Problem or Solution?

Reprinted from Cruising World Magazine May 1998
Clean water is like world peace: Everybody is in favor of it.
But the paradox of today's no-discharge trend is that "doing good"
may actually harm the environment.

By Tom Neale

For Years cruising sailors have worried silently about no discharge laws that are unrealistic and often impossible to obey. Devoted to the water and committed to living upon it, we strive to protect it in real world terms. But practical methods of dealing with waste are becoming less and less viable as inappropriate no-discharge laws proliferate. This is a trend that threatens long-range cruising It may even harm the environment we love. Onboard-treatment technology has the potential to work as well as, or better than, the pump out method. Onboard treatment is usually the only practical treatment solution for long-range cruising boats. In most places around the world, it is the only treatment method that works. This no discharge trend jeopardizes all that.

What Are Marine Sanitation Devices?
Types I, II, and III are the three kinds of marine-sanitation device (MSD) that are approved by the U.S. Environmental Protection Agency (EPA) as effective, legal ways to treat waste. Type I and II MSDs are treatment systems that macerate and purify sewage as it is collected, then discharge the treated waste overboard. Type I devices are used most commonly by pleasure boats;Type II devices are required for vessels larger than 65 feet and commercial vessels. A Type III MSD is simply a vented holding tank; raw sewage is stored onboard, pumped out later, and treated ashore.
Purification standards for Type I and II devices have been established by the EPA, pursuant to section 312 of the Clean Water Act.The U.S. Coast Guard, pursuant to the same act, certifies MSDs.The Type I MSD,"says the EPA,"must produce an effluent having a fecal coliform bacterial count not greater than 1,000 per 100 milliliters and no visible floating solids. Type I devices rely on maceration and disinfection for treatment of the sanitary waste prior to discharge into the water.'
Most Type I devices on today's market far exceed EPA standards. For example, the fecal coliform count of the effluent from the Lectra/San EC is 0-20/100 ml in ocean-salinity water. For the Groco Thermapure the count is zero.
Type II MSDs are similar, but their standards are even more exacting: Fecal-coliform bacterial count must not exceed 200 per l 00 ml; suspended solids, no more than 150 mg per liter.

LINK TO Pictorial of the Lectra/san treatment process

A. Electrode pack- Electric current is applied to electrodes, which converts the salt water to a powerful bactericide and oxidizing agent (hypochlorus acid). Bacteria and viruses are forced into contact with the treatment agent.
B. Mixing chamber- The next time the treatment unit is activated the treated waste from the macerating chamber crosses over into the mixing chamber. Waste is treated a second time and further broken down by oxidation, eliminating odors resulting in sanitized waste and saltwater.

Here's What Is Wrong With No-Discharge Zones
Contrary to popular belief, no-discharge zones (NDZs) do not seek to prevent raw- sewage dumping.This has already been illegal for 26 years. What NDZs prohibit is the use of EPA-approved, Coast Guard-certified Type I and Type II onboard treatment devices.
Holding tanks and pumpouts have their place in environmental protection, and this report should not be construed to suggest otherwise. In enclosed freshwater areas, and in highly congested basins where there is little tidal flush, pumpout stations have been very helpful. They work for small boats on day trips and often serve well on boats that make weekend trips and return to the same marina. But for boaters cruising more than a day or so away from developed areas, Type I or II MSD technology is the only practical way to avoid discharging raw sewage. The incentive with pumpout-only thinking is to dump untreated sewage whenever purnping out is impractical or impossible.

