EPA/600/R-10/137
                               10/37/WQPC-SWP
                                  August 2010
Environmental Technology
Verification Report

Evaluation of Wastewater Treatment
Technology  for Septage and High Strength
Wastewater

Big Fish Environmental, LLC
Big Fish Environmental Septage and High Strength
Wastewater Processing System

                  Prepared for
               NSF International

             Under a Cooperative Agreement with
          I.S. Environmental Protection Agency

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         THE ENVIRONMENTAL TECHNOLOGY VERIFICATION
                                    PROGRAM
  «EPA
    U.S. Environmental
    Protection Agency
                                    NSF International
                     ETV Joint Verification  Statement
   TECHNOLOGY TYPE:   WASTEWATER TREATMENT - CHEMICAL ADDITION,
                          FILTRATION AND BIOLOGICAL TREATMENT
   APPLICATION:
TREATMENT OF SEPTAGE AND HIGH STRENGTH
WASTEWATER
   TECHNOLOGY NAME:  BIG FISH ENVIRONMENTAL SEPTAGE AND HIGH
                          STRENGTH WASTEWATER PROCESSING SYSTEM
   COMPANY:
   ADDRESS:


   EMAIL:
BIG FISH ENVIRONENTAL, LLC
12640 TAYLOR ROAD
PO BOX 528
CHARLEVOIX, MI 49720
info@bigfishenvironmental.com
PHONE: (231) 547-4429
The U.S. Environmental Protection Agency (EPA) created the Environmental Technology Verification
(ETV) Program to facilitate the deployment of innovative or  improved environmental technologies
through performance verification and dissemination of information. The goal of the ETV program is to
further environmental protection by accelerating the acceptance and use of improved and cost-effective
technologies.  ETV seeks  to achieve this  goal by providing high quality, peer-reviewed  data on
technology performance to those involved in the  design, distribution, permitting, purchase, and use of
environmental technologies.

ETV works in partnership  with recognized standards  and  testing organizations;  stakeholder groups
consisting of buyers, vendor organizations, and permitters; and  the full participation of individual
technology developers. The program evaluates the performance of innovative technologies by developing
test plans that are responsive to the needs of stakeholders, conducting field or laboratory tests  (as
appropriate), collecting and analyzing  data,  and preparing peer-reviewed reports. All evaluations  are
conducted in accordance with rigorous quality assurance protocols to ensure that data of known and
verifiable quality are generated, and that the results are defensible.

NSF International  (NSF) operates the ETV Program's Water Quality Protection Center (WQPC) under a
cooperative agreement with EPA. The WQPC evaluated the performance  of the Big Fish Environmental
Septage and High  Strength Wastewater Processing System (System) over a period of more than a year.
The Big Fish System consists of lime treatment followed by solids separation in a heated screw press,
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with filtrate subsequently processed in an aerobic biological treatment system. Effluent from the System
is discharged to a municipal wastewater treatment plant. Biosolids are also produced which may be used
as fertilizer or soil amendment. This verification statement provides a summary of the test results for the
Big Fish System.

TECHNOLOGY DESCRIPTION
The following technology description is provided by the vendor and does not represent verified
information.

The Big Fish System (System) combines solids treatment with aerobic wastewater treatment, processing
high strength wastes to produce Exceptional Quality (EQ)  Class A Biosolids (refer to Federal Rule for
Class A Biosolids (40 CFR Part 503)(1) and the EPA document - A Plain English Guide to the EPA Part
503 Biosolids Rulem) and treated filtrate meeting pretreatment standards for discharge to most secondary
wastewater treatment plants (typically 250-300 mg/L BOD5; 300-350 mg/L TSS; 50-70 mg/L NH3; and
locally determined restrictions for total phosphorus). The system uses a combination of elevated pH for
vector (rodents, insects, birds, etc.) control and elevated temperature (time-temperature combination) for
pathogen control to meet the  Federal Rule for Class A  Biosolids.  There is no actual testing  for vector
control  addressed in the Rule, only the specified treatment.  The first requirement is to treat the waste
material with lime to raise the pH to a minimum of 12 for 2 hours, and then maintain a minimum pH of
11.5 after 24 hours without further lime addition. Treatment for pathogen control requires heating the
biosolids to a temperature of 72°C for a period of at least 20 minutes. The term EQ Biosolids is identified
in the Federal Rule to characterize Class A Biosolids that also meet low-pollutant metals concentrations
(see Table  3). If the Class A Biosolids treatment requirements are met and the metal pollutant levels are
not exceeded, they are considered EQ Class A Biosolids and can generally be applied as freely as any
other fertilizer or soil amendment to any type of land.

