder of the test.

       Day seven - The same condition of warning alarm and alarm lights occurred and no
       discharge was occurring from the device. All electrical was checked and floats cleaned,
       per manual. The manual pump-out worked, but when dosing was resumed, the tank once
       again filled  with no discharge. Dosing was discontinued and the manufacturer contacted.
       Site personnel, working with the manufacturer, determined that the thermal switch in the
       device was open, not allowing for discharge from the device. The final solution was to
       jumper across contacts for the switch to keep the testing going. This was successful,
       although eighteen doses and  two effluent samples were lost because of the problem.

       Day eight - It was observed that the device did not heat when tilted to one of the four
       directions (three o'clock position). Also on that day, effluent was observed spraying out
       of the vacuum breaker on the inlet side of the device when it was pumping out. NSF site
       personnel dismantled the breaker and found no apparent reason for the malfunction. A
       modification of the breaker, which the manufacturer representative acknowledged did not
       impact device operation, was made to accommodate the remainder of the test.

       Day nine - During the tilt cycle (to the three o'clock position), steam and a small amount
       of solids were emitting from the effluent hose, which indicated that the discharge pump

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Performance Evaluation Report for Type I MSDs
       may have been out of the water. The device was righted for 30 seconds and the
       emergency pump-out switch was activated to prevent damage to the heating element. The
       device was returned to the tilt position and subsequent doses filled the tank enough to
       allow the pump to operate properly.

3.6    Sample Collection
       Samples of the influent feed (challenge wastewater) and of the effluent discharged from
each device (Figure 3-3) were collected according to the schedule provided in Appendix B. Note
that the automated dosing schedule was started at the same time each day and the sample
schedule was followed precisely to accommodate the processing times needed for each of the
MSDs and the number of wastewater doses required to obtain sufficient effluent volume for
testing.
(dTT^i
Influent
wastewater
(• cpi j





/
Treatment
Device

/

/


_ -- — ^-^^
^spy^

^^ ^^
Effluent
wastewater
^ 	 	 '
               Note: SP1 is the influent sampling point; SP2 is the effluent sampling point.
                   Figure 3-3. Schematic Diagram of Sampling Points

       A grab sample of the challenge wastewater (mixed contents of the batch tank) was
collected from the outlet of the recirculation pump immediately prior to dosing to the devices
each day, for a total of 10 samples. Grab samples were collected using a clean 1.5-gallon glycol-
modified polyethylene terephthalate (PETG) carboy, collecting approximately six liters each day.
The collected wastewater was thoroughly mixed and poured off into appropriate sample bottles
for the analyses (See Table 3-2). The sampling device was dedicated to challenge wastewater
sample collection and was thoroughly decontaminated using Alconox cleaning solution and
deionized/distilled water rinse after each use.
                                          3-9

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Performance Evaluation Report for Type I MSDs
           Table 3-2. Methods, Sample Volume, Preservatives, and Holding Time
Reference/Method
160.2
405.1
350.1
353.2
351.2
365.2
Hach #58700-00
9221 C
Enterolert®
Colilert®
33 CFR159.125
Name
Total Suspended Solids
Biochemical Oxygen
Demand, 5 -day
Ammonia
Nitrate/ Nitrite
Kjeldahl nitrogen
Total phosphorus
Residual chlorine
Fecal coliform
Enterococcus
E. coli
Visible Floating Solids
Sample Volume
(mL)
250
1000
500
100
500
50
50
100
100
100
1000
Preservative"
4C
4C
H2SO4, 4C
H2SO4, 4C
H2SO4, 4C
H2SO4, 4C
None
Na2S2O3b,4C
Na2S203b,4C
Na2S203b,4C
None
Holding
Time
7 days
48 hours
28 days
28 days
28 days
28 days
None
6 hour
6 hour
6 hour
None
a Sample containers were pre-preserved with chemical preservatives as appropriate, and proper sample preservation
was verified upon sample receipt at the laboratory.
b Na2S2O3 addition performed only for samples from the Electro Scan device due to presence of total residual
chlorine.

       Effluent samples from the test devices were collected at the beginning, middle, and end
of each eight hour period during dosing, with one additional sample taken following a peak
dosing period each day. A total of 40 effluent samples were collected for the Electro Scan device
(four samples per day for 10 days), and a total of 38 effluent samples were collected for the
Thermopure-2 unit (two effluent sampled were missed due to unit operating problems on day 7
as discussed in Section 3.5). Grab  samples from each device were taken by draining the effluent
from each of the 10-gallon effluent receiving containers into separate clean 1.5-gallon PETG
carboys, collecting approximately six liters each sample time. The carboys were thoroughly
mixed and poured off into appropriate sample bottles for the analyses to be completed (Table 3-
2). The sampling devices (effluent receiving containers and carboys) were dedicated to  effluent
sample collection from each device and were thoroughly decontaminated using Alconox
cleaning solution and deionized/distilled water rinse after each use.
       NSF site personnel measured residual chlorine and visible floating solids onsite  due to
the relatively short holding times.  Aqua-Tech Laboratories, Inc.2 completed the chemical and
biological analyses.
 NSF's facility located in Ann Arbor, Michigan is currently accepted by the USCG as a Recognized Facility for the
evaluation, inspected, and testing of marine sanitation devices under 33 CFR 159.15. However, NSF's Waco, Texas
and Aqua-Tech Laboratories, Inc. subfacility currently is not accepted as a Recognized Facility by the USCG.	
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Performance Evaluation Report for Type I MSDs
3.7    Process Monitoring
       Process monitoring of influent and effluent streams was performed to verify that test
conditions remained relatively constant over the course of the evaluation. Monitoring parameters
were measured at regular intervals over the course of testing.
       Each grab sample of challenge water and effluent was tested for pH and temperature to
monitor the operating conditions of the test system. Conductivity testing was also completed on
the influent and effluent wastewater for the Electro Scan device.

   •   pH: Analyses for pH were performed according to SM 4500-H. A three-point calibration
       was performed each day that the meter was used for testing.

   •   Temperature: Temperature was measured according to SM 2550.

   •   Conductivity: Salt content of challenge water and treated effluent were monitored using
       a conductivity meter, similar to method EPA 120.1.  This testing was performed for
       testing of the Electro Scan device only.

       Wastewater flow rates (peak and off peak) were also monitored and recorded over the
course of testing.

3.8    Field Quality Control (PC) Measures
       Field quality control samples for this project included equipment blanks and field
duplicate samples. Note that not all QC measures listed are required for all methods.
       The purpose of equipment blanks is to document adequate decontamination of sampling
equipment before use and to evaluate possible contamination caused by sampling equipment or
by sampling equipment decontamination procedures. Sampling equipment included the effluent
receiving containers for each device and the plastic carboys used to collect, mix,  and pour the
influent and effluent samples. The sampling crew collected these blanks by rinsing
decontaminated sampling equipment with deionized/distilled water. Equipment blanks were
analyzed for the same parameters as those analyzed on the samples collected using the sampling
equipment.
       Field duplicate samples were collected to evaluate total measurement precision and
covered all the sources of data variability in sample collection, handling, preparation, and

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Performance Evaluation Report for Type I MSDs
analysis. Test personnel collected field duplicate samples simultaneously as split samples from
the selected composite sample at a rate of one per batch of 10 to 20 samples for microbiologicals
and one per batch of 10 samples for all other analytes.

3.9    Deviations from the Work Plan
       Performance testing proceeded as specified in the work plan with the deviations below:

   •   Malfunction of effluent pump on the Thermopure-2 device on day two resulted in four
       missed doses of challenge wastewater. No samples were missed.

   •   Malfunction of the thermal switch on the Thermopure-2 device on day seven resulted in
       eighteen missed doses of challenge wastewater and two missed effluent samples.
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Performance Evaluation Report for Type I MSDs
4.0    TEST RESULTS AND DISCUSSION
       This section presents the data collected during the performance tests. Section 4.1 presents
the analytical results and discussion for fecal coliform and visible floating solids. Section 4.2
presents the analytical results and discussion for analytes other than coliform and visible floating
solids. Section 4.3 discusses the performance of the two MSDs tested. Analytical data for the
Electro Scan device are presented in Tables 4-1 through 4-14, and analytical data for the
Thermopure-2 device are presented in Tables 4-15 through 4-26. Tables are presented at the end
of this section.

4.1    Fecal Coliform and Visible Floating Solids
4.1.1   Fecal Coliform
       Table 4-1 presents the fecal coliform data for the Electro Scan device, and Table 4-15
presents the fecal coliform data for the Thermopure-2 device. Note that two effluent samples
were not collected for the  Thermopure-2 device as discussed in Section 3.9, resulting in a total of
38 effluent samples for this device rather than the planned 40 samples. The effluent produced by
the Electro Scan device ranged from nondetect to >1,600 fecal coliform bacteria MPN/100 mL
with a mean concentration of 82 MPN/100 mL (see Table 4-1).  The effluent from the
Thermopure-2 device ranged from nondetect to 30,000,000 fecal coliform bacteria MPN/100 mL
with a mean concentration of 4,500,000 MPN/100  mL (see Table 4-15).3
       Upon receipt of the analytical data, ERG contacted representatives of Gross Mechanical
Laboratories, Inc., the manufacturer of the Thermopure-2 device, to inform them of the
performance of their device. The manufacturer's representative visited the test facility to
investigate. The representative verified proper device installation and test infrastructure. After
drilling a 1-in. hole in the  schedule 80 housing on the Thermopure-2 device, the representative
found that a small internal thermal sensor that controls the heating and pumping cycle for the
device, which is supposed to be inserted in a drilled recess in the heating block, was not in the
recess or was not completely in the recess. The representative stated that misplacement of the
thermal sensor would result in the  device not reaching the designated threshold temperature
sufficient to kill bacteria. It would  also account for the shorting that occurred in the thermal
3 Performance testing was not conducted in accordance with the test conditions described in 33 CFR 159.53
(Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic human sewage
rather than human sewage in a ratio of four urinations to one defecation, as specified in 3 3 CFR 15 9.121 (c).
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Performance Evaluation Report for Type I MSDs
switch on day seven (see discussion in Section 3.5). The manufacturer's representative placed
the sensor all the way into the recess and ran water through the device, measuring the
temperature through several cycles. Effluent temperatures ranging between 61°C and 85°C were
observed, which the representative stated was perfect working order. This compares to effluent
temperatures ranging between 38°C and 49°C during the performance test (see Table 4-26). Per a
request by Gross Mechanical Laboratories, Inc., a retest of a replacement Thermopure-2 device
was conducted (see Section 5.0).
       It is not clear whether the sensor had come out in shipping or had simply not been
installed properly during assembly. Given that the sensor is approximately 1-1/2 in. in length,
and the distance between the outer schedule-80 housing and the surface of the heating block, into
which the recess hole was drilled is only approximately 3/8-in., it does not appear likely that the
sensor could have slipped out during shipping.

4.1.2   Visible Floating Solids
       Table 4-2 presents the VFS data for the Electro Scan device, and Table 4-16 presents the
VFS data for the Thermopure-2  device. Note that two effluent samples were missed for the
Thermopure-2 device as discussed in Section 3.9, resulting  in a total of 38 effluent samples for
this device rather than the planned 40 samples. VFS is determined by passing approximately 1L
of sample expeditiously through a U.S. Sieve No. 12 (openings of 0.0661 in. or 1.68 mm). The
material retained on the sieve is  dried to a constant weight at 103 °C and reported in mg/L. VFS
is also reported as a percentage of the sample TSS.
       VFS concentrations in the effluent produced by the Electro Scan device ranged from zero
to  5,500 mg/L with a mean concentration of 190 mg/L (see  Table 4-2). VFS concentrations in the
effluent from the Thermopure-2 device ranged from zero to 1,600 mg/L with a mean
concentration of 66 mg/L (see Table 4-16). For the Electro  Scan device, 33 of the 40 effluent
samples had VFS less than or equal to 10%  of the effluent TSS (see Table 4-2). For the
Thermopure-2 device, 36 of the  38 effluent  samples had VFS less than or equal to 10% of the
effluent TSS  (see  Table 4-16).4
       The effluent TSS concentration does not appear to indicate the effluent VFS
concentration. For the Electro Scan device,  10 samples had  TSS concentrations that exceeded
4 Performance testing was not conducted in accordance with the test conditions described in 33 CFR 159.53
(Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic human sewage
rather than human sewage in a ratio of four urinations to one defecation, as specified in 3 3 CFR 15 9.121 (c).
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Performance Evaluation Report for Type I MSDs
1,000 mg/L. Of these, eight samples had corresponding VFS concentrations that were 10% or
less than the TSS concentration and two samples did not. While the Electro Scan effluent sample
with the highest TSS concentration had a corresponding VFS concentration significantly greater
than 10% of the TSS concentration, the sample with the second highest TSS concentration had a
corresponding VFS concentration significantly less than 10% of the TSS concentration. For the
Thermopure-2 device, eight samples had effluent TSS concentrations that exceeded 1,000 mg/L.
Of these, seven samples had corresponding VFS concentrations that were 10% or less than the
TSS concentration (including the sample with the highest TSS concentration), and only one
sample did not.

4.2    Other Analyses
4.2.1  Pathogen Indicators E. Coli and Enterococci
       Tables 4-3 and 4-4 present E.  coli, and enterococci data for the Electro Scan device,
respectively, and Tables 4-17, and 4-18 present E. coli.,  and enterococci data for the Thermopure-
2 device, respectively. E. coli is a subgroup of fecal coliform that indicates possible presence of
enteric pathogens. Enterococcus is a subgroup of fecal streptococcus and is the most efficient
bacterial indicator of water quality. (Fecal streptococcus is a subgroup of fecal coliform used to
differentiate human versus animal sources of these microbiologicals.) Epidemiological studies
suggest a positive relationship between high concentrations of E. coli and enterococci in ambient
waters and incidents of gastrointestinal illnesses associated with swimming. The studies support
the use of E. coli and enterococci (instead of fecal coliform) as indicators of microbiological
pollution.5  There are currently no E. coli or enterococci federal  performance standards for Type I
MSDs.
       Pathogen indicators generally were not detected in the effluent from the  Electro Scan
device. For those samples where pathogen indicators were detected, they were generally found at
concentrations within 10 times the analytical detection limit. Four pathogen indicator results
were uncharacteristically high: two detected E. coli concentrations of >24,000 MPN/100 mL,
and two detected enterococci  concentrations of 5,900 MPN/100 mL and >24,000 MPN/100 mL.
5 U.S. Environmental Protection Agency. Health Effects Criteria for Fresh Recreational Waters. EPA-600/1-84-004.
Research Triangle Park, NC, August 1984.
U.S. Environmental Protection Agency. Health Effects Criteria for Marine Recreational Waters. EPA-600/1 -80-031.
Research Triangle Park, NC, August 1983.	
                                           4-3

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Performance Evaluation Report for Type I MSDs
       Both pathogen indicators were detected at elevated concentrations in the effluent from the
Thermopure-2 device. E. coli concentrations were generally in the millions of MPN/100 mL,
while enterococci were generally in the hundreds of thousands of MPN/100 mL. As discussed in
Section 4.1.1, misplacement of the thermal sensor in the Thermopure-2 device is believed to
have resulted in the device not reaching the designated threshold temperature sufficient to kill
bacteria.