The Pumpout Method Doesn't Always Work Well
Land-based treatment centers receiving pumpout wastes are often unreliable. In Long Island Sound last June, more than 15-million gallons of raw New York sewage was dumped because of a shoreside treatment facility failure. In August, tens of thousands of gallons of raw sewage were accidentally dumped into Miami waters. Boaters in some parts of the Florida Keys who pump out can occasionally smell their waste as it leaches into the water from the outdated sewage facilities. In late 1997, Largo, and Pinellas counties in Florida. dumped 300 million gallons of sewage into the water. Every time it rains hard in Newport, Rhode Island, boaters who pump out can see their effluent well up in the harbor from the sewage overflow. These are but a few examples.
Many marinas are rural. They must rely upon septic tanks. Research conducted for the Florida Keys Marine Sanctuary indicates that septic tanks are susceptible to damage from bulk loading from holding tanks. Further, they often leach waste components, such as nutrients causing increased biological oxygen demand (BOD), into the water even when they are working properly. Holding tank chemicals may damage them. Some municipal systems,such as the one in Wilmington, North Carolina, wisely refuse the bulk loading from pumpout operations.
Type I MSDs resolves these problems. Boaters simply push a button and the waste is treated.Warning lights or buzzers tell them instantly if there is a malfunction. At the worst, only one untreated flush is lost overboard.

The proliferation of NDZs in coastal areas may harm marine ecology in three ways.
(1) Pumpout solutions do not work well in many situations.
(2) The no discharge movement creates false security that a given pollution problem is solved when it may not be.
(3) The movement is chilling the use and development of onboard treatment technology

No-Discharge Zones Encourage Cheating
Most pleasure boats don't have space for holding tanks large enough to last more than a few days. (The typical capacity is 5 to 40 gallons, including flush water.) When the tank is full, there can't be much delay in emptying it. Tank-capacity gauges are prone to failure. Suppose you are anchored out for the weekend, even near a harbor with a pumpout, but a gale arrives about the time your tank fills up. Suppose the pumpout station breaks. Suppose the pumpout-boat operator is off-duty till tomorrow. Suppose the depth at the station is too shallow. Such real-world obstacles occur regularly. What do you do with a full tank? The only answer unless you have an onboard treatment system is to dump raw sewage. Because NDZs discourage onboard treatment systems, they paradoxically cause bulk dumping. Fact is, people are more likely to treat their waste if they only have to push a button rather than wait in line at the end of the day to grab a hose that just came out of someone else's honey pot. The public is led to believe that NDZs outlaw raw waste discharge when, in fact, this is already illegal. The effect of NDZs is to outlaw use of legal onboard treatment systems.

Hidden Health Risks?
Pumpout literature typically portrays officials in coats and ties glowing over shiny new stations as they witness staged pumpouts. There's more than meets the eye here. No one is telling the public that pumpout stations are a potential health threat to users. Disseminated information implies that the hose always comes out clean, and that a dip in a bucket of chlorinated water (to be disposed of somewhere, sometime, hopefully without any splashes) takes care of any problems. But in the real world this just doesn't wash. When states such as Florida and New Jersey began pushing their "Clean Vessel Act" pumpouts, signs told users to pour boiling water or chlorine onto their decks to clean up afterward. The nozzle, after being inserted into the holding tank port,"must be secured tightly by hand to prevent spillage and air from entering tank," said directions. The user must check through a sight lens to, see that sewage is flowing. (On any but new hoses you've got to put your face right up close, because these lenses become cloudy with use.) After the pumpout, the nozzle should be washed "with clean water, to prevent clogging and eliminate odor."They don't tell you where to get the clean water or where it goes after the washing.
A publication called Biological Hazards at Wastewater Treatment Facilities outlines the hazards. The study focused on workers at sewage-treatment facilities, but it could be applicable to pumpout users. "Because of their direct exposure to raw waste water, collection systems workers have greater risks of infection than do treatment plant employees ... Most surfaces near wastewater equipment are likely to be covered with bacteria or viruses. These potentially infectious agents may be deposited on surfaces in the form of an aerosol or may come from direct contact with the wastewater."
The study lists many diseases directly associated with "wastewater contaminated environments" a list that includes bacillary dysenteryAsiatic cholera, typhoid fever, tuberculosis, and hepatitis A. Infection can come from touching the equipment, breathing the fumes, or through contact with small skin wounds.
None of this information is circulated at pumpout stations. Unfortunately, it will probably take lawsuits to drive the point home to those responsible for the lack of warnings. With a Type l MSD all you touch is a button.