Truck-delivered wastes pass through an in-line JWC Muffin Monster 0.25 in. screen to remove any large
inorganic particles or debris. A flow meter records the waste volume and an in-line pH meter monitors the
waste to confirm the pH is between 4.0 and 9.0.  The screened  waste passes through a de-grit chamber,
into an 11,000-gallon aerated receiving/equalization tank, which is directly connected to a second aerated
15,000-gallon equalization tank.

When 15,000 to 20,000 gallons of waste are accumulated, the waste is pumped to one of the  two 20,000-
gallon lime treatment tanks. Lime is added to the waste mixture during the transfer to achieve pH 12 for a
minimum of 2 hours; the mixture is then held at minimum pH of 11.5 for at least 22 hours. After lime
treatment  is  complete, the wastewater  and solids are pumped  from the lime treatment tank to  a
flocculation tank, where polymer is added, and then to a rotary  screen thickener prior to  entering the
screw press. Filtrate extracted by the thickener  is discharged to a blending tank for pH adjustment to
approximately pH 7.5 - 8.0. The thickened  sludge is processed in a heated screw press that raises the
solids temperature to a minimum of 72° C for at least 20 minutes which increases the solids content to 40-
50%. The combination of the lime treatment and the elevated temperature in the screw press  conforms to
the treatment requirements established in 40 CFR Part 503 for producing Class A Biosolids.  Solids are
collected in a hopper and the transferred to an outside covered storage area, while the screw press filtrate
is discharged to the blending tank for pH adjustment and subsequent biological treatment.

The aerobic treatment system consists of a series of aerated tanks, followed by a 2,000-gallon quiescent
settling  tank, a 2,000-gallon re-aeration  tank, and two 2,000-gallon discharge tanks.  The  combined
volume  of the aerobic treatment tanks is 27,000 gallons.  The suspended growth aerated tanks have one or
more White Knight™ microbial generators  suspended in the tanks to provide a source of supplemental
microorganisms to the naturally occurring microorganisms. A hatchery at the facility is also maintained as
an additional source of microorganisms if needed. The large capacity of the aeration tanks is designed to
provide  time  for biological treatment to reduce the very high organic loadings that normally remain in

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septage type wastes after solids removal. Liquid discharged to the aerated tanks from the screw press and
thickener causes water to flow through the system tanks. A float switch in the discharge tank triggers an
effluent discharge by pump from the treatment system to the City of Charlevoix, MI municipal sewer
system. Solids that accumulate in the settling tank are periodically pumped to the receiving tank for
processing through the treatment system. All treatment processes, including truck unloading, occur inside
a building equipped with a biofilter to reduce odors.

