End No Discharge Zones and require Type 1 Sanitation Devices - Why not?

[WindLove]

I am thinking of buying a Marine Sanitation Device type 1 (probably an Electra Scan), but the decision is complicated. Here is the EPA explanation for those unfamiliar with MSD types.

It bothers me that these political people think they are being environmentally friendly when they vote to expand the No Discharge Zones. As it is now vessels are prohibited from discharging any sewage, whether treated by an MSD or not, into an area designated as a No Discharge Zone, and there are lots of big areas that are NDZ designated.

It's a misguided law. The water would be cleaner if instead we required every boat owner to have a Type 1 Marine Sanitation Device.

These devices are expensive now because the market is so limited. Most people and boat builders don't bother because there are so many NDZs. If the No Discharge Zones were eliminated and Type 1 devices were required for boats with toilets (other than compost and porta potties), the cost of Type 1's would drastically fall. Al they do is combine salt water and electricity to convert the salt water into a bactericide.

[ThereAndBack]

If you haven't noticed... Policy is run by emotion rather than logic lately.

Good luck.

[goat]

Originally Posted by WindLove

It's a misguided law. The water would be cleaner if instead we required every boat owner to have a Type 1 Marine Sanitation Device.

These devices are expensive now because the market is so limited. Most people and boat builders don't bother because there are so many NDZs. If the No Discharge Zones were eliminated and Type 1 devices were required for boats with toilets (other than compost and porta potties), the cost of Type 1's would drastically fall. Al they do is combine salt water and electricity

Yikes! Forcing boaters to buy and install electric toilets hoping that would make them cheaper?

No offense, but you certainly don't have my vote.

It's not that hard to sail 3 miles offshore to pump out.

Most of the older boats' owners I've met with electroscan units are using a bucket due to breakdowns.

You're using a sledgehammer to drive a thumbtack.

goat (I have a composting toilet)

[billknny]

To understand the logic behind a "NDZ" you have to understand that there are two separate issues with discharging waste. First, is the possible presence of pathogens that can make others who come in contact with the water ill. Pathogens can also make any filter feeding shellfish in the area dangerous to eat. Pathogens can include Hepatitis, Listeria, Norovirus, and lots of others.

Destroying pathogens is what a Type I MSD does. Essentially by chlorinating the waste to, hopefully, kill any pathogenic bacteria or viruses that might be present. You have made the waste essentially non-toxic to people, but not necessarily to the environment.

What most people don't understand, is that Type I treatment really doesn't change the polluting nature of the discharge. Essentially all of the "Biological Oxygen Demand" (BOD) is still present. In other words, your poop is still poop, even though it is now sterile poop.

In harbors with limited flushing of clean water, if enough material with a high enough BOD is added, the bacteria that decompose the waste proliferate, and as they eat the poop you dumped there, they consume the oxygen in the water to the detriment of most other living creatures. The waste also fertilizes the water, and this causes algea blooms that can also cause problems. This comes up in any place where the number of boats per volume of water exceeds a certain threshold. That should be the logic behind any NDZ. Now, get politics into the equation, and things change. But the idea that a Type I MSD eliminates any need for a NDZ shows a basic lack of understanding of the issue.

If you would not put the water coming out of your Type I MSD into your bathtub and swim in it, asking other people to do so seems, at best, selfish.

[fstbttms]

Originally Posted by WindLove

Most people and boat builders don't bother because there are so many NDZs.

An assumption and not a particularly good one.

[peghall]

Ya gotta love idealogues...they protest without bothering to find out what they're actually protesting!

Yikes! Forcing boaters to buy and install electric toilets hoping that would make them cheaper?

2. No one except those those who think that putting toilet waste into tanks that will be pumped out and taken to sewage treatment plants who'll put it half treated into the water is forcing anyone to do anything.

2. Treatment devices aren't toilets...they're devices that toilets flush into.

If you would not put the water coming out of your Type I MSD into your bathtub and swim in it, asking other people to do so seems, at best, selfish.