4.2.2   Biochemical Oxygen Demand and Total Suspended Solids
       Tables 4-5 and 4-6 present BOD5 and TSS data, respectively, for the Electro Scan device,
and Tables 4-19 and 4-20 present BOD5 and TSS data, respectively, for the Thermopure-2
device. BOD5 and TSS were detected in all effluent samples for both devices. There are currently
no BODs or TSS federal performance standards for Type I MSDs.
       The following table, for the purpose of comparison, shows the effluent quality from the
Type I MSDs (which are not required to remove BODs or TSS) and EPA's  standards for
secondary treatment for land-based publicly owned treatment works (POTWs). Note that the
technology and capacity of Type I MSDs and POTWs are very different and must be considered
in any comparison.

   BODs Comparison of Effluent from Type I MSDs to Secondary Treatment Standards
Analyte
BOD5 (mg/L)
TSS (mg/L)
Average Effluent Concentration From Type I MSDs
Electro Scan
780
1,000
Thermopure-2
920
1,000
EPA Secondary
Treatment Standards a
45
45
a 40 CFR 133.102 Secondary Treatment Regulations, 7-day average.

4.2.3   Nutrients
       Tables 4-7 through 4-10 present nutrient data for the Electro Scan device, and Tables 4-
21 through 4-24 present nutrient data for the Thermopure-2 device. Ammonia, TKN, and total
phosphorus were detected in all effluent samples for both devices. Detection of nitrate/nitrite was
generally not consistent in effluent samples for both devices. There are currently no nutrient
federal performance standards for Type I MSDs.
                                          4-4

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Performance Evaluation Report for Type I MSDs
       Ammonia is an inorganic form of nitrogen in water and wastewater, as is nitrate/nitrite.
Ammonia is produced within humans when proteins are digested and used by the body, and
excess ammonia is excreted in urine. TKN measures both ammonia and organic nitrogen.
Examples of organic nitrogen include proteins, peptides, nucleic acids, and urea. A comparison
of the ammonia and TKN results in both the influent and effluent samples show that
approximately 20% of TKN is the ammonia form. Total nitrogen is the combination of inorganic
and organic forms of nitrogen in water and wastewater.

4.2.4  Process Monitoring
       Review of pH results for the Electro Scan and Thermopure-2 devices in Tables 4-11 and
4-25, respectively, showed there were no uncharacteristic pH excursions in the challenge
wastewater or the treated effluent.
       Temperature variations for the Electro Scan device (see Table 4-12) reflect variations in
ambient temperatures at the test site. On average, influent and effluent temperatures were similar,
which is expected as the Electro Scan device does not affect wastewater temperature. In  contrast,
effluent temperatures for the Thermopure-2 device were greater than the influent temperatures
(see Table 4-26) due to the Thermopure-2 heating mechanism. However,  as discussed in Section
4.1.1, the Thermopure-2 device failed to reach the designated temperature sufficient to kill
bacteria.
       Elevated effluent conductivity as compared to influent conductivity for the Electro Scan
device (see Table 4-13) results from the salt addition required for the electrodes to generate
chlorine residual. Successful generation of residual chlorine is demonstrated by the free and total
chlorine residual results provided in Table 4-14.  Conductivity and chlorine residual testing were
performed for the Electro Scan device only.

4.3     Type I MSP Performance
       Table 4-27 compares the average influent and effluent concentrations for each device as
determined from the individual results presented in Tables 4-1 through 4-26.6 Review of these
results reveals significant variability in analyte concentrations in both the influent and effluent
6 Performance testing for fecal coliform and VFS was not conducted in accordance with the test conditions described
in 33 CFR 159.53 (Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic
human sewage rather than human sewage in a ratio of four urinations to one defecation, as specified in 33 CFR
159.121(c). There are currently no federal performance standards for Type I MSDs for parameters other than fecal
coliform and VFS.	
                                            4-5

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Performance Evaluation Report for Type I MSDs
for most analyses as illustrated by high standard deviations. Challenge wastewater and treated
effluent are not homogeneous, and sample concentrations are highly dependent on the amount
solids in the individual grab samples. Such variability is expected with raw, complex wastewater
with high amounts of solids. With the exception of the fecal coliform, E. coli, and enterococci
sample results, extreme variability in influent and effluent sample results preclude any
meaningful assessment of MSD performance efficiency.
       The Electro Scan device removed almost all  fecal coliform, E. coli, and enterococci
(99.99% or greater). In contrast, the performance of the Thermopure-2 device in removing these
analytes was generally low and highly erratic. In general, only half of fecal coliform, E. coli, and
enterococci were removed. As discussed in Section 4.1.1, misplacement of the thermal sensor in
the Thermopure-2 device is believed to have resulted in the device not reaching the designated
threshold temperature sufficient to kill bacteria.
                                           4-6

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Performance Evaluation Report for Type I MSDs
                             Table 4-1. Fecal Coliform - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent Concentration
(MPN/lOOmL)
4,000,000
6,000,000
5,000,000
4,700,000
30,000,000
6,000,000
22,000,000
3,000,000
5,000,000
9,000,000
9,500,000 ± 9,100,000
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:45 PM
8:12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent Concentration
(MPN/lOOmL)
2
4
2
ND(2)
ND(l.l)
ND(l.l)
>23
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
1.1
ND(l.l)
ND(l.l)
12
2
ND(l.l)
<2.2
ND(l.l)
1.1
ND(l.l)
ND(l.l)
ND(l.l)
<1.1
2.2
ND(l.l)
ND(l.l)
2
ND(l.l)
9.2
ND(l.l)
ND(l.l)
ND(l.l)
>1,600
>1,600
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
<82 ± 350
ND - Not detected (number in parentheses is detection limit).
> - The sample was not diluted sufficiently; actual concentration is greater than the reported upper limit.
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                  4-7

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Performance Evaluation Report for Type I MSDs
                      Table 4-2. Visible Floating Solids - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12: 15PM
3:48PM
8:12 AM
10:36 AM
12: 15PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12: 15PM
3:48PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:45PM
8:12 AM
12: 15PM
1:36 PM
3:48PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent TSS
Concentration
(mg/L)
560
460
4,800
1,700
3,300
1,500
650
500
580
460
450
430
1,800
2,500
1,700
1,300
1,300
760
960
630
680
910
670
1,000
1,000
1,400
710
840
590
490
910
600
450
920
320
270
590
600
1,000
780
1,000 ± 860
Effluent VFS
Concentration
(mg/L)
0
0
5,500
100
100
0
100
100
0
0
0.6
0.7
370
86
32
110
130
9.4
180
4.7
16
6
0
130
46
110
7
50
10
8
110
7
5
27
1
2
30
5
70
14
190 ± 860
VFS as %
TSS (%)
0
0
110
5.9
3.2
0
15
20
0
0
0.13
0.16
21
3.4
1.9
8.5
10
1.2
15
0.8
2.4
0.7
0
13
5.8
7.9
1
6
1.7
1.6
12
1.2
1.1
2.9
0.31
0.74
5.1
0.83
7.4
1.8

                                             4-8

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Performance Evaluation Report for Type I MSDs
                             Table 4-3. Escherichia coli - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent Concentration
(MPN/lOOmL)
6,400,000
7,700,000
6,800,000
20,000,000
8,000,000
6,100,000
19,000,000
6,300,000
3,700,000
7,400,000
9,100,000 ± 5,600,000
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48 PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:48PM
8:12 AM
10:36 AM
12: 15PM
3:48PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:45PM
8:12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent Concentration
(MPN/lOOmL)
ND(500)
ND(500)
ND(500)
ND(500)
ND(IOO)
ND(IOO)
980
ND(IOO)
ND(l.l)
ND(ll)
ND(10)
ND(10)
ND(ll)
ND(ll)
Excluded
Excluded
ND(10)
ND(10)
ND(5.6)
ND(l.l)
ND(ll)
ND(ll)
ND(ll)
ND(10)
<11
ND(ll)
ND(ll)
ND(10)
79
41
ND(10)
ND(10)
Excluded
ND(10)
>24,000
>24,000
ND(10)
ND(10)
ND(10)
ND(10)
<1,400 ± 5,500
ND - Not detected (number in parentheses is detection limit).
Excluded - Sample result was determined by the laboratory to be inconclusive (see Section 6.1).
> - The sample was not diluted sufficiently; actual concentration is greater than the reported upper limit.
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                  4-9

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Performance Evaluation Report for Type I MSDs
                               Table 4-4. Enterococci - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent Concentration
(MPN/lOOmL)
1,300,000
3,300,000
350,000
9,200,000
570,000
960,000
370,000
840,000
1,900,000
720,000
2,000,000 ± 2,700,000
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48 PM
8:12 AM
12:15 PM
1:36 PM
3:48 PM
8:12 AM
8:24 AM
12:15 PM
3:48 PM
8:12 AM
12:15 PM
1:36 PM
3:48 PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:45PM
8:12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent Concentration
(MPN/lOOmL)
38.1
29.4
ND(1,000)
1.0
ND(IOO)
3.0
6.2
1.0
3.3
ND(l.l)
ND(l.l)
ND(l.l)
ND(10)
10
1.1
257
1.1
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
1.0
ND(l.l)
ND(l.l)
ND(l.l)
15
ND(10)
ND(10)
17
6.9
>24,000
5,900
ND(10)
ND(10)
ND(10)
ND(10)
<790 ± 3,900
ND - Not detected (number in parentheses is detection limit).
> - The sample was not diluted sufficiently; actual concentration is greater than the reported upper limit.
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                 4-10

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Performance Evaluation Report for Type I MSDs
               Table 4-5. Biochemical Oxygen Demand (5 day) - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard Deviation
Influent
Concentration (mg/L)
1,900
NA
530
810
500
990
820
450
400
2,100
950 ± 630
Effluent Sample
Collection Time
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:45PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
310
240
1,500
600
1,200
690
410
320
290
200
170
180
920
1,400
1,300
1,100
1,700
1,800
2,600
2,600
340
610
500
670
760
970
770
1,100
690
270
540
450
650
350
280
350
380
710
1,100
490
780 ± 600
NA - Sample not analyzed due to laboratory error (see Section 6.1).
                                            4-11

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Performance Evaluation Report for Type I MSDs
                     Table 4-6. Total Suspended Solids - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard Deviation
Influent
Concentration (mg/L)
4,000
12,000
1,100
720
420
1,100
740
500
450
3,300
2,500 ± 3,600
Effluent Sample
Collection Time
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:45PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
560
460
4,800
1,700
3,300
1,500
650
500
580
460
450
430
1,800
2,500
1,700
1,300
1,300
760
960
630
680
910
670
1,000
1,000
1,400
710
840
590
490
910
600
450
920
320
270
590
600
1,000
780
1,000 ± 860
                                          4-12

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Performance Evaluation Report for Type I MSDs
                      Table 4-7. Ammonia as Nitrogen - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard Deviation
Influent
Concentration (mg/L)
13
12
14
15
15
13
14
18
19
21
15 ± 3.0
Effluent Sample
Collection Time
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12: 15PM
3:48PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:45PM
8:12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
4.2
3.3
9.8
11
7.7
3.4
2.2
3.9
3.2
6.8
8.9
6.9
6.2
5.6
7.2
10
16
8.7
8.0
8.1
1.5
10
5.9
5.7
5.7
9.3
3.2
7.0
10
5.5
7.7
12
2.2
6.5
21
19
8.8
16
12
18
8.2 ± 4.7
                                           4-13

-------
Performance Evaluation Report for Type I MSDs
                     Table 4-8. Total Kjeldahl Nitrogen - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard Deviation
Influent
Concentration (mg/L)
170
290
62
230
41
73
37
75
46
74
110 ±89
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:45PM
8:12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
17
28
130
82
37
27
28
30
15
27
22
21
31
38
66
76
37
43
49
38
22
31
43
46
43
56
47
54
47
15
66
44
5
15
45
34
66
47
69
61
42 ±23
                                           4-14

-------
Performance Evaluation Report for Type I MSDs
                      Table 4-9. Nitrate/Nitrite as Nitrogen - Electro Scan
Date

/i /o/onn^7



A/in/onn7



/i /i i /inrr?



A/io/onrn



A/I ^/onr»7



A/i^/?r»r»7



A/i7/onr»7



A/I R/onrv?



A/I o/onr»7



A/on/onrn


Average ±
Standard Deviation
Influent
Concentration (mg/L)

01 1



n ^



"MT^n n^



n ns



MT>/'H n^



xiTvn n^



MT>/'H n^



xiTvn n^



n r»7



xrn/'n ^^^


<0.09 ± 0.078
Effluent Sample
Collection Time
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:45PM
8:12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
3.0
3.6
2.3
o
.J
.2
.1
.1
.8
2.2
0.95
0.97
1.0
2.3
.8
.9
0.8
.1
.1
.4
.4
4.7
2.7
0.94
.1
.4
.1
.5
.4
2.0
5.5
4.3
2.3
10
6.8
ND(0.05)
0.2
1.7
1.2
1.2
0.77
<2.1 ± 1.9
ND - Not detected (number in parentheses is detection limit).
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                4-15

-------
Performance Evaluation Report for Type I MSDs
                       Table 4-10. Total Phosphorus - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ± Standard
Deviation
Influent Concentration
(mg/L)
59
79
15
72
9.6
11
9
19
14
13
30 ±28
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12: 15PM
3:48PM
8:12 AM
10:36 AM
12: 15PM
3:48PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:48PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:48PM
8:12 AM
10:36 AM
12: 15PM
3:48PM
8:12 AM
12: 15PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12: 15PM
3:45PM
8:12 AM
12: 15PM
1:36 PM
3:48PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
9
12
53
31
33
16
13
11
15
12
12
12
15
17
19
21
16
11
13
10
16
12
9
9
11
15
12
14
10
6
18
12
o
J
7
11
9
14
14
20
15
15 ± 8.4
                                          4-16

-------
Performance Evaluation Report for Type I MSDs
                               Table 4-11. pH - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Influent pH
6.2
6.1
6.4
5.8
6.2
7.0
5.9
7.0
6.1
6.7
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12:15 PM
3:48 PM
8:12 AM
10:36 AM
12:15 PM
3:48 PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:45PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Effluent pH
5.8
6.2
6.1
6.1
6.3
6.3
6.5
6.4
6.2
5.8
6.1
6.2
6.4
6.4
6.1
6.1
6.2
6.2
6.4
6.3
6.6
6.4
6.3
6.3
6.3
6.2
6.4
6.3
6.5
6.3
6.2
6.4
6.0
6.2
6.8
6.0
6.5
6.4
6.4
6.4
                                           4-17

-------
Performance Evaluation Report for Type I MSDs
                         Table 4-12. Temperature - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ± Standard Deviation
Influent
Temperature (°C)
14
21
21
22
22
20
21
21
21
22
20 ± 2.4
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:45PM
8:12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Temperature (°C)
14
13
16
18
15
18
20
23
17
25
26
27
18
19
23
26
20
23
25
26
12
16
22
23
15
21
21
24
17
18
22
25
19
25
26
27
19
25
26
27
21 ± 4.3
                                          4-18

-------
Performance Evaluation Report for Type I MSDs
                          Table 4-13. Conductivity - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ± Standard Deviation
Influent
Conductivity
(mS/cm)
0
0.01
0
0.04
0.05
0
0.48
0.51
0.51
1.1
0.27 ± 0.37
Effluent Sample
Collection Time
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:48PM
8:12 AM
10:36 AM
12:15 PM
3:48PM
8:12 AM
12:15 PM
1:36 PM
3:48PM
8:12 AM
8:24 AM
12:15 PM
3:45PM
8:12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Conductivity
(mS/cm)
0
20
0.08
0.06
0.11
0.17
0.55
18
0.04
0.43
0.25
15
18
0.42
15
17
32
0.38
25
17
35
37
18
34
17
33
19
18
27
41
39
31
110
75
3
27
35
31
36
36
22 ±22
                                           4-19