The Public Has Been Misled About The Impact Of NDZs On Clean Water
Federal criteria for establishing NDZs do not even require a showing that human waste from boats is causing a problem. Presumably, pinpointing pollution sources might implicate targets less politically vulnerable than boaters. In North Carolina and some Chesapeake Bay tributaries, strange lesions on fish and fish kills were found to be caused by pfiesteria piscida .At first, many observers blamed the outbreak on boaters. Later, the bacteria was traced to hog farms. Scientists at the Virginia Polytechnical Institute can identify genetic tracings of fecal coliforin bacteria.On Chesapeake's Eastern Shore they found that a high fecal coliform count affecting shellfish came from raccoons. When the overabundant raccoon population was removed, the water returned to normal bacteria levels. When high fecal coliform counts were found in the Las Olas Isles area in Ft. Lauderdale, the South Florida Marine Industries Association agreed to help fund a study to find the source.The mayor backed this proposal. However, city agencies rejected this plan, forced dock owners to install pumpouts connected to the city sewage system and forced docked boaters to plumb into the shoreside facilities, creating a technological nightmare still fraught with problems. The study to pinpoint other sources of the pollution should have been conducted. Tests conducted after the pumpouts were installed showed almost no diminution in fecal coliform.
Consider the criteria required by the EPA to certify a No-Discharge area. It does not require any water-quality data for no-discharge certification. It requires; only a minimum number of pumpout stations in the region. Further, it requires no follow-up testing to determine whether water quality has improved.
That's not all. It doesn't take a rocket scientist to understand that for NDZs to work there must be enough pumpout stations. EPA"requirements" for this; are farcical. Plug in the boating statistics from one Florida area, and you'll see how it works. Bottom line: With 5,699 boats in the 26-to-40 foot range, and 1,394 vessels longer than 40 feet, only 14 pumpout facilities are enough for nodischarge certification.The criteria assume that a station will operate continuously 24 hours a day, handling four pumpouts per hour. They ignore that every boater wants to pump out at 4 pm. on Sunday, not at midnight Wednesday.

Follow The Dollars
Although states do not receive federal grants as a direct quid pro quo for creating NDZs, federal spending does strongly favor the pumpout solution. Pursuant to the Clean Vessel Act of 1992, the federal government began giving money to towns and states to install pumpout stations. This meant lucrative contracts for pumpout station makers. They lobbied for more. Bob Pacific of the US. Fish and Wildlife Service directs the grant program. Over $40 million has been spent through this program in the last five years, he said. Of this, $2.5 million has gone for administrative expenses on the federal level. The grant money covers 75 percent of the unit cost. Approximately 2,735 pumpouts and dumping stations; have been built under the program. Information wasn't available as to how much of the $37.5 million disbursed to local governments paid for pumpouts and how much was spent administratively, but the total average cost comes to $18,281.54 per unit.
The agency did not grant money for further development of onboard treatment systems because,Pacific said,Congress has not provided any. He said he was neither for nor against NDZs or treatment technology because Congress has not directed him to be. But his agency recently commissioned, financed, and is now disseminating a 60-page booklet entitled American Success Stories about the grant program. It endorses further proliferation of NDZs. It ignores Type I and II MSDs. His agency display at the 1998 Miami Boat Show advocated pumpouts exclusively.

When asked about NDZs'impact on treatment devices, he recommended we call Ed McKiernan, president of Sea-Land Technologies. His company makes pumpout equipment,as well as a Type l device."Although man is capable of flying to the moon,"McKiernan said,"he probably will never develop good onboard treatment units" He said that nutrients exist in treated waste and that,"regardless of whether or not there are scientific findings attributing nutrient related problems to boaters, the public will blame problems on boaters unless they all pump out" (In fact, every blade of grass, every leaf, every drop of rain running from ground to sea adds nutrients as do some livestock raising, farming, sewage treatment facilities, and many other shoreside activities.) Obviously, manufacturers are less likely to develop onboard-treatment technology when they see the grant money going only to the pumpouts.