Since the federal standard for maximum allowable bacteria count in swimming waters is 200/100 ml, and the discharge from Type I MSD treatment devices is <10/100 ml, I wouldn't have any problem at all with that and can't imagine why you would.

And if you'd bothered to do a little more research into the BOD demand from them, you have found that it's less than that from 4 leaves falling off a tree into the water.

Most of the older boats' owners I've met with electroscan units are using a bucket due to breakdowns.


I've yet to meet a single one in the 30 years I've been in the marine sanitation biz. And I don't think you have either because you refer to the ElectroScan, which hasn't been on the market under that name long enough for that to be true and because the likelihood of anyone who has one using a bucket instead of just bypassing it to flush the toilet directly overboard is somewhere south of -0-. If you're gonna spout lies, at least learn enough to make 'em plauseable!

--Peggie

[catsketcher]

I don't mind having no disharge zones but we spend a lot of time swimming around our cat and always use a holding tank when stationary. When a fair way off shore we dump as we sail along.

I don't think that making treatment devices mandatory would lower the price quickly, there are many devices that are cheaper with greater production - EPIRBS and GPS but it has taken about 20 years or more for GPS to go from $3000 in 1990 to less than $30 for a GPS puck today. Watermakers are still pretty pricey, even though they are way more popular than they were a decade ago.

Installing a holding tank can be a cheaper and easier option for those who can do things themselves. I don't think I could build my own treatment system but the holding tank was pretty easy.

cheers

Phil

[senormechanico]

Originally Posted by goat

Yikes! Forcing boaters to buy and install electric toilets hoping that would make them cheaper?



It's not that hard to sail 3 miles offshore to pump out.

It is if you live anywhere in Puget Sound, Admiralty Inlet or the San Juan Islands.

[billknny]

Originally Posted by peghall

If you would not put the water coming out of your Type I MSD into your bathtub and swim in it, asking other people to do so seems, at best, selfish.

Since the federal standard for maximum allowable bacteria count in swimming waters is 200/100 ml, and the discharge from Type I MSD treatment devices is <10/100 ml, I wouldn't have any problem at all with that and can't imagine why you would.

Peggie,

I am not sure what point you are trying to make. Are you suggesting that all NDZs are worthless and should be eliminated?

I think you completely missed my point... Of course the waste coming out of a properly running Type I device has a very lot pathogen count. That was actually my POINT. It has just been chlorinated. But that does NOT make it clean water that I want to swim in. Just LOOK at it. Is it clean water?

TypeI devices can be great tools, for open waters. For enclosed harbors with limited circulation, with lots of boats and lots of discharges I do not think they are the answer.

Do you have real numbers for the amount of BOD reduction that actually occurs in a TypeI device? Convince me that the amount of REDUCTION is large, and I might reconsider. But the chemistry just doesn't support it.

I also believe that the standard for fecal coliform content from a TypeI MSD is 1000 CFU/100 ml, NOT 10. But the regulations might have been updated sine the ones I have...

Edit: Confirmed that the number Peggie quoted for baterial levels in Type I discharge are off by 2 orders of magnitude according the the current CFR. SHe might want to reconsider what she puts in her bathtub...

§ 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.

[CGD 73-83, 40 FR 4624, Jan. 30, 1975, as amended by CGD 75-213, 41 FR 15326, Apr. 12, 1976]

[senormechanico]

Read her post again. She is quoting people .


As per epa:
No more than 1000 per 100 ml.
Swimming is OK with up to 200 per 100 ml.

As per Peg Hall's post re ElectroScan output:
10 per 100 ml.


It's right there in her post.

[Lepke]

This discussion is pointless. Few of the voting public know anything of boats. The people they elect, even less. The law makers react to their big donors and feel good issues. NDZs are a feel good issues.

In the past I used a couple different pass thru MSDIIs and never had a problem. I was a party to a test years ago that installed a MSDII on land for an marine office meeting the sewage flow needs. The exit pipe was 20' clear plastic leading to a sewer connection. There were no solids and the water was close to clear.

[RaymondR]

AND,

many of the waterside communities pointing the finger at waterway users have sewage treatment facilities which dump into the very waterways they are claiming to protect. Many of these facilities are bypassed for various times because of excessive storm water flowing into them.