-------
Performance Evaluation Report for Type I MSDs
                       Table 4-14. Chlorine Residual - Electro Scan
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ± Standard Deviation
Effluent Sample
Collection Time
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:48PM
8: 12 AM
10:36 AM
12:15 PM
3:48PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM
8: 12 AM
8:24 AM
12:15 PM
3:45PM
8: 12 AM
12:15 PM
1:36 PM
3:48PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent Free
Chlorine (mg/L)
1.0
0.80
1.2
0.34
0.45
0.66
0.74
0.59
0.55
0.81
1.1
0.73
0.10
0.54
0.30
0.50
6.8
0.76
0.61
0.89
0.25
0.86
0.98
0.69
0.40
1.2
1.2
1.6
1.0
1.4
1.5
1.4
0.96
0.90
0.99
1.3
0.82
1.2
1.3
1.4
1.0 ± 1.0
Effluent Total
Chlorine (mg/L)
2.2
2.2
1.7
2.2
0.90
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
6.8
6.9
8.8
8.8
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.2
2.7 ±1.8
                                           4-20

-------
Performance Evaluation Report for Type I MSDs
                          Table 4-15. Fecal Coliform - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent Concentration
(MPN/lOOmL)
4,000,000
6,000,000
5,000,000
4,700,000
30,000,000
6,000,000
22,000,000
3,000,000
5,000,000
9,000,000
9,500,000 ± 9,100,000
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52 PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent Concentration
(MPN/lOOmL)
13,000,000
220
8,000,000
5,000,000
9,000,000
5,000,000
5,000,000
3,000,000
1,300,000
2,700,000
2,400,000
3,500,000
1,700,000
140,000
500,000
6,000,000
30,000,000
1,300,000
3,000,000
7,000,000
5,000,000
7,000,000
11,000,000
5,000,000
17,000,000
NC
NC
13,000,000
5,000,000
ND(2,000)
170,000
ND(2,000)
13,000
11,000
ND(2,000)
<3,000
500,000
23,000
90,000
ND(2000)
<4,500,000 ± 6,100,000
NC - Sample not collected due to unit operating problems (see Section 3.9).
ND - Not detected (number in parentheses is detection limit).
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                4-21

-------
Performance Evaluation Report for Type I MSDs
                     Table 4-16. Visible Floating Solids - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent TSS
Concentration
(mg/L)
2,400
2,000
400
620
2,700
880
600
320
380
260
260
310
4,900
6,000
580
2,400
2,200
370
660
400
960
1,200
290
400
420
NC
NC
360
260
360
800
410
970
310
360
310
560
530
640
310
1,000 ± 1,300
Effluent VFS
Concentration
(mg/L)
78
0
0
0
100
0
100
0
0
0
1.9
0.9
1,600
240
2.8
36
49
3.1
5
0
79
35
0
10
1
NC
NC
7.5
1
3
28
12
49
18
4.5
1
9
26
51
0
66 ± 260
VFS as
% TSS
(%)
3.2
0
0
0
3.7
0
17
0
0
0
0.7
0.29
33
4.0
0.48
1.6
2.2
0.84
0.76
0
8.2
2.9
0
2.5
0.24
NC
NC
2.1
0.38
0.83
3.5
2.9
5.0
5.8
1.2
0.36
1.6
4.9
8.0
0

NC - Sample not collected due to unit operating problems (see Section 3.9).
                                             4-22

-------
Performance Evaluation Report for Type I MSDs
                          Table 4-17. Escherichia coli - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ± Standard
Deviation
Influent Concentration
(MPN/lOOmL)
6,400,000
7,700,000
6,800,000
20,000,000
8,000,000
6,100,000
19,000,000
6,300,000
3,700,000
7,400,000
9,100,000 ± 5,600,000
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent Concentration
(MPN/lOOmL)
4,900,000
1,000
1,500,000
2,300,000
3,200,000
8,600,000
3,600,000
3,300,000
9,700,000
3,900,000
2,600,000
1,500,000
4,300,000
4,400,000
1,800,000
ND(20,000)
7,400,000
2,000,000
3,900,000
2,500,000
7,600,000
13,000,000
2,400,000
1,200,000
21,000,000
NC
NC
18,000,000
2,800,000
<20,000
260,000
15,000,000
20,000
20,000
ND(20,000)
<30,000
630,000
20,000
82,000
20,000
<4,000,000 ± 5,200,000
NC - Sample not collected due to unit operating problems (see Section 3.9).
ND - Not detected (number in parentheses is detection limit).
 < - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                               4^23

-------
Performance Evaluation Report for Type I MSDs
                            Table 4-18. Enterococci - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent Concentration
(MPN/lOOmL)
1,300,000
3,300,000
350,000
9,200,000
570,000
960,000
370,000
840,000
1,900,000
720,000
2,000,000 ± 2,700,000
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52 PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12: 15PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
12: 15PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
11:46 AM
12: 15PM
3:52PM
8:30 AM
12: 15PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52 PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent Concentration
(MPN/lOOmL)
ND( 1,000,000)
32,000
440,000
730,000
2,000,000
800,000
530,000
450,000
480,000
160,000
31,000
68,000
990,000
180,000
10,000
110,000
440,000
190,000
440,000
310,000
370,000
750,000
200,000
43,000
870,000
NC
NC
200,000
110,000
<1,000
4,100
1,000
39,000
3,100
ND(1,000)
< 1,000
170,000
2,000
2,000
ND(1,000)
<320,000 ± 410,000
NC - Sample not collected due to unit operating problems (see Section 3.9).
ND - Not detected (number in parentheses is detection limit).
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                4-24

-------
Performance Evaluation Report for Type I MSDs
             Table 4-19. Biochemical Oxygen Demand (5 day) - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard Deviation
Influent
Concentration (mg/L)
1,900
NA
530
810
500
990
820
450
400
2,100
950 ± 630
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off Peak
Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
1,200
1,100
460
470
1,200
540
570
370
280
270
200
250
3,700
3,700
910
2,600
1,700
1,200
1,300
1,900
660
1,100
460
610
460
NC
NC
630
260
400
1,300
600
380
410
640
350
470
440
1,600
480
920 ± 850
NA - Sample not analyzed
NC - Sample not collected
due to laboratory error (see Section 6.1).
due to unit operating problems (see Section 3
9).
                                            4-25

-------
Performance Evaluation Report for Type I MSDs
                    Table 4-20. Total Suspended Solids - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent
Concentration (mg/L)
4,000
12,000
1,100
720
420
1,100
740
500
450
3,300
2,500 ± 3,600
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
2,400
2,000
400
620
2,700
880
600
320
380
260
260
310
4,900
6,000
580
2,400
2,200
370
660
400
960
1,200
290
400
420
NC
NC
360
260
360
800
410
970
310
360
310
560
530
640
310
1,000 ± 1,300
NC - Sample not collected due to unit operating problems (see Section 3.9).
                                            4-26

-------
Performance Evaluation Report for Type I MSDs
                     Table 4-21. Ammonia as Nitrogen - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent
Concentration (mg/L)
13
12
14
15
15
13
14
18
19
21
15 ± 3.0
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
11
13
17
21
12
12
12
16
12
15
15
14
15
15
17
20
18
16
17
18
9
12
14
15
14
NC
NC
16
o
5
21
21
22
16
18
23
22
15
23
25
23
16 ± 4.5
NC - Sample not collected due to unit operating problems (see Section 3.9).
                                            4^27

-------
Performance Evaluation Report for Type I MSDs
                    Table 4-22. Total Kjeldahl Nitrogen - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent
Concentration (mg/L)
170
290
62
230
41
73
37
75
46
74
110 ±89
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
89
130
62
69
110
48
55
37
42
39
37
34
100
92
73
110
59
49
50
50
35
45
49
51
51
NC
NC
48
21
62
76
58
44
42
48
60
48
68
58
54
59 ±24
NC - Sample not collected due to unit operating problems (see Section 3.9).
                                            4-28

-------
Performance Evaluation Report for Type I MSDs
                    Table 4-23. Nitrate/Nitrite as Nitrogen - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard Deviation
Influent
Concentration (mg/L)
0.11
0.3
ND(0.05)
0.08
ND(0.05)
ND(0.05)
ND(0.05)
ND(0.05)
0.07
ND(0.05)
<0.09 ± 0.078
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
0.28
0.36
0.22
0.24
ND(0.05)
ND(0.05)
ND(0.05)
ND(0.05)
0.08
0.15
0.17
0.14
0.23
0.19
0.20
0.24
0.13
0.12
0.13
0.12
ND(0.05)
ND(0.05)
ND(0.05)
ND(0.05)
ND(0.05)
NC
NC
ND(0.05)
0.44
0.22
0.13
0.08
0.25
0.23
0.27
0.14
0.11
0.21
0.39
0.34
<0.17±0.11
NC - Sample not collected due to unit operating problems (see Section 3.9).
ND - Not detected (number in parentheses is detection limit).
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                4-29

-------
Performance Evaluation Report for Type I MSDs
                       Table 4-24. Total Phosphorus - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ±
Standard
Deviation
Influent
Concentration (mg/L)
59
79
15
72
9.6
11
9
19
14
13
30 ±28
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
33
47
18
21
36
13
12
11
11
9.8
10
9.4
26
48
17
32
13
8.4
9.8
9.5
7.1
9.2
7.3
7.2
9.5
NC
NC
8.5
5.2
12
19
12
9.9
11
9.1
9.4
9.4
13
19
14
15 ±11
NC - Sample not collected due to unit operating problems (see Section 3.9).
                                            4-30

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Performance Evaluation Report for Type I MSDs
                               Table 4-25. pH - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Influent pH
6.2
6.1
6.4
5.8
6.2
7.0
5.9
7.0
6.1
6.7
Effluent Sample Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52 PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52 PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52 PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52 PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
Peak/Off Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Effluent pH
6.3
6.4
6.7
7.1
6.4
6.4
6.6
7.1
6.4
6.4
6.3
6.6
6.5
6.4
6.5
6.4
6.7
6.5
6.6
7.0
5.4
7.1
7.1
7.4
6.9
NC
NC
6.7
7.0
7.2
6.9
6.9
7.0
6.7
6.5
7.0
6.9
7.2
7.0
7.3
NC - Sample not collected due to unit operating problems (see Section 3.9).
                                            4-31

-------
Performance Evaluation Report for Type I MSDs
                         Table 4-26. Temperature - Thermopure-2
Date
4/9/2007
4/10/2007
4/11/2007
4/12/2007
4/13/2007
4/16/2007
4/17/2007
4/18/2007
4/19/2007
4/20/2007
Average ± Standard Deviation
Influent
Temperature (°C)
14
21
21
22
22
20
21
21
21
22
20 ± 2.4
Effluent Sample
Collection Time
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:58 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Temperature (°C)
39
46
39
38
42
40
39
40
42
43
43
43
45
47
43
43
43
39
41
41
38
41
43
41
37
NC
NC
40
43
49
47
45
49
42
48
49
46
49
49
45
43 ± 3.5
NC - Sample not collected due to unit operating problems (see Section 3.9).
                                            4-32

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Performance Evaluation Report for Type I MSDs
                                         Table 4-27. Summary of Type I MSD Performance
Analysis
Fecal Coliform
Visible Floating Solids
Escherichia coli
Enterococci
Biochemical Oxygen Demand (5 day)
Total Suspended Solids
Ammonia as Nitrogen
Total Kjeldahl Nitrogen
Nitrate/Nitrite as Nitrogen
Total Phosphorus
pH
Temperature
Conductivity
Chlorine Residual (Free)
Chlorine Residual (Total)
Average Influent Concentration ± Standard
Deviation
9,500,000 ±9, 100,000
-
9, 100,000 ±5,600,000
2,000,000 ± 2,700,000
950 ±630
2,500 ± 3,600
15 ±3.0
110 ±89
0.09 ± 0.078
30 ±28
5. 8 to 7.0
20 ± 2.4
0.27 ±0.37
-
-
Average Effluent Concentration ± Standard
Deviation
Electro Scan
<82 ± 350
190 ± 860
<1,400± 5,500
<790 ± 3,900
780 ± 600
1,000 ± 860
8.2 ±4.7
42 ±23
<2.1±1.9
15 ±8.4
5. 8 to 6.8
21 ±4.3
22 ±22
1.0 ±1.0
2.7 ±1.8
Thermopure-2
<4,500,000± 6, 100,000
66 ± 260
<4,000,000 ± 5,200,000
<320,000± 4 10,000
920 ± 850
1,000 ±1,300
16 ±4.5
59 ±24
0.17 ±0.11
15±11
5.4 to 7.4
43 ±3. 5
-
-
-
Unit
MPN/100
mL
mg/L
MPN/100
mL
MPN/100
mL
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
-
°C
mS/cm
mg/L
mg/L
        < - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                                 4-33

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Performance Evaluation Report for Type I MSDs
5.0    THERMOPURE-2 RETEST
       The Thermopure-2 unit is believed to have not reached the designated threshold
temperature sufficient to kill bacteria due to the misalignment of a thermal sensor. Per a request
by Gross Mechanical Laboratories, Inc., a retest of a replacement Thermopure-2 device was
conducted. The scope of the retesting was reduced from that of the original test due to a
limitation in funding. Accordingly, challenge wastewater sampling and analysis was reduced to a
single sample of the challenge wastewater batch prepared each day to verify the target TSS
concentration of 500 mg/L. Effluent sampling remained at four samples per day; however,
sample analyses were reduced to fecal coliform, visible floating solids, BOD5, and TSS. The
duration of the performance testing was also reduced from 10 to nine days. Retesting dates were
October 15 and 16, 2007, November 29 and 30, 2007, and December 3 through 7, 2007.

5.1    Performance Evaluation Retesting Procedures
Installation and Start-up
       A replacement device, shipped by the manufacturer, was received at the test site on
October 12 and was installed on the testing platform in the same manner as the April testing. The
same means of tilting the device during testing was used. A trial run of the system was
completed on October 13, using fresh water following the start-up procedures provided by the
manufacturer. The device was found to be ready for testing.
       Retesting with challenge wastewater began on October 15, using the same dosing
schedule as the April testing. While sample effluent temperatures were higher than those
measured during the April testing, they were not as high as the manufacturer indicated they
should be. Test-site  personnel conferred with the manufacturer, who expressed confidence in
proper operation of the device. However, preliminary fecal coliform results from the first day of
retesting on October 16 indicated that the unit was not performing as expected. After consulting
with the manufacturer, retesting was halted on the morning of October  17.
       On October  18, test facility personnel assisted the manufacturer in troubleshooting the
device. Specifically, they accessed the processor chip that controls unit operation and took
voltage readings as the device processed 10 cycles of clean water over three hours. The
manufacturer confirmed that the voltage readings indicated that the chip was functioning as
                                          5-1

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Performance Evaluation Report for Type I MSDs
designed. Based on this information, the manufacturer began evaluating whether the
programming of the chip was causing the temperature to not reach manufacturer indicated levels.
       The test facility received a new processor chip on November 27, installed it, and verified
proper operation by testing with fresh water. Retesting with challenge wastewater commenced
on November 29, and continued through December 7, using the same dosing schedule as the
April testing.
       Effluent sample temperatures were still not as high as expected. Following discussions
with the manufacturer, test-site personnel investigated whether the temperature discrepancy
resulted from temperature measurements taken at the sampling location rather than at the heating
block during the treatment cycle. On November 29, test-site personnel installed  a thermometer
close to the outlet of the heating block to develop a temperature profile over several four- to five-
minute treatment cycles. Over the first 60 to 90 seconds, the temperature rose to a high point of
85°C to 91°C. The heating element then turned off, and the temperature steadily declined over
the next 120 to 180 seconds until it reached 75°C to 80°C at the start of pump-out. Effluent
temperature at the end of pump-out was approximately 58°C. Based on these results, the
manufacturer expressed confidence in proper operation of the device.

