Standardization for Marine Sanitation Devices:

One Manufacturers Perspective

Stephen P. Markle, PEEngineering Director, Navalis Environmental Systems

09 December 2009

Made in the USA

Drivers

• Regional VariationRegional Variation• Public PerceptionPublic 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 g’s acceleration.• Requirements based on 1970’s smaller vessels exposed to heavy seas

– Reasonable and Reflective of Today’s 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 F2363-06

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.