Years ago one of the towns on the east coast of Australia which relied heavily on tourism designated their river estuary as a NDZ because they were obliged to fairly often close a popular beach because of excessive fecal coliform counts.

The regulations were policed very vigorously by rangers until boat users pretty well stopped using the estuary however the closures continued. Someone in authority noticed that the closures usually occurred following heavy rains. A large street drain which discharged into the estuary was found to be the culprit. Further investigation found that the drain was part of the storm water street drainage system of a rocky headland and that all the houses had their own septic systems. The houses had been there a long time and the plumbers for the original builds had combined all the drainage into the septic tanks and run overflow drains out into the streets roadside drains.

[ranger58sb]

Originally Posted by WindLove

These devices are expensive now because the market is so limited. Most people and boat builders don't bother because there are so many NDZs.

In the grand scheme of things, there's a boatload of water around here that's NOT in an NDZ. Percentage of NDZ versus non-NDZ? I dunno, but I'd just guess that NDZs might be less than 10% of territorial waters (not counting inland lakes and so forth).

FWIW, I just got an estimate to install a Purasan Type I MSD; the quote was just south of $7K including labor.

Originally Posted by goat

It's not that hard to sail 3 miles offshore to pump out.

It is if you're any distance inside the Chesapeake Bay... or Delaware Bay... or up any of the major rivers...

OTOH, it's not all that difficult in many areas to get a pump-out.

-Chris

[peghall]

Are you suggesting that all NDZs are worthless and should be eliminated?

No...only the 90% or more that are unnecessary.

You're correct that the CFR only requires that bacteria count be reduced to a max of 1000/100 ml, but the Lectra/San, ElectroScan and PuraSan have always reduced to less than 10...the Groco ThermoPure uses heat to reduce it to -0- (proven in independent research). But the regulation hasn't been updated. Jim Saxton (R-NJ, now retired) introduced legislation in the '90s that would have revised the CFR to allow vessels equipped with treatment devices which meet that standard to use them even in NDZs. reintroduced it for 5 consecutive years, but the environmental lobby never even let it get out of committee. He finally gave up. And so outdated laws written 40 years ago remain on the books to be cited by people who, like you, wrongly assume that's all any device does.

Do you have real numbers for the amount of BOD reduction that actually occurs in a TypeI device?

Yep...this an excerpt from material in my files:
____________
"(The discharge from the LectraSan, ElectroScan and PuraSan) meets or exceeds the EPA’s coliform effluent criteria for land based systems and reduces BOD by as much as 75%. The following illustrate’s what B.O.D. (Biological oxygen demand) represents in the context of the marine environment.
B.O.D.5 results from a boats holding tank contents is approximately 4000 - 5000 mg/l.
B.O.D.5 results from untreated waste is approximately 1000 - 4000 mg/l.
B.O.D.5 results from 12 oak leaves/250 ml water is 2241 mg/l.
B.O.D.5 results from Lectra/San treated waste is approximately 300 - 1200 mg/l.
B.O.D.5 results from municipal treatment is approximately (no nat. stds.) 50 - 700 mg/l.
The above figures indicate that the discharge has a B.O.D. impact of no more than four oak leaves landing in the water with equally harmless effect.

"Another factor relative to B.O.D. is volume. There would never be enough boaters safely discharging treated effluent in our coastal and navigable waters to cause oxygen depletion or algae blooms. It has never been established that treated particulate from boats has ever caused oxygen depletion especially in an entire states coastal waters."
________________

It's also important to remember that due to the cost, power requirements and other factors, no more than about 5% of boats have treatment devices. And the number of boats in waters that provide no access to open sea that are equipped with overboard discharge pumps is a good indication of the number of tanks that are illegally dumped.


--Peggie

[Pegu Club]

There are so few people who boat to begin with that the volume of sales of any marine head will never allow them to be cheap, they will always be a specialty purchase, thus expensive to purchase and maintain.

NDZ are a good thing, they cause no harm, go to a pump out location already.