Sewage Processing Test
       The sewage processing test was performed  in the same manner as the April test. As
shown in Table 5-1, the influent TSS concentrations during testing ranged from  230 mg/L to
3,100 mg/L. There were three days during the testing when the influent TSS concentration was
less than 500 mg/L; however, the average TSS concentration over the course of the test was
1,280 mg/L with a standard deviation of ±3,600 mg/L (1,300 mg/L ± 1,100 mg/L excluding the
October testing).
                                          5-2

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Performance Evaluation Report for Type I MSDs
                 Table 5-1. Influent TSS Results - Theromopure-2 Retest
Date
Influent TSS (mg/L)
October Retesting
10/15/2007
10/16/2007
600
1,700
November/December Retesting
11/29/2007
11/30/2007
12/3/2007
12/4/2007
12/5/2007
12/6/2007
12/7/2007
1,000
330
230
460
1,700
3,100
2,400
MSD Operation and Maintenance
       The device required no maintenance during the testing.

Sample Collection
       Sample collection was performed identically with the April testing, with one exception.
Because of the reduced number of analyses, the volume needed for each sample was reduced,
allowing for collection of samples directly into sample bottles. This differs from the April testing
where samples were collected into carboys, mixed, and poured off into appropriate sample
bottles.

Process Monitoring
       Process monitoring was the same as during the April testing.

Field QC Measures
       Field QC samples for the Thermopure-2 retesting included duplicate samples. Equipment
blanks were not required as the intermediate sample collection carboys were not used.

Deviation from the Work Plan
       Performance retesting proceeded as specified in the work plan with the following
deviations:
                                          5-3

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Performance Evaluation Report for Type I MSDs
    •   The scope of the retesting was reduced from that of the original test due to a limitation in
       funding. Accordingly, challenge wastewater evaluation was reduced to a single sample of
       the challenge wastewater batch prepared each day to verify the minimum target TSS
       concentration of 500 mg/L. Effluent sampling remained at four samples per day;
       however, sample analyses were reduced to fecal coliform, visible floating solids, BOD5,
       and TSS. The duration of the performance testing was also reduced from 10 days to nine
       days.

    •   The device overflowed during the morning of November 29, which resulted in six missed
       doses and only 26 gallons of wastewater processed for that day. No samples were missed.
       The holding tank filled and overflowed because of the longer heating cycles resulting
       from the reprogrammed processor chip, coupled with the warm-up time required for start-
       up each morning.

    •   The reprogramming of the chip affected the peak flow rate capacity of the Thermopure-2
       device. After the overflow on November 29, the influent was allowed to back up into the
       dosing  line, and the unit processed the wastewater during off-peak dosing periods. The
       full  dosing volume of 32 gallons was processed in the days following November 29.

5.2    Retest  Results and Discussion
5.2.1   Fecal Coliform
       Table 5-2 presents the fecal coliform data for the Thermopure-2 retesting. The effluent
produced by the Thermopure-2 device during the November/December retesting ranged from
nondetect to 3,000,000 fecal coliform bacteria MPN/100 mL with a  mean concentration of
380,000 MPN/100 mL (see Table 5-2).7 While these results show some improvement compared
to the April testing (range from nondetect to 30,000,000 fecal coliform bacteria MPN/100 mL
with a mean concentration of 4,500,000 MPN/100 mL), device performance remained poor.
Although the cause of the poor performance is unknown, the device pump-out volume may have
7 Performance testing was not conducted in accordance with the test conditions described in 33 CFR 159.53
(Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic human sewage
rather than human sewage in a ratio of four urinations to one defecation, as specified in 3 3 CFR 15 9.121 (c).
                                           5-4

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Performance Evaluation Report for Type I MSDs
exceeded the capacity of the heating chamber, which would have mixed unheated (untreated)
wastewater with treated wastewater during discharge (see discussion in Section 7.2).

5.2.2   Visible Floating Solids
       Table 5-3 presents the VFS data for the Thermopure-2 retesting. VFS concentrations in
the effluent from the Thermopure-2 device during the November/December retesting ranged
from zero to 1,000 mg/L with a mean concentration of 100 mg/L. Of the 28 collected samples,
26 had VFS less than 10% of the effluent TSS.8 The November/December VFS results are
similar to those from the April testing.

5.2.3   Biochemical Oxygen Demand and Total Suspended Solids
       Tables 5-4 and 5-5 present BOD5 and TSS data, respectively, for the Thermopure-2
retesting. Both analytes were detected in all 28 samples. There are currently no BOD5 or TSS
federal performance standards for Type I MSDs.
       The following table, for the purpose of comparison, shows the effluent quality from the
Thermopure-2 device (which is not required to remove BODs or TSS) and EPA's standards for
secondary treatment for land-based publicly owned treatment works (POTWs). Note that the
technology and capacity of Type I MSDs and POTWs are very different and must be considered
in any comparison.

   BOD5 Comparison of Effluent from Type I MSDs to Secondary Treatment Standards
Analyte
BOD5 (mg/L)
TSS (mg/L)
Average Effluent Concentration From Thermopure-2
November/December
Retesting
710
1,100
April Testing
920
1,000
EPA Secondary
Treatment Standards a
45
45
' 40 CFR 133.102 Secondary Treatment Regulations, 7-day average.
5.2.4   Process Monitoring
       Review of the pH results for the Thermopure-2 retesting in Table 5-6 showed there were
no uncharacteristic pH excursions in the challenge wastewater or the treated effluent.
 Performance testing was not conducted in accordance with the test conditions described in 33 CFR 159.53
(Appendix A). For reasons of practicality, testing was conducted using a feed of fresh domestic human sewage
rather than human sewage in a ratio of four urinations to one defecation, as specified in 3 3 CFR 15 9.121 (c).
                                           5-5

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Performance Evaluation Report for Type I MSDs
       As expected, the reprogrammed processor chip produced significantly greater effluent
sample temperatures during the November/December retesting as compared to the original chip
for the April testing: an average of 62°C (see Table 5-7) as compared to an average of 43°C. This
increase in temperature is likely responsible for the somewhat improved device performance in
removing fecal coliform (see Section 5.2.1).
                                          5-6

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Performance Evaluation Report for Type I MSDs
                       Table 5-2. Fecal Coliform - Thermopure-2 Retest
Date
Effluent Sample
Collection Time
Peak/Off Peak Flow
Effluent Concentration
(MPN/lOOmL)
October Retesting
10/15/2007
10/16/2007
8:40 AM
9:05 AM
12:20 PM
4:00 PM
8:35 AM
11:50 AM
12:20 PM
3:56PM
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
700,000
240,000
1,300,000
110,000
9,000,000
24,000,000
3,000,000
280,000,000
November/December Retesting
11/29/2007
11/30/2007
12/3/2007
12/4/2007
12/5/2007
12/6/2007
12/7/2007
Average ± Standard
Deviation
8:30 AM
8:50 PM
12:15 PM
3:55 PM
8:30 AM
12:15 AM
2:52 PM
3:52PM
8:30 AM
8:55 AM
12:15 PM
3:52 PM
8:30 AM
11:46 AM
12:15 PM
1:52 PM
8:30 AM
12: 15PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
12: 15PM
2:52 PM
3:52PM

Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

2,200,000
3,000,000
300
2,200
1,700,000
3,000,000
50
1,700
5,000
4,000
1,600
ND(2.0)
14,000
28,000
3,000
3,000
5,000
1,300
2.0
2.0
300,000
500
900
22,000
130,000
170,000
800
350
<9,100,000 ± 47,000,000
(<380,000 ± 900,000 a)
a Average of November/December samples.
ND - Not detected (number in parentheses is detection limit).
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                5-7

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Performance Evaluation Report for Type I MSDs
                    Table 5-3. Visible Floating Solids - Thermopure-2 Retest
Date
Effluent Sample
Collection Time
Peak/Off
Peak Flow
Effluent TSS
Concentration
(mg/L)
Effluent VFS
Concentration
(mg/L)
VFS as
% TSS
October Retesting
10/15/2007
10/16/2007
8:40 AM
9:05 AM
12:2 PM
4:00 PM
8:35 AM
11:50 AM
12:20 PM
3:56PM
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
330
320
820
790
870
1,500
1,100
1,400
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
November/December Retesting
11/29/2007
11/30/2007
12/3/2007
12/4/2007
12/5/2007
12/6/2007
12/7/2007
Average ±
Standard
Deviation
8:30 AM
8:50 AM
12: 15PM
3:55PM
8:30 AM
12: 15PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
11:46 AM
12: 15PM
1:52 PM
8:30 AM
12: 15PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
12: 15PM
14:52 PM
3:52PM

Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

700
660
680
840
430
230
140
100
480
320
190
130
290
280
180
150
3,100
2,000
1,700
1,200
2,500
2,500
1,300
1,100
3,700
2,600
1,300
1,500
1,000 ± 920
(1,100 ± 1,000 a)
0
10
5
4
1
7
2
1
38
8
0
1
1
0
0
0
20
160
120
80
220
41
1,000
38
330
670
67
20
100 ± 230 a
0
1.5
0.74
0.48
0.23
3.0
0.71
2.0
7.9
2.5
0
0.77
0.34
0
0
0
0.65
8.0
7.1
6.7
8.8
1.6
77
3.5
8.9
26
5.1
1.3

a Average of November/December samples.
NA - Samples not analyzed due to termination of October retesting.
                                             5-8

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Performance Evaluation Report for Type I MSDs
          Table 5-4. Biochemical Oxygen Demand (5 day) - Thermopure-2 Retest
Date
Effluent Sample Collection
Time
Peak/Off Peak Flow
Effluent Concentration
(mg/L)
October Retesting
10/15/2007
10/16/2007
8:40 AM
9:05 AM
12:20 PM
4:00 PM
8:30 AM
11:50 AM
12:20 PM
3:56PM
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
160
250
970
470
1,100
1,400
1,500
1,600
November/December Retesting
11/29/2007
11/30/2007
12/3/2007
12/4/2007
12/5/2007
12/6/2007
12/7/2007
Average ± Standard
Deviation
8:30 AM
8:50 AM
12:15 PM
3:55PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
2:52 PM
3:52PM

Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

320
320
420
480
370
230
350
220
440
300
270
230
250
200
190
240
1,200
1,500
1,300
980
920
1,400
940
970
>1,900
1,800
1,100
1,100
760 ± 540
(710 ± 540 a)
a Average of November/December samples.
> - The sample was not diluted sufficiently; actual concentration is greater than the reported upper limit.
                                             5-9

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Performance Evaluation Report for Type I MSDs
                Table 5-5. Total Suspended Solids - Thermopure-2 Retest
Date
10/15/2007
10/16/2007
11/29/2007
11/30/2007
12/3/2007
12/4/2007
12/5/2007
12/6/2007
12/7/2007
Average ±
Standard Deviation
Influent
Concentration (mg/L)
600
1,700
1,100
330
230
460
1,700
3,100
2,400
1,300 ± 1,000
(1,300 ± 1,100 a)
Effluent Sample
Collection Time
8:40 AM
9:05 AM
12:2 PM
4:00 PM
8:35 AM
11:50 AM
12:20 PM
3:56PM
8:30 AM
8:50 AM
12: 15PM
3:55PM
8:30 AM
12: 15PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
11:46 AM
12: 15PM
1:52 PM
8:30 AM
12: 15PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12: 15PM
3:52PM
8:30 AM
12: 15PM
14:52 PM
3:52PM

Peak/Off
Peak Flow
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

Effluent
Concentration (mg/L)
330
320
820
790
870
1,500
1,100
1,400
700
660
680
840
430
230
140
100
480
320
190
130
290
280
180
150
3,100
2,000
1,700
1,200
2,500
2,500
1,300
1,100
3,700
2,600
1,300
1,500
1,000 ± 920
(1,100 ± 1,000 a)
a Average of November/December samples.
                                          5-10

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Performance Evaluation Report for Type I MSDs
                        Table 5-6. pH - Thermopure-2 Retest
Date
Influent pH
Effluent Sample
Collection Time
Peak/Off Peak
Flow
Effluent pH
October Retesting
10/15/2007
10/16/2007
6.4
6.7
8:40 AM
9:05 AM
12:2 PM
4:00 PM
8:35 AM
11:50 AM
12:20 PM
3:56PM
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
6.9
6.9
7.1
7.0
6.7
6.5
6.7
6.6
November/December Retesting
11/29/2007
11/30/2007
12/3/2007
12/4/2007
12/5/2007
12/6/2007
12/7/2007
6.7
6.4
6.8
6.6
6.9
6.9
7.0
8:30 AM
8:50 AM
12:15 PM
3:55PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
1:52 PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
14:52 PM
3:52PM
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
6.1
6.2
6.1
6.2
5.9
5.8
6.5
6.1
7.0
7.0
7.0
6.6
6.8
7.4
7.1
6.7
7.3
7.3
7.3
7.2
6.8
7.5
7.1
7.2
6.9
6.9
7.1
7.4
                                         5-11

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Performance Evaluation Report for Type I MSDs
                     Table 5-7. Temperature - Thermopure-2 Retest
Date
Influent
Temperature (°C)
Effluent Sample
Collection Time
Peak/Off
Peak Flow
Effluent
Temperature (°C)
October Retesting
10/15/2007
10/16/2007
28
27
8:40 AM
9:05 AM
12:2 PM
4:00 PM
8:35 AM
11:50 AM
12:20 PM
3:56PM
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
56
57
66
58
63
61
57
53
November/December Retesting
11/29/2007
11/30/2007
12/3/2007
12/4/2007
12/5/2007
12/6/2007
12/7/2007
Average ± Standard Deviation
22
22
21
22
22
22
23
23 ± 2.5
(22 ± 0.58 a)
8:30 AM
8:50 AM
12:15 PM
3:55PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
11:46 AM
12:15 PM
1:52 PM
8:30 AM
12:15 PM
2:52 PM
3:52PM
8:30 AM
8:50 AM
12:15 PM
3:52PM
8:30 AM
12:15 PM
14:52 PM
3:52PM

Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak
Peak
Peak
Off Peak
Off Peak
Peak
Off Peak
Peak
Off Peak

46
60
65
64
53
63
66
67
68
65
67
63
60
62
59
61
51
58
61
61
64
67
65
66
59
64
55
65
61 ±5.1
(62 ± 5.2 a)
' Average of November/December samples.
                                          5-12

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Performance Evaluation Report for Type I MSDs
6.0    DATA QUALITY
       Quality assurance/quality control (QA/QC) procedures applicable to this Type IMSD
performance evaluation are outlined in the Evaluation of Type I Marine Sanitation Devices
(MSDs) Quality Assurance Project Plan (QAPP) dated March 20, 2007. This section describes
the QC practices used to assess the precision and accuracy of the analytical data presented in
Section 4.0. QC practices used for this performance evaluation include the analysis of matrix
spikes, duplicate samples, and QC standard checks.