The push is on The public is led to believe that NDZs outlaw raw-waste discharge, when in fact this is already illegal, and the effect of NDZs is to outlaw use of onboard treatment systems.Those who question this solution are condemned as"environmentally incorrect " Underlying all of this is a sophisticated media campaign. We saw a typical example in St. Petersburg, Florida. In June 1997, the local Department of Leisure Services circulated a "Marina Pumpout Survey" for the city marina, ostensibly to gather information. It concluded by asking"Would you agree that the marina should be designated as an NDZ in the city ordinance since even treated sewage can contribute to poor water quality?"The media is regularly given party-line pamphlets to assure the"right"stories. And it is working. As New Jersey sought NDZ certification for Manasquan Inlet, Lester W Jargowsky the county public health coordinator, told local press,"No one knows if those grinding and disinfecting systems are really effective"

A Case In Point Rhode Island calls itself the Ocean State. Billions of gallons of ocean course back and forth along its shores daily. It now has an application pending before the EPA that seeks to, have all state waters, including a three-mile-wide band of open ocean, certified as an NDZ.Joseph Migliore, the well-meaning state agent who has pushed the proposal, says he knows that local municipal treatment systems have problems, but that"to fix them would cost hundreds of millions of dollars, while (targeting) boaters costs relative little."Besides,"he notes,"the state gets federal money for building pumpouts "His state"doesn't have the technology to, check onboard treatment technology,"he said,so they'd rather outlaw it because"anyone can check a holding tank" Migliore also admitted he hadn't studied Type l MSDs, but that he didn't like them because of his experiences many years ago in a marina. He further admitted he had not conducted any tests demonstrating that boating waste, as distinguished from other sources, adversely affected the water quality in his state, except in a few very confined and densely packed areas such as the Great Salt Pond at Block Island.There was no DNA sampling to establish that boaters were a contributing problem. He noted that his state was concerned with shellfish contamination, but that they conducted no tests that showed that RI shellfish were contaminated by boat waste. He couldn't cite fecal coliform counts from any Type I-treated effluent and couldn't show that Type I-treated effluent was injuring shellfish. He claims that, next, all of New England will outlaw Type l and II technology. "This permit application was a cooperative effort," Migliore said."We could never have done it without assistance from the Rhode Island Marine Trades Association"
We called RIMTA vice president Michael Keyworth, who had been photographed with Migliore and Governor Lincoln Almond at a pumpout ceremony staged for the presentation of the EPA permit application. He said that, while RIMTA has supported efforts to clean up Rhode Island's waters for the past decade, members of his trade organization had not yet read the application. He said he was not aware that NDZ certification would effectively outlaw MSD's that are now approved by the EPA, but that he would "respond with appropriate comments during the public comment period'"
At least one local news organization carried a glowing report of the development, the implication being that anyone for the environment had to be for the proposal. Its information came almost entirely from Mr Migliore and his handouts. The story discussed none of the problems and gave only passing and misleading reference to onboard-treatment systems.

What Is To Be Done?
If you care about ecology, then advocate the use and further development of Type I and II devices (and no discharge zones only in enclosed, non-flushed waters).
If you cruise in areas where pumping out is impractical, consider installing a Type l or II device. You can then treat your waste anytime, anywhere. If an area doesn't allow these devices, and if you don't want to pump out every couple of days, risking serious fines when unable to do so because of the normal contingencies of cruising, don't go there. Encourage your friends to avoid those areas.
See page 5 for information on how to comment on the RI No-Discharge application. Also, Congress is now considering renewal of the Federal Grant Law; contact your political representatives to assure that your funds are going to further development of onboard treatment as well as building pumpout stations.
We should be part: of a joint solution to the very real challenges of keeping our waters clean. How ever designating entire state to be No-Discharge Zones, and the de facto outlawing of responsible use of Type I and II devices, disproportionately penalizes boaters for a problem for which they are in only a very small way responsible There's something smelly in the air, but it's not coming from your head.

Tom Neale is a Cruising World contributing editor

Reprinted from Cruising World Magazine May 1998

Home | Products | Tech Support | Purchase | Information | Contact Us

©2003 Raritan Engineering Company Inc.
Last updated: Tuesday, July 31, 2007
Website designed and maintained by JasperDyne Industries.