Standardization for Marine Sanitation Devices: One Manufacturers Perspective Stephen P. Markle, PE Engineering Director, Navalis Environmental Systems 09 December 2009 Made in the USA

Drivers Regional Variation Regional Variation Public Perception Public Perception Industry Policies Industry Policies

Sewage, Why the Difference? US 33CFR159: Sewage means human body wastes and the wastes from toilets and other receptacles intended to receive or retain body waste. MARPOL Annex IV: (MEPC.115(51) April 2004) –.1 drainage and other wastes from any form of toilets and urinals; –.2 drainage from medical premises (dispensary, sick bay, etc.) via wash basins, wash tubs and scuppers located in such premises; –.3 drainage from spaces containing living animals; or –.4 other waste waters when mixed with the drainages defined above. Should be harmonized.

Existing Test Requirements US 33CFR159 Type II MSD and MEPC.159(55) STP –10 Days, 40 Samples –Influent Quality –Fresh Sewage –Minimum 500 mg/l TSS –Account for Loading –Allow both Land Based and Shipboard Testing Correlate the differences Only Murkowski for Cruise Ships in Alaska (33CFR159 Subpart E) requires continual performance verification after installation. Reality is that Certificate does not mean it works in Marine Environment. –Test Protocol –Influent Specification looks like generic land based POTWF influent. What is desired, a Certificate or High Quality Effluent?

What is Required? International Standard –EPA and IMO come to Terms –Goal is a single world wide maritime standard –Emphasize Best Available Technology Revise Test Protocol –Specify Shipboard Like Influent –Examine 10-day test for adequacy Examine USCG Material Requirements –i.e. Shock and Vibe Requirement Vibe requirement exposed Navalis PLC to equivalent of 9.5 gs acceleration. Requirements based on 1970s smaller vessels exposed to heavy seas –Reasonable and Reflective of Todays Ship Designs? –Surrogate Testing: Modeling and Simulation, Component Testing Who? –ASTM Task Group with US EPA, US Coast Guard, US Navy, CLIA, INTERTANKO, Manufacturers, Academics, NGO Environmental Groups…

Recraft ASTM F

Conclusion: Desired Actions US Ratify MARPOL 73/78 Annex IV –Even the Playing Field –Allow Industry to Build One Product Line Increase Efficiency, Reduce Costs –Take Guess Work out of What is Legal ASTM Take Lead and Develop World Class Specification for Type II MSD/STPs –Require Representative Influent –Require Reasonable Tests Process Duration Physical –Consensus Standard: Owner/Operator, Manufacturer, Regulator… –Best Available Technology? Long Term: Shift from Equipment Standard to Ship Standard as in 33CFR159 Subpart E if truly working to protect the environment.