6.1    Analytical PC
       NSF site personnel measured residual chlorine and visible floating solids onsite due to
the relatively short holding times. Aqua-Tech Laboratories, Inc., of Bryan, Texas completed the
chemical and biological analyses.9 Aqua-Tech prepared written data review narratives describing
any qualifications of the analytical data. NSF and ERG verified that contract laboratory
performance was acceptable by conducting quality control checks of the analytical data as
specified by the QAPP. Most of the data were determined to be of acceptable quality. The
following data were not considered to be of acceptable quality and were excluded from the data
set:
Sample
Influent, 4/10/2007
Electro Scan Effluent, 4/12/2007, 12:15
PM
Electro Scan Effluent, 4/12/2007, 3:48 PM
Electro Scan Effluent, 4/19/2007, 8:12 AM
Retesting Equipment Blanks, 10/15/2007,
11/29/2007
Analytical Parameter
BOD5
E. coli
E. coli
E. coli
BOD5, TSS, Fecal coliform
Reason for Exclusion
Sample not analyzed due to laboratory
error.
Laboratory determined results to be
inconclusive.
Equipment blanks were not required
for Thermopure-2 retesting as samples
were collected directly into sample
containers.
 NSF's facility located in Ann Arbor, Michigan is currently accepted by the USCG as a Recognized Facility for the
evaluation, inspected, and testing of marine sanitation devices under 33 CFR 159.15. However, NSF's Waco, Texas
and Aqua-Tech Laboratories, Inc. subfacility currently is not accepted as a Recognized Facility by the USCG.	
                                            6-1

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Performance Evaluation Report for Type I MSDs
6.2    Field PC
       The field QA/QC measures discussed in this subsection includes equipment blanks and
field duplicate results, as specified in Section 6.3 of the Type IMSD QAPP. Tables are presented
at the end of this section.

6.2.1   Equipment Blanks
April Testing
       NSF test-site personnel collected equipment blank QC samples to evaluate the potential
introduction of contaminants by sample collection equipment. The sample collection equipment
used to collect the equipment blank was identical to that used at the sampling points: effluent
receiving containers for each device and carboys used to collect, mix, and pour the challenge
wastewater and MSD effluent samples. Prior to collecting the equipment blanks, the sampling
equipment was decontaminated by cleaning with Alconox cleaning solution, and then rinsed with
distilled water. Following decontamination, fresh distilled water was added to each container and
carboy, lids were put in place, and the equipment was vigorously shaken. This distilled water
was decanted into sample bottles and analyzed for the same parameters as the samples collected
using the sampling equipment.
       Table 6-1 presents the results from equipment blank analyses. The results showed no
contamination of the influent carboy or the Electro Scan effluent receiving container. The only
analyte detected in the equipment blanks for the Thermopure-2 effluent receiving container and
the Electro Scan and Thermopure-2 carboys was nitrate/nitrite,  with concentrations ranging from
0.05 to 0.07  mg/L, close to the detection limit of 0.05 mg/L. The source of nitrate/nitrite is likely
the Alconox that was used for the cleaning. Alconox  contains ethylenediaminetetraacetic acid,
which could (per the manufacturer) result in a positive reading for total nitrogen, in this case
nitrate. Average nitrate/nitrite concentrations in the effluent samples were 2.4- to 30-times
greater than  those found in the equipment blanks; therefore, it is unlikely that equipment
contamination had a significant impact the  sample results.

October and November/December Retesting
       Equipment blanks were not required for the Thermopure-2 retesting as samples were
collected directly into sample bottles.
                                           6-2

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Performance Evaluation Report for Type I MSDs
6.2.2  Field Duplicates
       Field duplicate samples were collected to assess the precision of the sampling and
analysis process. Field duplicate samples were collected from the same source, at the same time,
and then stored and analyzed independently. The relative percent difference (RPD) between the
two duplicate sample results was calculated and compared to the target objective of 30% for each
analyte. In the tables presenting the analytical results in Sections 4 and 5, duplicate sample
results are presented as averages (calculation uses detection limits for non-detected results).

April Testing
       Duplicate samples were collected as split samples  poured from the same sample
collection carboy to minimize sample waste  stream variability. Two duplicate samples of the
challenge wastewater were collected on two  different days of the 10-day testing period,
representing one set of duplicates for every batch of five challenge wastewater samples. Four
duplicate samples were also collected of the  effluent from each of the two MSDs throughout the
10-day testing period. Effluent duplicate samples represent one set of duplicates for every batch
of 10 effluent samples.
       Table 6-2 presents analytical results and the RPDs for these duplicate samples.
Approximately 45% of the challenge wastewater duplicate pairs  either achieved the RPD target,
or the RPD could not be calculated because one or both of the sample results was less than the
laboratory detection limit. Approximately 70% of the Electro Scan duplicate pairs and
approximately 80% of the Thermopure-2 duplicate pairs either achieved the RPD target, or the
RPD could not be calculated because one or  both of the sample results was less than the
laboratory detection limit, respectively. These results are common in complex wastewater
samples.
       The presence of unmacerated versus macerated solids in the samples appears to affect the
ability to achieve the RPD targets. This was demonstrated by the differences in the percentages
of duplicate pairs that achieve the RPD target for challenge wastewater versus effluent samples.

November/December Retesting
       As a result of the modification to the  sampling procedure, duplicate samples were
collected as sequential grab samples. This methodology introduced wastewater variability into
the assessment of the precision of sample collection and analysis as compared to the

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Performance Evaluation Report for Type I MSDs
methodology used for the April testing, which used split samples. One duplicate sample of the
challenge wastewater was collected for the series of seven challenge wastewater samples. (An
additional challenge wastewater duplicate sample was collected during the October retesting
period.) Two duplicate samples of the Thermopure-2  effluent were also collected during the
nine-day retesting period, and three duplicate samples were collected for visible floating solids.
One set of duplicates was collected for every batch of 10 to 15 effluent samples.
       Table 6-2 presents analytical results and the RPDs for these duplicate samples. All of the
challenge wastewater duplicate pairs achieved the RPD target. Six of the 10 Thermopure-2
duplicate pairs achieved the RPD target, while the remaining four did not. These results are
common in complex and variable wastewater samples

6.3    Testing Audit
       ERG conducted an audit of NSF's Waco, Texas test facility to evaluate compliance with
procedures, testing protocols, and analyses outlined in the Evaluation of Type I Marine
Sanitation Devices (MSDs) Work Plan dated March 20, 2007 and the Evaluation of Type I
Marine Sanitation Devices (MSDs)  Quality Assurance Project Plan (QAPP) dated March 20,
2007.
       During the audit, two days of performance testing and sample collection were observed.
This included preparation of the challenge wastewater, device start-up procedures, operation of
both devices at peak and off peak dosing cycle, handling of samples, and record keeping for both
the Electro Scan and Thermopure-2 devices by NSF. ERG verified device operations, waste
dosing, sample collection, field tests, field test documentation, instrument calibrations,  daily
tilting of devices,  sample preservation, and transportation  of the samples to the laboratory as
outlined in the Audit Checklist provided as Figure 8-2 of the QAPP. Mechanical malfunction,
troubleshooting, and the eventual repair of the Thermopure-2 device was also observed and
documented on the second day of the audit.
       ERG observed some minor issues and their resolutions (as applicable) during the audit,
but none of these issues impacted the analytical results from this Type IMSD test program.
Further detailed observations, the audit checklists, and a list of issues and resolutions are
provided in the Audit Report for Type I MSD Testing (Appendix C).
                                           6-4

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Performance Evaluation Report for Type I MSDs
                                              Table 6-1. Equipment Blank Results
Analyte
Unit
Influent
Carboy
Electro Scan Effluent
Receiving
Container
Carboy
Thermopure-2 Effluent
Receiving
Container
Carboy
April Testing
Fecal Coliform
Escherichia coli
Enterococci
Biochemical Oxygen Demand (5 day)
Total Suspended Solids
Ammonia as Nitrogen
Total Kjeldahl Nitrogen
Nitrate/Nitrite as Nitrogen
Total Phosphorus
MPN/100 mL
MPN/100 mL
MPN/100 mL
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
ND(l.l)
ND(l.O)
ND(l.O)
ND(2)
ND(1)
ND(0.05)
ND(0.50)
ND(0.05)
ND(0.05)
ND(l.l)
ND(l.O)
ND(l.O)
ND(2)
ND(1)
ND(0.05)
ND(0.50)
ND(0.05)
ND(0.05)
ND(l.l)
ND(l.O)
ND(l.O)
ND(2)
ND(1)
ND(0.05)
ND(0.50)
0.06
ND(0.05)
ND(l.l)
ND(l.O)
ND(l.O)
ND(2)
ND(1)
ND(0.05)
ND(0.50)
0.05
ND(0.05)
ND(l.l)
ND(l.O)
ND(l.O)
ND(2)
ND(1)
ND(0.05)
ND(0.50)
0.07
ND(0.05)
ND - Not detected (number in parentheses is detection limit).
                                                                6-5

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Performance Evaluation Report for Type I MSDs
                                            Table 6-2. Field Duplicate Analytical Results
Sample
Collection
Date
Time
Analysis
Unit
Original
Sample
Duplicate
Sample
Average
Concentration
Relative %
Difference
April Testing
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Influent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
4/9/2007
4/16/2007
4/9/2007
4/16/2007
4/9/2007
4/16/2007
4/9/2007
4/16/2007
4/9/2007
4/16/2007
4/9/2007
4/16/2007
4/9/2007
4/16/2007
4/9/2007
4/16/2007
4/9/2007
4/16/2007
4/10/2007
4/13/2007
4/17/2007
4/20/2007
4/10/2007
4/13/2007
4/17/2007
4/20/2007
4/10/2007
4/13/2007
4/17/2007
4/20/2007
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8: 00 AM
8: 00 AM
8:00 AM
8:00 AM
8:00 AM
8:00 AM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
Ammonia as Nitrogen
Ammonia as Nitrogen
Biochemical Oxygen Demand (5 day)
Biochemical Oxygen Demand (5 day)
Enterococci
Enterococci
Escherichia coli
Escherichia coli
Fecal Coliform
Fecal Coliform
Nitrate/Nitrite as Nitrogen
Nitrate/Nitrite as Nitrogen
Total Kjeldahl Nitrogen
Total Kjeldahl Nitrogen
Total Phosphorus
Total Phosphorus
Total Suspended Solids
Total Suspended Solids
Ammonia as Nitrogen
Ammonia as Nitrogen
Ammonia as Nitrogen
Ammonia as Nitrogen
Biochemical Oxygen Demand (5 day)
Biochemical Oxygen Demand (5 day)
Biochemical Oxygen Demand (5 day)
Biochemical Oxygen Demand (5 day)
Enterococci
Enterococci
Enterococci
Enterococci
mg/L
mg/L
mg/L
mg/L
MPN/100 mL
MPN/100 mL
MPN/100 mL
MPN/100 mL
MPN/100 mL
MPN/100 mL
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
MPN/lOOmL
MPN/100 mL
MPN/100 mL
MPN/lOOmL
13
13
2,100
850
890,000
300,000
5,400,000
7,400,000
3,000,000
9,000,000
0.13
ND(0.05)
190
84
63
8.8
4,500
880
8.1
8.2
7
7.1
1,300
3,100
720
560
ND(IOO)
ND(l.l)
ND(l.l)
ND(10)
13
14
1,800
1,100
1,700,000
1,600,000
7,400,000
4,800,000
5,000,000
3,000,000
0.09
ND(0.05)
140
62
54
12
3,500
1,400
7.3
7.8
4.4
16
1,000
2,200
800
1,600
ND(IOO)
ND(l.l)
ND(l.l)
ND(10)
13
13
1,900
990
1,300,000
960,000
6,400,000
6,100,000
4,000,000
6,000,000
0.11
ND(0.05)
170
73
59
11
4,000
1,100
7.7
8.0
5.7
12
1,200
2,600
760
1,100
ND(IOO)
ND(l.l)
ND(l.l)
ND(10)
0.80%
3.0%
16%
29%
64%
140%
31%
43%
50%
100%
36%
NC
32%
30%
15%
35%
24%
44%
10%
4.9%
45%
77%
24%
33%
9.5%
95%
NC
NC
NC
NC
                                                                 6-6

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Performance Evaluation Report for Type I MSDs
                                     Table 6-2. Field Duplicate Analytical Results (Continued)
Sample
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Electro Scan Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Collection
Date
4/10/2007
4/13/2007
4/17/2007
4/20/2007
4/10/2007
4/13/2007
4/17/2007
4/20/2007
4/10/2007
4/13/2007
4/17/2007
4/20/2007
4/10/2007
4/13/2007
4/17/2007
4/20/2007
4/10/2007
4/13/2007
4/17/2007
4/20/2007
4/10/2007
4/13/2007
4/17/2007
4/20/2007
4/12/2007
4/13/2007
4/16/2007
4/18/2007
4/11/2007
4/12/2007
4/18/2007
Time
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8: 12 AM
1:36 PM
8:24 AM
1:36 PM
3:48 PM
1:36 M
12:15 PM
3:52 PM
12:15 PM
Analysis
Escherichia coli
Escherichia coli
Escherichia coli
Escherichia coli
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Nitrate/Nitrite as Nitrogen
Nitrate/Nitrite as Nitrogen
Nitrate/Nitrite as Nitrogen
Nitrate/Nitrite as Nitrogen
Total Kjeldahl Nitrogen
Total Kjeldahl Nitrogen
Total Kjeldahl Nitrogen
Total Kjeldahl Nitrogen
Total Phosphorus
Total Phosphorus
Total Phosphorus
Total Phosphorus
Total Suspended Solids
Total Suspended Solids
Total Suspended Solids
Total Suspended Solids
Visible Floating Solids
Visible Floating Solids
Visible Floating Solids
Visible Floating Solids
Ammonia as Nitrogen
Ammonia as Nitrogen
Ammonia as Nitrogen
Unit
MPN/100 mL
MPN/100 mL
MPN/100 mL
MPN/100 mL
MPN/lOOmL
MPN/lOOmL
MPN/lOOmL
MPN/lOOmL
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Original
Sample
ND(IOO)
ND(10)
ND(ll)
ND(10)
ND(l.l)
3.3
1.1
ND(l.l)
1.1
1.5
1.6
1.2
34
54
46
54
25
14
11
16
3,100
1,200
800
1,000
67
310
120
140
16
20
20
Duplicate
Sample
ND(IOO)
ND(l.l)
11
ND(10)
ND(l.l)
ND(l.l)
ND(l.l)
ND(l.l)
1.4
1.4
1.3
1.2
39
45
50
85
41
11
12
24
3,400
730
1,200
1,100
110
41
140
72
15
20
23
Average
Concentration
ND(IOO)
ND(5.6)
<11
ND(10)
ND(l.l)
<2.2
<1.1
ND(l.l)
1.2
1.4
1.4
1.2
37
49
48
69
33
13
11
20
3,300
960
1,000
1,000
86
180
130
110
15
20
21
Relative %
Difference
NC
NC
NC
NC
NC
NC
NC
NC
26%
6.4%
21%
2.5%
14%
17%
12%
45%
48%
30%
7.0%
41%
10%
48%
42%
16%
45%
150%
14%
65%
6.0%
3.0%
14%
                                                                6-7

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Performance Evaluation Report for Type I MSDs
                                     Table 6-2. Field Duplicate Analytical Results (Continued)
Sample
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Collection
Date
4/19/2007
4/11/2007
4/12/2007
4/18/2007
4/19/2007
4/11/2007
4/12/2007
4/18/2007
4/19/2007
4/11/2007
4/12/2007
4/18/2007
4/19/2007
4/11/2007
4/12/2007
4/18/2007
4/19/2007
4/11/2007
4/12/2007
4/18/2007
4/19/2007
4/11/2007
4/12/2007
4/18/2007
4/19/2007
4/11/2007
4/12/2007
4/18/2007
4/19/2007
4/11/2007
4/12/2007
Time
3:52 PM
12:15 PM
3:52 PM
12:15 PM
3:52 PM
12: 15PM
3: 52PM
12: 15PM
3: 52PM
12:15 PM
3:52 PM
12:15 PM
3:52 PM
12: 15PM
3:52 PM
12:15 PM
3:52 PM
12:15 PM
3:52 PM
12:15 PM
3:52 PM
12:15 PM
3:52 PM
12:15 PM
3: 52PM
12: 15PM
3:52 PM
12:15 PM
3: 52PM
12:15 PM
3:52 PM
Analysis
Ammonia as Nitrogen
Biochemical Oxygen Demand (5 day)
Biochemical Oxygen Demand (5 day)
Biochemical Oxygen Demand (5 day)
Biochemical Oxygen Demand (5 day)
Enterococci
Enterococci
Enterococci
Enterococci
Escherichia coli
Escherichia coli
Escherichia coli
Escherichia coli
Fecal Coliform
Fecal Coliform
Fecal Coliform
Fecal Coliform
Nitrate/Nitrite as Nitrogen
Nitrate/Nitrite as Nitrogen
Nitrate/Nitrite as Nitrogen
Nitrate/Nitrite as Nitrogen
Total Kjeldahl Nitrogen
Total Kjeldahl Nitrogen
Total Kjeldahl Nitrogen
Total Kjeldahl Nitrogen
Total Phosphorus
Total Phosphorus
Total Phosphorus
Total Phosphorus
Total Suspended Solids
Total Suspended Solids
Unit
mg/L
mg/L
mg/L
mg/L
mg/L
MPN/100 mL
MPN/100 mL
MPN/100 mL
MPN/100 mL
MPN/lOOmL
MPN/lOOmL
MPN/lOOmL
MPN/lOOmL
MPN/lOOmL
MPN/100 mL
MPN/100 mL
MPN/100 mL
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Original
Sample
22
300
2,200
340
300
180,000
110,000
1,000
1,000
5,100,000
ND(20,000)
ND(20,000)
ND(20,000)
3,000,000
9,000,000
ND(2,000)
4,000
0.15
0.24
0.25
0.12
32
82
62
70
9.7
28
11
9.3
250
2,200
Duplicate
Sample
22
240
2,900
460
400
130,000
100,000
ND(1,000)
ND(1,000)
2,700,000
ND(20,000)
20,000
40,000
2,400,000
3,000,000
ND(2,000)
ND(2,000)
0.15
0.24
0.19
0.15
46
140
63
50
10
37
12
9.4
260
2,700
Average
Concentration
22
270
2,600
400
350
160,000
110,000
< 1,000
<1,000
3,900,000
ND(20,000)
<20,000
<30,000
2,700,000
6,000,000
ND(2,000)
<3,000
0.15
0.24
0.22
0.14
39
110
62
60
10
32
12
9.4
260
2,400
Relative %
Difference
0.93%
23%
24%
30%
30%
29%
12%
NC
NC
62%
NC
NC
NC
22%
100%
NC
NC
0.00%
0.00%
27%
22%
35%
51%
2.9%
33%
2.0%
26%
6.8%
1.9%
3.9%
23%
                                                                6-8

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Performance Evaluation Report for Type I MSDs
                                          Table 6-2. Field Duplicate Analytical Results (Continued)
Sample
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Collection
Date
4/18/2007
4/19/2007
4/10/2007
4/11/2007
4/17/2007
4/19/2007
4/20/2007
Time
12:15 PM
3:52 PM
8:30 AM
8:30 AM
3:52 PM
12:15 PM
3:52 PM
Analysis
Total Suspended Solids
Total Suspended Solids
Visible Floating Solids
Visible Floating Solids
Visible Floating Solids
Visible Floating Solids
Visible Floating Solids
Unit
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
Original
Sample
360
280
100
0
2.0
1.0
0
Duplicate
Sample
360
340
100
0
13
8.0
0
Average
Concentration
360
310
100
0
7.5
4.5
0
Relative %
Difference
0.00%
19%
0.00%
0.00%
150%
160%
0.00%
October Retesting
Influent
10/15/2007
8:05 AM
TSS
mg/L
650
560
600
14.9
November/December Retesting
Influent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Thermopure-2 Effluent
Therompure-2 Effluent
Therompure-2 Effluent
11/29/2007
12/5/2007
12/5/2007
12/5/2007
12/5/2007
12/6/2007
12/6/2007
12/6/2007
12/6/2007
12/7/2007
8:00 AM
12: 15PM
12: 15PM
12: 15PM
8:30 AM
15:52 PM
15:52 PM
15:52 PM
8: 50 AM
2: 52PM
TSS
TSS
BOD5
Fecal coliform
Visible floating solids
TSS
BOD5
Fecal coliform
Visible floating solids
Visible floating solids
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
1,100
1,800
1,500
1,600
0
1,200
1,000
22,000
0
94
1,000
2,200
1,600
900
40
1100
910
22,000
82
39
1,100
2,000
1,600
1,300
20
1,200
970
22,000
41
67
9.52
20.0
6.45
56.0
200
8.70
9.42
0.00
200
82.7
ND - Not detected (number in parentheses is detection limit).
< - Average result includes at least one non-detect value (calculation uses detection limits for non-detected results).
                                                                       6-9

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Performance Evaluation Report for Type I MSDs
7.0    MANUFACTURER RESPONSE
       A draft performance evaluation report was provided to the two MSD technology
manufacturers on May 30, 2008. Sections 7.1 and 7.2 present the submissions received from
Raritan Engineering Company, Inc. and Gross Mechanical Laboratories, Inc., respectively,
together with a response to the manufacturer's comments. This final report incorporates
manufacturer comments as appropriate.

7.1    Raritan Engineering Company, Inc.
Raritan Submission
       It is our understanding that the purpose of this testing was to determine whether or not
standards that have remained unchanged since 1975 should be reviewed. It is Raritan's
contention that technology exists to treat waste to a much higher standard than the current 1975
standards reflect. The original law stated that standards would be reviewed every five years. Our
interpretation of this review was that it would help to encourage the use of continually improved
on-board treatment as a viable alternative for conscientious boaters.
       As it relates to the testing performed it must also be stated that there are substantial
differences in small recreational vessel waste streams as compared to larger commercial vessels
and high occupancy vessels such as cruise ships. 33 CFR Sec.159.121 Sewage Processing test
does indicate the difference in the two waste streams and it appears testing was done based on
section (d) not section (c). Section (c) describes the type of system the Electroscan is and all
previous testing had been done based on section (c). Based on the fact that the Electroscan was
tested as a unit that continually processes sewage the system was overloaded, Electroscan should
have been tested per Coast Guard specifications section (c) of 33 CFR 159.121. In light of that
fact the system performed flawlessly with respect to Fecal Coliform, Escherichia coli and
Enterococci. These three pathogen indicators were used because they are the most efficient
bacterial indicator of water quality. (Fecal streptococcus is a subgroup of fecal coliform used  to
differentiate human versus animal  sources of these microbiologicals.) Epidemiological studies
suggest a positive relationship between high concentrations of E. coli and enterococci in ambient
waters and incidents of gastrointestinal illnesses associated with  swimming. The results suggest
use of this on-board device is compatible with recreational waters.
                                           7-1

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Performance Evaluation Report for Type I MSDs
       The VFS test that was performed must be questioned based on the simple fact the system
was overloaded. Normal loading as indicated in the report is based on section (d) of 33 CFR
159.121 and the Electroscan should have been tested based on section (c) of 33 CFR 159.121.
Section (d) specified a minimum of 500 mg/L and the average was 2,500 mg/L. We do not agree
that the system does not meet current requirements as it was not tested based on requirements.
This also brings into question the results of TSS, VFS and BOD5 as all tend to be inter-related.
There are several days where the influent concentration is less than the effluent concentration
which is not possible. This is documented in Table 4-5 for BODs 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 BODs therefore we do not fully agree
with the statement on page 4-8 that "Consequently, it is likely that apparent BOD5 and TSS
removals are solely a phenomenon of the wastewater, sampling, and analytical variability and
not actual removal  by Type I devices." If we discard the erroneous data of table 4-5 where
effluent is higher than influent total BODs reduction is 58.9%.
       Raritan believes this testing is a step in the right direction for all users of recreational
vessels. The intention of the law in 1975 was quite clear - continual improvement. By changing
standards more  companies will see the benefit of providing treatment on-site rather than risk
illegal discharges.

Response to Raritan Submission
       The performance evaluations of Type I MSDs were conducted in accordance with the
Sewage Processing Test contained in the regulations at 33 CFR 159.121. One exception to the
USCG's  Sewage Processing Test requirements is that, for reasons of practicality, testing was
conducted using a feed of fresh domestic human sewage rather than human  sewage in a ratio of
four urinations to one defecation, as specified in Section (c). Furthermore, for this evaluation,
testing was not limited to fecal coliform bacteria and visible floating solids measured in the
treated effluent, but rather included a variety of analyses of both influent and effluent samples to
measure the effectiveness of each treatment device and to characterize influent and effluent
quality. In every other regard, the Raritan device was tested using the 33 CFR 159.121 protocols,
including Section (c). The Raritan device was not tested in accordance to Section (d), as this
device does not process or discharge sewage continuously, nor was the device modified in any
way to operate continuously.

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Performance Evaluation Report for Type I MSDs
       The dosing schedule was well within the average and peak capacity of the Raritan unit as
indicated in the unit documentation (see Appendix B of this report for the challenge wastewater
dosing schedule).  Specifically, peak flow was designated by Raritan as 1 gallon flush of
wastewater every  six minutes, and a 30-minute cool-down period after every four to five flushes.
Off-peak (average) process flow was based on an assumption of four passengers each using the
toilet five times in an eight-hour day with 1-gallon per flush. Raritan product specifications
indicate a unit capacity of 575 gallons per day, and a maximum total flush volume of 1.5 gallons
per flush; these compare to the test conditions of a total daily dose volume of 28 gallons and a
total flush volume of 1 gallon per flush.
       Anomalies between influent and effluent results were due to the non-homogeneity and
high variability of the influent feed and treated effluent (see Section 4.3). Such problems are
expected with raw, complex wastewater with high amounts of unmacerated solids.

7.2    Gross Mechanical Laboratories, Inc.
Gross Mechanical Laboratories (GROCO) Submission - 7/15/08
       This is in response to ERG's Performance Evaluation Report (draft) of Type I MSDs.
While we recognize the good intent of this evaluation, GROCO respectfully objects to the test
procedure employed for the re-test, and questions the results. Following are our objections in
several specific areas of concern:

       1.      The dosing system that was employed clearly overloaded Thermopure-2, forcing
             untreated sewage through the system and causing unacceptable fecal coliform
             bacteria counts in the effluent. As stated on page 5-1 paragraph-2, the retest
              dosing was conducted using the  same dosing schedule as in the April test. Page 5-
             4 indicates that Thermopure-2 overflowed, further supporting our claim that the
              dosing schedule  exceeded system capacity. In normal operation, audible and
             visual alarms alert the user that the holding tank is at (approximately) 75%
              capacity, but the automatic dosing procedure employed during the retest ignored
             the built-in warnings. Additionally, by forcing unprocessed sewage through the
              system, related symptoms such as low temperature measurements reported on
             Page 5-2 may have been caused. Such readings may be attributed to siphoning of
                                          7-3

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Performance Evaluation Report for Type I MSDs
              sewage past a clogged or sticking vacuum breaker (part of the plumbing system to
              and from the treatment block), and caused by the forced over-dosing.

       2.      Table 4-15 shows effluent samples contained a greater fecal coliform bacteria
              count than the influent. This is not possible.

       3.      Project 0214.00.020 appears to have been conducted in consideration of
              33CFR159.121 (d) as it pertains to large vessel systems. Type-I MSDs are
              intended for use aboard small vessels (smaller than 65-feet in length).
              Thermopure-2 includes a holding tank that effectively stores influent received at a
              rate that is in excess of treatment capacity, thereby avoiding system overload as
              experienced during the retest. In the "real world" of small vessel toilet systems, as
              little  as 1-quart of flush water is required per flush. Testing with peak capacity
              dosing is not appropriate.

       4.      Prior to sending a Thermopure-2 unit for retest in November, 2007 GROCO
              submitted effluent samples to an  independent lab for fecal coliform bacteria
              count. Using test method SM209221E, the results indicated consistently <2 MPN.
              On July 8, 2008 we submitted additional samples to the same lab and received
              similarly consistent satisfactory results.

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

Additional Gross Mechanical Laboratories Submission - 8/14/08
       Following are answers to questions from your August 13 e-mail:

       1.      The heater block used in GROCO's in-house tests is identical to the heater block
              submitted to ERG. This is a production item for us; one which we have
              manufactured for years without change. The effluent flow volume in our test is
              also identical to that of the unit you received for the re-test. Thermopure-2 control
              software limits pump  run time so as not to exceed the volume of the heater block.
              The resulting effluent measures approximately 500 ml.

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Performance Evaluation Report for Type I MSDs
       2.      Attached are copies of results from Chesapeake Labs, Inc. The report from
              November 14, 2007 was the result of effluent sampling following our software
              correction, prior to the re-test. The report from July 8, 2008 tests samples from the
              same GROCO test unit from which the November 2007 samples were produced.
              These were tested after receiving your re-test test report indicating that we were
              not eliminating fecal coliform bacteria.

       3.      Unit testing and sampling was conducted in-house. GROCO has a fully
              operational unit which has been in operation for approximately  10-years. The test
              unit receives "live" raw sewage from a marine toilet used by me, not diluted or
              otherwise controlled test influent. There is no question that the influent used
              contains ample fecal coliform bacteria. The test unit is not tilted, and our test
              procedure is  simply that the system is used "normally" as follows:
              a.     the toilet is used and flushed
              b.     the Thermopure-2 unit holding tank receives the influent
              c.     the level sensor recognizes increased holding tank level  and turns on the
                    heater
              d.     when the appropriate level of heat has been achieved, waste is processed
                    and discharged
              e.     all samples were collected by me personally, as received directly from the
                    discharge hose from the treatment block. Samples were captured into
                    sterile sample bottles furnished by Chesapeake Labs. Immediately after
                    catching each sample, the bottles were capped, placed into a cooler with
                    ice, and delivered within 1-hour to Chesapeake Labs, for testing in
                    compliance with Fecal Coliform Method SM209221E.

       Our test unit does not consider average flow or peak flow; "real world" rates of usage are
employed, and the rate of processing effluent does not change with the rate of influent. The
holding tank portion of Thermopure-2 is fully capable of handling additional influent volume as
might be imposed during peak flow conditions.
       If additional information is required please contact  me.

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Performance Evaluation Report for Type I MSDs
Response to GROCO Submissions
       The dosing schedule is well within the average and peak capacity of the Thermopure-2
unit as indicated in the unit documentation (see Appendix B of this report for the challenge
wastewater dosing schedule). Specifically, peak flow was as designated by the manufacturer as
50 gallons per eight-hour day or about 1 gallon every 10 minutes, based on  an assumed challenge
wastewater temperature of 68°F (20°C). Off-peak (average) process flow was based on an
assumption of four passengers each using the toilet five times in an eight-hour day. This resulted
in an off-peak flow of 20 gallons in an eight-hour day or 1 gallon of wastewater every 24
minutes. Thermopure-2 product specifications indicate a maximum treatment capacity ranging
from 40 gallons per day (65°F flush water) to 60 gallons per eight-hour day (80°F flush water);
there is no specified total flush volume. These compare to the test conditions of a total daily dose
volume of 32 gallons and a total flush volume of 1 gallon per flush. Flush water temperature was
68°F (20°C) during April 2007 testing,  and 72°F (22°C) during November/December 2007
testing.
       The Thermopure-2 holding tank overflowed briefly during one combined "tilt"
event/peak flow dose. Neither the dosing schedule, nor the dosed volumes administered,
exceeded the treatment capacity of the unit as specified by unit documentation.
       The design of the Thermopure-2 unit and placement of components, piping, and
connections make it extremely unlikely that wastewater could be forced or siphoned through the
system. First, movement of untreated wastewater out of the holding tank into the treatment block
occurs only when the macerator pump located inside the holding tank operates to transfer fluid to
the treatment block. Therefore, while the dosing system moves wastewater into the holding tank,
it does not move or "force" wastewater through the remainder of the system. Gross Mechanical
Laboratories, Inc. confirms this in their August 14 response: "the rate of processing effluent does
not change with the rate of influent. The holding tank portion of Thermopure-2 is fully capable
of handling additional influent volume as might be imposed during peak flow conditions."
Second, the treatment system design incorporates discharge vented loops, which are essentially
atmospheric vacuum breakers that function to prevent siphoning of fluids. These vented loops
were installed in accordance with the configuration indicated in the manufacturer's literature. A
Gross Mechanical Laboratories, Inc. representative visited the test facility and verified proper
device installation (see Section 4.1.1). Third, as experienced during day eight of the original test,
a malfunction caused the vacuum breaker to leak when under pump pressure and did not allow

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Performance Evaluation Report for Type I MSDs
siphoning. Fourth, the sample technician monitored all unit discharges during testing, and no
siphoning or other inappropriate discharges were observed.
       Anomalies between influent and effluent results were due to the non-homogeneity and
high variability of the influent feed and treated effluent (see Section 4.3). Such problems are
expected with raw, complex wastewater with high amounts of unmacerated solids.
       The performance evaluations of Type I MSDs were conducted in accordance with the
Sewage Processing Test contained in the regulations at 33 CFR 159.121. One exception to the
USCG's Sewage Processing Test requirements is that, for reasons of practicality, testing was
conducted using a feed of fresh domestic human sewage rather than human sewage in a ratio of
four urinations to one defecation, as specified in Section (c). Furthermore, for this evaluation,
testing was not limited to fecal coliform bacteria and visible floating solids measured in the
treated effluent, but rather included a variety of analyses of both influent and effluent samples to
measure the effectiveness of each treatment device and to characterize influent and effluent
quality. Specific to the retesting, testing that was not at least 10  days within a 20-day period. In
every other regard, the Raritan device was tested using the 33 CFR 159.121 protocols, including
Section (c). The Raritan device was not tested in accordance to  Section (d), as this device does
not process or discharge sewage continuously, nor was the device modified in any way to operate
continuously.
       The Sewage Processing Test contained in the regulations at 33 CFR 159.121  specifies
that systems must process sewage at peak capacity during three periods of each day of testing.
Although the cause of the unit not performing to the specified manufacturer's standard  is
unknown, the cause may be a discrepancy between the unit's design pump-out flow, versus
actual pump-out flow. In their August 14 submission, Gross Mechanical Laboratories, Inc, states
that the "Thermopure-2 control software limits pump run time so as not to exceed the volume of
the heater block" and that "the resulting effluent measures approximately 500 ml." Actual pump-
out volumes measured by test facility personnel using a graduated cylinder were a constant 1,000
mL to 1,200 mL over the two-second pump-out period. An actual  pump-out volume of more than
twice the design rate  suggests that unheated (untreated) wastewater may have been pumped out
along with treated wastewater, which could account for the unit not performing to specified
manufacturer's standard.
                                          7-7

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Performance Evaluation Report for Type I MSDs
                                      Appendix A




                                 33 CFR 159 Excerpts

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Performance Evaluation Report for Type I MSDs
33 CFR § 159.53  General requirements.

A device must:

(a) Under the test conditions described in §§159.123 and 159.125, produce an effluent having a
fecal coliform bacteria count not greater than 1,000 per 100 milliliters and no visible floating
solids (Type I),

(b) Under the test conditions described in §§159.126 and 159.126a, produce an effluent having a
fecal coliform bacteria count not greater than 200 per 100 milliliters and suspended solids not
greater than 150 milligrams per liter (Type II), or

(c) Be designed to prevent the overboard discharge of treated or untreated sewage or any waste
derived from sewage (Type III).

33 CFR § 159.121  Sewage processing test.

(a) The device must process human sewage in the manner for which it is designed when tested in
accordance with this section. There must be no sewage or sewage-treating chemicals remaining
on surfaces or in crevices that could come in contact with a person using the device or servicing
the device in accordance with  the instructions supplied under §159.57(b)(7).

(b) During the test the device must be operated and maintained in accordance with the
manufacturer's instructions. Any initial start-up time specified by the manufacturer must be
allowed before test periods begin. For 1 hour of each 8-hour test period, the device must be tilted
to the maximum angles specified by the manufacturer under §§159.55 and 159.57.

(c) Except for devices described in paragraph (d) of this section, the devices must process and
discharge or store human sewage over at least an 8-consecutive hour period on at least 10 days
within a 20-day period. The device must receive human sewage consisting of fecal matter, urine,
and toilet paper in a ratio of four urinations to one defecation with at least one defecation per
person per day.  Devices must be tested at their average rate of capacity as specified in §159.57.
In addition, during three periods of each day the system must process sewage at the peak
capacity for the period of time it is rated at peak capacity.

(d) A device that processes and discharges continuously between individual use periods or a
large device, as determined by the Coast Guard, must process and discharge sewage over at least
10-consecutive  days at the average daily capacity specified by the manufacturer.  During three
periods of each  day the system must process sewage at the peak capacity  for the period of time it
is rated at peak  capacity. The sewage for this test must be fresh, domestic sewage to which
primary sludge  has been added, as necessary, to create a test sewage with a minimum of 500
milligrams of suspended solids per liter.
                                          A-l

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Performance Evaluation Report for Type I MSDs
33 CFR § 159.123 Coliform test: Type I devices.

(a) The arithmetic mean of the fecal coliform bacteria in 38 of 40 samples of effluent discharged
from a Type I device during the test described in §159.121 must be less than 1000 per 100
milliliters when tested in accordance with 40 CFR Part 136.

(b) The 40 samples must be taken from the device as follows: During each of the 10-test days,
one sample must be taken at the beginning, middle, and end of an 8-consecutive hour period with
one additional sample taken immediately following the peak capacity processing period.

33 CFR § 159.125 Visible floating solids: Type I devices.

During the sewage processing test (§159.121) 40 effluent  samples of approximately  1 liter each
shall be taken from a Type I device at the same time as samples taken in §159.123 and passed
expeditiously through a U.S. Sieve No. 12 as specified in ASTM Ell  (incorporated by
reference, see §159.4). The weight of the material retained on the screen after it has been dried to
a constant weight in an oven at 103 °C must  be divided by the volume of the sample and
expressed as milligrams per liter. This value  must be 10 percent or less of the total suspended
solids as determined in accordance with 40 CFR Part 136  or at least 38 of the 40 samples.

Note: 33 U.S.C. 1321(b)(3) prohibits discharge of harmful quantities of oil into or upon the
navigable waters of the United  States or adjoining shorelines or into or upon the waters of the
contiguous zone. Under 40 CFR 110.3 and 110.4 such discharges of oil include discharges
which:

(a) Violate applicable water quality standards, or

(b) Cause a film or sheen upon  or discoloration of the surface of the water or adjoining
shorelines or cause a sludge or  emulsion to be deposited beneath the surface of the water or upon
adjoining shorelines.  If a sample contains a quantity of oil determined to be harmful, the Coast
Guard will not certify the device.
                                          A-2

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Performance Evaluation Report for Type I MSDs
                                  Appendix B




               CHALLENGE WASTEWATER DOSING SCHEDULE

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Performance Evaluation Report for Type I MSDs
                            NSF International Waco Test Facility
                          Marine Sanitation Device Evaluation 2007
            Dosing and Sample Schedule for Test Device #1 - The Electro Scan Device
Dose#

1
2
3
4
5


6
7
8
9
10
11
12
13


14
15
16
17

18
19
20
21
22
23

Time
07:45
08:00
08:06
08:12
08:18
08:24
08:30
08:30-09:00
09:00
09:24
09:48
10:12
10:18
10:24
10:30
10:36
10:42
10:42-11:12
11:12
11:36
12.00
12.15
12:30
12:48
13:12
13:18
13:24
13:30
13:36
13:42
Description
Challenge
wastewater batch
Peak Flow Dose



T



r
End of processing
08:24 dose
30-min. Cool Down
Off-Peak Dose (1
HR)

i

r
Peak Flow Dose



i



r
End of processing
10:36 dose
30-min. Cool Down
Off-Peak Dose (2
HRs)




i




r
Peak Flow Dose



i



r
End of processing
Tilt3







Tl-mw-1
T2-tw-l
T3-ww-l







T4-thw-l
Tl-mw-2
T2-tw-2









T3-ww-2
Sample b

#l-Infl.

#ES-1 (beginning)

#ES-2pm; #ES-2pth









#ES-2ptu





#ES-3m (mid-day Mon.
/Tues. /Thurs.);
ES-2m (Wed/Fri.)
Lab Pickup





#ES-3pw; #ES-3pf

Peak
Flow
Dose#

1
2
o
3
4
5





6
7
8
9
10








11
12
13
14
15

Off-
Peak
Dose#








1
2
3







4
5
6
7

8






                                            B-l

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Performance Evaluation Report for Type I MSDs
                                NSF International Waco Test Facility
                             Marine Sanitation Device Evaluation 2007
             Dosing and Sample Schedule for Test Device #1 - The Electro Scan Device
Dose#


24
25
26
27
28


Dose
Volumes
TTL
Dose
Volume
Time

13:42-14:12
14:12
14:36
15:00
15:24
15:48
15:54
16:30


Description
13:26 dose
30-min. Cool Down
Off-Peak Dose (2
HRs)




End of j
15:4

T


recessing
3 dose

r

Tilt3

T4-thw-2


T5-fw-l
T5-fw-2






Sample b






#ES-4e(endofday)

Lab Pickup


TTL Influent Sample Volume
TTL Effluent Sample Volume
Peak
Flow
Dose#









15
Gallons
Off-
Peak
Dose#


9
10
11
12
13


13
Gallons
28 Gallons
6 Liters
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#l =
Device tilted 30° to the left of vertical axis as viewed from the inlet end elevation (to the 10:00 o'clock position); #2
= 30° to right of vertical axis as viewed from the inlet end elevation (to the 2:00 o'clock position); #3 = Device tilted
30° to the left of vertical axis as viewed from the inlet side elevation (to the 10:00 o'clock position); #4 = Device
tilted 30° to the right of vertical axis as viewed from the inlet side elevation (to the 2:00 o'clock position). Tl-mw-1
= Tilt #1, Mon. /week #1, Tl-mw-2 = Tilt #1, Mon. /week #2, etc.
b Sample # & Description: #1 = Influent prior to dosing; #ES-1 = Effluent at beginning of dosing; #ES-2pm = Effl.
following peak dosing on Monday; #ES-2pth = Effl. following peak dosing on Thurs.; #ES-2ptu = Effluent
following peak dosing on Tues.; ES-3m = Effl. at mid-day on Mon/Tues/Thurs; ES-2m = Effl. at mid-day on
Wed/Fri; #2e = Effluent at end of dosing; #ES-3pw = Effl. following peak dosing on Wed.; #ES-3pf = Effl.
following peak dosing on Fri.
                                                 B-2

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Performance Evaluation Report for Type I MSDs
                            NSF International Waco Test Facility
                          Marine Sanitation Device Evaluation 2007
            Dosing and Sample Schedule for Test Device #2 - The Thermopure Device
Dose#

1
2
3
4
5
6

7
8
9
10
11
12
13
14
15
16
17

18
19

20
21
22
23
24
25
26
27
28
29

Time
07:45
08:00
08:10
08:20
08:30
08:40
08:50
08:56
08:56
09:20
09:44
10:08
10:32
10:56
11:06
11:16
11:26
11:36
11:46

11:52
12:16
12:30
12:40
13:04
13:28
13:52
14.02
14.12
14:22
14:32
14:42
14:52

Description
Challenge Wastewater Batch
Peak Flow Dose (1 HR)




^




r
End of processing 08:50 dose
Off-Peak Dose (2 HR)



i



r
Peak Flow Dose (1 HR)




i




r
End of processing 1 1 :46 dose
Off-Peak Dose (2 HR)




i




r
Peak Flow Dose (1 HR)





^





r
End of processing 14:52 dose
Tilt3






Tl-mw-1

T2-tw-l
T3-ww-l









T4-thw-l
Tl-mw-2
T2-tw-2




T3-ww-2
T4-thw-2






Sample b
#llnfl



#TP-1 (beginning)

#TP-2pm; #TP-2pth











#TP-2ptu


#TP-3m (mid-day
Mon/Tues/Thurs) ;
#TP-2m Wed/Fri
Lab Pickup









#TP-3pw; #TP-3pf

Peak
Flow
Dose#

1
2
3
4
5
6






7
8
9
10
11
12







13
14
15
16
17
18
19

Off-Peak
Dose#








1
2
o
5
4
5







6
7

8
9
10








                                           B-3

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Performance Evaluation Report for Type I MSDs
                                NSF International Waco Test Facility
                             Marine Sanitation Device Evaluation 2007
             Dosing and Sample Schedule for Test Device #2 - The Thermopure Device
Dose#
30

31
32






Dose
Volumes
by Flow
Time
14:58
15:00
15:22
15:46
15:52
16:30





Description
Off-Peak Dose (1 HR)



End of proc^



1
ssing 15:46 dose






Tilt3

T5-fw-l
T5 fw-2









Sample b




#TP-4e(endofday)
Lab Pickup





TTL Dose Volume
TTL Influent Sample Volume
TTL Effluent Sample Volume
Peak
Flow
Dose#










19
Gallons
Off-Peak
Dose#
11

12
13






13
Gallons
32 Gallons
6 Liters
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#l =
Device tilted 30° to the left of vertical axis as viewed from the inlet end elevation (to the 10:00 o'clock position); #2
= 30° to right of vertical axis as viewed from the inlet end elevation (to the 2:00 o'clock position); #3 = Device tilted
30° to the left of vertical axis as viewed from the inlet side elevation (to the 10:00 o'clock position); #4 = Device
tilted 30° to the right of vertical axis as viewed from the inlet side elevation (to the 2:00 o'clock position). Tl-mw-1
= Tilt #1, MonVweek #1, Tl-mw-2 = Tilt #1, Mon./week #2, etc.
b Sample # & Description: #1 = Influent prior to dosing; #TP-1 = Effluent at beginning of dosing; #TP-2pm = Effl.
following peak dosing on Monday; #TP-2pth = Effl. following peak dosing on Thurs.; #TP-2ptu = Effluent
following peak dosing on Tues.; TP-3m = Effl. at mid-day  on Mon/Tues/Thurs; #TP-2m = Effl. mid-day on
Wed/Fri; #TP-4e = Effluent at end of dosing; #TP-3pw = Effl. following peak dosing on Wed.; #TP-3pf = Effl.
following peak dosing on Fri.
                                                 B-4

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Performance Evaluation Report for Type I MSDs
                                  Appendix C




                  AUDIT REPORT FOR TYPE I MSB TESTING

-------
Performance Evaluation Report for Type I MSDs
MEMORANDUM

TO:         Ray Frederick, EPA

FROM:      Kathleen Wu, ERG

DATE:      May 10, 2007

SUBJECT:  Audit Report for Type I MSB Testing
INTRODUCTION

       ERG, in support of EPA's STREAMS Program Task Order #20, is evaluating the
effectiveness of Type I MSDs. The two devices identified are Gross Mechanical Laboratories'
Thermopure-2 device and Raritan Engineering Company's Electro Scan device. ERG prepared a
Work Plan and a Quality Assurance Project Plan to evaluate these devices and subcontracted the
setup and testing phase of the project to NSF International.

       AUDIT

       Kathleen Wu, ERG Scientist, conducted an audit of NSF International's test facility to
evaluate compliance with procedures, testing protocols, and  analyses outlined in the Evaluation
of Type I Marine Sanitation Devices (MSDs) Work Plan dated March 20, 2007 and the
Evaluation of Type I Marine Sanitation Devices (MSDs) Quality Assurance Project Plan (QAPP)
dated March 20, 2007. The audit was conducted at the Waco Metropolitan Area Regional
Sewage System (WMARSS) Treatment Facility in Waco, Texas and at Aqua-Tech Laboratories,
Inc. in Bryan, Texas. The first two days of the audit, April 9, 2007 to April 10, 2007, were spent
at the test facility,  while the last day, April 11, 2007, was spent in the lab.
Date
4/09/2007
4/10/2007
4/11/2007
Location
WMARSS
Waco, Texas
WMARSS
Waco, Texas
Aqua-Tech
Laboratories Bryan,
Texas
Sample Description
Influent, peak, and off peak samples
from Electro Scan and Thermopure-
2 devices
Influent, peak, and off peak samples
from Electro Scan and Thermopure-
2 devices
Microbiological and TSS samples
from Electro Scan and Thermopure-
2 devices
Sampling/Laboratory Personnel
David Jumper, NSF
Dustin Fatten, NSF
Jim Patten, NSF
David Jumper, NSF
Dustin Patten, NSF
Jim Patten, NSF
June Brien, Aqua-Tech
John Brien, Aqua-Tech
       During the audit, Ms. Wu observed two days of performance testing and sample
collection. This included preparation of the challenge wastewater, device start-up procedures,
operation of both devices at peak and off peak dosing cycle, handling of samples, and record
keeping for both the Electro Scan and Thermopure-2 device by NSF International. She verified
device operations, waste dosing, sample collection, field tests, field test documentation,
instrument calibrations, daily tilting of devices, sample preservation, and transportation of the
                                          (M

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Performance Evaluation Report for Type I MSDs
Memorandum
10 May 2007
Page 2

samples to the laboratory. She was also present during the mechanical malfunction,
troubleshooting, and eventual repair of the Thermopure-2 device on the second day of the audit.

       The Audit evaluated the following elements:

    •   Overall level of organization, professionalism, and understanding of the project;

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

    •   Set-up and preparation of challenge wastewater from the influent tank through the dosing
       system prior to testing;

    •   Compliance and understanding of all activities and goals described in the Work Plan;

    •   Compliance with all procedures outlined in the QAPP;

    •   Documentation of samples, analysis activity, and observations;

    •   Condition of field test equipment and materials;

    •   Appropriate transport of the samples to the laboratory; and

    •   Overall satisfaction with environment and procedures of the laboratory.

       AUDIT RESULTS

       Ms. Wu recorded her observations on the Type IMSD Testing Audit Checklists provided
in Attachment 1.

       The site manager prepared appropriate challenge wastewater that was fed to the devices
using an automated the dosing system following testing procedure guidelines. Facility personnel
operated each device at start-up, during peak and off peak flows, and at the end of the testing day
per manufacturer instructions and requirements of the Work Plan. Moreover, sample collection,
field tests, sample handling, and paperwork requirements were administered according to the
Work Plan and QAPP.

       Samples were transported to Aqua-Tech Laboratories, where Ms. Wu spent her third day
of the audit observing lab procedures, documentation, and reporting, and reviewing preliminary
TSS andE. coli results. She reviewed the lab's documentation process and obtained the most
recent audit report conducted by the state of Texas. Review of Aqua-Tech's audit revealed three
positive findings  and two negative findings in their quality assurance program. Negative findings
were resolved with corrective actions.
                                          C-2

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Performance Evaluation Report for Type I MSDs
Memorandum
10 May 2007
Page3

       Ms. Wu observed the following minor issues and their resolutions (if applicable) during
the audit, none of which should have any impact on the analytical results or quality of the data
obtained from this Type IMSD test program.

   •   On the first day of testing, the Thermopure-2 device required more time than predicted to
       reach warm-up temperature at the beginning of the day and the target treatment
       temperature for each treatment cycle. The ambient temperature in Waco, Texas was cold
       (approximately 39°F). However, neither the dosing nor sampling schedule was delayed as
       the treatment system design includes a holding tank that stores influent wastewater in
       queue for the treatment chamber. There was more than enough effluent flow from the
       device to allow sampling to proceed as scheduled. Additionally, as testing progressed and
       continued on subsequent days, this issue was observed less and less as ambient
       temperatures increased.

   •   Each treatment device had its own designated sampling equipment to minimize cross
       contamination between samples. This equipment included the field test container,
       sampling container, Alconox solution, effluent sampling tap, and all container lids, which
       were originally labeled with its designated treatment device. As sampling progressed,
       these labels were being constantly rinsed with Alconox solution and deionized water and
       began to peel off. The samplers reprinted all the labels and covered them with clear
       plastic tape to maintain their integrity.

   •   Field test data sheets and total chlorine residual data sheets were originally formatted in a
       way that did not facilitate data collection over multiple days. New data sheets were
       designed to correct this error. Previously collected data were transferred to new sheets.

   •   At around noon on the second day of performance testing, the Thermopure-2 device's
       75% capacity warning light came on. Troubleshooting identified the problem  as
       mechanical failure of the pump to the treatment chamber and a blown fuse. NSF
       personnel replaced both and resumed treatment within 40 minutes. In all, 3 one-gallon
       doses during the peak flow of the Thermopure-2 device were missed. No partially treated
       or untreated wastewater passed through the device, and sampling times were not  affected.
                                          C-3

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Performance Evaluation Report for Type I MSDs
                                  Attachment 1




   AUDIT CHECKLISTS FOR THERMOPURE-2 AND ELECTRO SCAN DEVICES
                                      C-4

-------
Performance Evaluation Report for Type I MSDs
                            Type I MSB Testing Audit Checklist
MSD Names  Thermopure-2, Groco
Auditor Kathleen Wu, ERG
Date(s) of Audit  April 9th and 10th, 2007
Samplers David Jumper, Dustin Patton, & Jim H. Patton Ph.D., NSF
Testing Procedures
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.
Are MSDs started and operated as described in the devices' operating manuals?
Correct voltages were used as monitored by a voltmeter.
The device was started by first preparing the challenge wastewater and
recirculation loop and then connecting battery power to the dosing and treatment
devices.
Are MSD maintenance instructions conducted according to the devices' operating
manuals?
No short term maintenance operations are required by the device.
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.
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.
Yes
X
X
X
X
X
No
"
"
"
"
"
                                       C-5

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Performance Evaluation Report for Type I MSDs
           Type I MSD Testing Audit Checklist for Thermopure-2 (Continued)
Testing Procedures
Are the devices dosed for a minimum of 8 hours each day? Is the dosing pattern based
on the design hydraulic capacity of the devices with three periods each day when
devices are dosed at their peak capacities?
The dosing system is designed to dose for 8 hours each day. On the second day of
testing, the pump on the Thermopure-2 device that draws wastewater from the
holding tank to the treatment chamber experienced a mechanical failure. The
dosing system was shut down for about 45 minutes during its peak flow to prevent
the device from overflowing. Although all samples were collected as scheduled,
three one-gallon doses were missed.
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°.
Are the devices periodically tilted during testing?
Are any operational problems and maintenance provided recorded in a field log book?
All operational problems were summarized and recorded site personnel.
Yes
"
X
X
X
No
X
"
D
D
                                        C-6

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Performance Evaluation Report for Type I MSDs
           Type I MSD Testing Audit Checklist for Thermopure-2 (Continued)
Sampling Procedure
Are the challenge wastewater samples collected immediately prior to dosing the
device? If more than one challenge wastewater batch is dosed in one day, are the batch
samples appropriately composited, mixed, and transferred to appropriate sample
containers?
Only one challenge wastewater batch was prepared each day and dosed to both
devices, so there was no need to composite or mix influent samples.
Are the effluent samples collected with a clean pitcher that is thoroughly
decontaminated using Alconox solution and rinsing with deionized/distilled water after
each use?
The device had two dedicated effluent containers, which were used to transport
samples to the lab to be poured into sample bottles.
Are flow rates monitored and accurate for the collection type?
The automatic dosing system is programmed to switch between peak and off peak
as specific times. The system can be programmed to the minute.
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)?
Are the effluent samples taken at the appropriate time intervals (i.e., beginning, middle,
and end of daily dosing period with one additional during peak dosing period)?
Are the sample containers used to collect the samples appropriately labeled?
Sample labels listed the following information: NSF, device name, sample
number, analyte, volume, date, time, and name of sampler.
Are sample collection containers and volumes appropriate for planned analysis per
Table 2 of the work plan?
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.
Yes
X
X
X
n
X
X
X
X
X
No
"
"
"
°
D
n
"
D
"
                                        C-7

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Performance Evaluation Report for Type I MSDs
           Type I MSD Testing Audit Checklist for Thermopure-2 (Continued)
Sampling Procedure
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.
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.)?
Are all collected samples preserved according to Table 2 of the work plan?
Aqua-Tech pre-preserved the sample containers per Table 2.
Is residual chlorine tested promptly following sample collection?
Not applicable for Thermopure-2, which does not use chlorine.
Is a container, separate from the sample container, used to collect sample for
conducting pH, temperature, and salinity (Electro Scan device only) field tests on each
sample aliquot?
The device had a dedicated field test container that was cleaned with Alconox and
deionized water after each use.
A probe was used to measure temperature, pH, conductivity (even though it was
not required for the Thermopure-2 Device), and dissolved oxygen for each
sample.
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.
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.
Is the field test container appropriately stored between sample aliquots?
Are the correct QC samples and duplicate samples collected?
Yes
X
X
X
n
X
X
X
X
X
No
"
D
D
D
"
"
D
n
D

-------
Performance Evaluation Report for Type I MSDs
           Type I MSD Testing Audit Checklist for Thermopure-2 (Continued)
Sampling Procedure
Are all equipment blanks and field duplicates prepared, collected, and stored
appropriately after sampling?
Field duplicates were stored with regular samples and treated as such. Equipment
blanks were taken the week before sampling and already processed by the lab.
Are the processes and sample information, such as flow rates (peak and off peak) and
field measurements and sample collection times recorded appropriately in a field log
book?
These were all programmed into the dosing system. A print out of the detailed
schedule was provided, listing dosing times, times for peak/off peak flows, sample
collection time, tilting times, etc
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.
Yes
X
X
X
No
"
"
"
                                        C-9

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Performance Evaluation Report for Type I MSDs
                           Type I MSB Testing Audit Checklist
MSD Names  Electro Scan, Raritan
Auditor Kathleen Wu, ERG
Date(s) of Audit April 9th and 10th 2007
Samplers David Jumper, Dustin Patton, & Jim H. Patton Ph.D., NSF
                             Testing Procedures
Yes
No
 Is the MSD setup performed in accordance with manufacturer instructions to simulate,
 as close as possible, installation onboard a vessel?

 The device was bolted and strapped down to elevated wood boards that had the
 influent tank on the highest board and with each progressive step of the treatment
 system at a lower elevation.

 Flexible hosing used to allow for tilting. On a vessel the piping would  likely be
 rigid.
X
 Are MSDs started and operated as described in the devices' operating manuals?

 Correct voltages were used as monitored by a voltmeter.

 The device was started by first preparing the challenge wastewater and
 recirculation loop and then connecting battery power to the dosing and treatment
 devices.

 The salt water feed system was installed as described in the manual. The salt used
 was 98% pure water softening tablets.
X
 Are MSD maintenance instructions conducted according to the devices' operating
 manuals?

 No short term maintenance operations are required by the device.
X
 Are challenge wastewater batches prepared with a minimum concentration of 500
 mg/L TSS?

 Preliminary TSS results for the influent on the first day of sampling were
 approximately 4,000 mg/L.
X
                                           C-10

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Performance Evaluation Report for Type I MSDs
            Type I MSD Testing Audit Checklist for Electroscan (Continued)
Testing Procedures
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.
Are the devices dosed for a minimum of 8 hours each day? Is the dosing pattern based
on the design hydraulic capacity of the devices with three periods each day when
devices are dosed at their peak capacities?
The dosing system is designed to dose for 8 hours each day.
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°.
Are the devices periodically tilted during testing?
Are any operational problems and maintenance provided recorded in a field log book?
All operational problems were summarized and recorded by samplers.
Yes
X
X
X
X
X
No
"
"
"
D
"
                                         C-ll

-------
Performance Evaluation Report for Type I MSDs
            Type I MSD Testing Audit Checklist for Electroscan (Continued)
Sampling Procedure
Are the challenge wastewater samples collected immediately prior to dosing the
device? If more than one challenge wastewater batch is dosed in one day, are the batch
samples appropriately composited, mixed, and transferred to appropriate sample
containers?
Only one challenge wastewater batch is prepared each day in one influent holding
tank and dosed to both devices automatically, so there was no need to composite
or mix influent samples.
Are the effluent samples collected with a clean pitcher that is thoroughly
decontaminated using Alconox solution and rinsing with deionized/distilled water after
each use?
The device had two dedicated effluent containers, which were used to transport
samples to the lab to be poured into sample bottles.
Are flow rates monitored and accurate for the collection type?
The automatic dosing system is programmed to switch between peak and off peak
as specific times. The system can be programmed to the minute.
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.
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)?
Are the effluent samples taken at the appropriate time intervals (i.e., beginning, middle,
and end of daily dosing period with one additional during peak dosing period)?
Are the sample containers used to collect the samples appropriately labeled?
Sample labels listed the following information: NSF, device name, sample
number, analyte, volume, date, time, and name of sampler.
Are sample collection containers and volumes appropriate for planned analysis per
Table 2 of the work plan?
Yes
X
X
X
X
X
X
X
X
No
"
"
"
"
D
D
"
D
                                         C-12

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Performance Evaluation Report for Type I MSDs
            Type I MSD Testing Audit Checklist for Electroscan (Continued)
Sampling Procedure
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.
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.
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.)?
Are all collected samples preserved according to Table 2 of the work plan?
Aqua-Tech pre-preserved the sample containers per Table 2.
Is residual chlorine tested promptly following sample collection?
Is a container, separate from the sample container, used to collect sample for
conducting pH, temperature, and salinity (Electro Scan device only) field tests on each
sample aliquot?
The device had a dedicated field test container that was cleaned with Alconox and
deionized water after each use.
A probe was used to measured temperature, pH, conductivity, and dissolved
oxygen for each sample.
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.
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.
Is the field test container appropriately stored between sample aliquots?
Yes
X
X
X
X
X
X
X
X
X
No
"
"
a
a
n
"
"
n
D
                                         C-13

-------
Performance Evaluation Report for Type I MSDs
            Type I MSD Testing Audit Checklist for Electroscan (Continued)
Sampling Procedure
Are the correct QC samples and duplicate samples collected?
Are all equipment blanks and field duplicates prepared, collected, and stored
appropriately after sampling?
Field duplicates were stored with regular samples and treated as such. Equipment
blanks were taken the week before testing and already processed by the lab.
Are the processes and sample information, such as flow rates (peak and off peak) and
field measurements and sample collection times recorded appropriately in a field log
book?
These were all programmed into the dosing system. A printout of a detailed
schedule was provided, listing dosing times, times for peak/off peak flows, sample
collection time, tilting times, etc
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.
Yes
X
X
X
X
No
D
"
"
"
                                         C-14

-------