VERIFICATION TESTING DESCRIPTION
Test Site
The verification test was performed at the Big Fish facility in Charlevoix, Michigan, a full-scale System
operating under a permit issued by the Michigan Department of Natural Resources and Environment
(MDNRE), and in accordance with the requirements of the City of Charlevoix. Scherger Associates was
the lead for the Testing Organization (TO) for this verification and provided technical oversight during
the test. The facility has been  in operation for over three years, with effluent discharge to the City of
Charlevoix municipal  WWTP. The  System receives septage waste from several septic tank cleanout
companies, secondary  sludge from the City of Charlevoix WWTP, commercial grease interceptor waste
containing fats, oils and grease (FOG) from local businesses, portable toilet waste and fruit processing
waste.
Methods and Procedures
Testing was completed in accordance with the approved test plan1-2-1 for the System. The verification test
was conducted from September 2008 through October 2009 and included thirteen sampling and analysis
events  over the 14-month test. Monthly  sampling  events included  a  5-day period with two batches of
waste being processed, except in March 2009 when only one batch was  processed and April 2009 when
there was no sampling. Sampling locations included the  untreated waste material and the treated effluent.
Untreated waste samples were  grab  samples from the aerated equalization tank. Effluent samples were
both composite and grab samples collected during discharge periods. Grab samples were collected each
sample day for pH, FOG, temperature, and dissolved  oxygen. The composite discharge  samples and
untreated waste grab samples were collected each sampling day and analyzed for total suspended solids
(TSS),  five-day biochemical oxygen demand (BOD5), chemical oxygen demand (COD), and alkalinity.
Weekly composite samples were made of the untreated  waste grab samples and the composite  discharge
samples.  This was  done by combining aliquots  of several  individual daily  samples to  form batch
composite samples, which were analyzed for total Kjeldahl nitrogen (TKN), ammonia, nitrite plus nitrate,
and total phosphorus (TP).  Samples of the biosolids material were collected twice during the verification
test and analyzed for percent solids and regulated (40 CFR Part 503) metals (As, Ba, Cd, Cr, Hg, Pb, Ni,
Zn).  The pH of the lime treated waste material was measured and recorded in the System  operating
record; the temperature of the biosolids in the screw press was recorded continuously.

The  approved test plan included monitoring  system performance during startup.  From January 2 to
January 4, 2009, Big Fish personnel emptied and cleaned the System tanks and restarted the System. The
tanks were  filled with processed wastewater from the screw process and microorganisms were  seeded to
the aerated tanks  by adding 1,500  gallons of material from the  hatchery tank. The White  Knight™
microbial generators were hung in place in accordance with standard  operating practice. The normal
January 2009 verification sampling was performed three weeks after startup and showed the  System was
producing an effluent comparable to the four months (September 2008 through December 2008) prior to
the cleaning and startup demonstration.

All analyses were  completed in accordance  with USEPA approved methods or Standard Methods for the
Examination of Water and Wastewater,  20th Edition. An established quality assurance/quality control
(QA/QC) program was used to monitor sampling and  laboratory  procedures. Details on all  analytical
methods and QA/QC procedures are provided in the full  verification report.
                                              IV

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PERFORMANCE VERIFICATION
Verification Test Results and Discussion
There were three sampling events during the  verification testing that are not included in  the data
summaries  presented in Tables 1 and 2, but are  discussed in detail in the Verification Report. In March
2009, the reported effluent BOD5 data was not consistent with the other reported data for the sampling
event (particularly the effluent COD) so none of the day's data were included in the averages for the
verification. The other two events occurred in May 2009 when the System received highly concentrated
wastes, believed to be fruit waste, increasing the influent holding tank BOD5 and COD concentrations to
21,000 mg/L and 31,000 mg/L, respectively  (the  BOD5 being  seven (7) times the mean influent
concentrations over the course  of the verification). The effluent BOD5 and COD concentrations increased
in the two treated batches following receipt of the waste to a BOD5 of 5,500 mg/L and 5,700 mg/L, and a
COD of 11,000 mg/L  and 8,600 mg/L, respectively.  The data  for these  two sampling events  were
determined to have  resulted  from  System upset (defined  in  the Protocol for  the  Verification of
Wastewater Treatment Technologies,  April 20011-3-1), so the data were not included in the averages for the
verification testing indicated in Table  1.

Following the upset, the System was operated in normal aeration recycle mode, without additional waste
loading or effluent discharge.  After 10 days operation in this mode, a batch of wastes from the holding
tank was processed. The effluent BOD5 (810 mg/L - facility-generated data) indicated the System was
recovering, but not yet back to  typical discharge concentrations. The System continued to operate with the
aeration tanks in normal recycling mode for another ten  days, when another batch of waste material was
processed and the  effluent BOD5 concentration was found to be 110 mg/L. A subsequent batch of waste
was processed and it was confirmed that the system had returned to normal operating conditions (effluent
BOD5 of 96 mg/L).  The ETV  verification  testing for June was performed the week of June  22 and the
data showed the System had recovered.

Table 1 presents the results for BOD5, COD and TSS.  The influent concentrations are typical of a
septage/high strength wastewater mixture.  The treated effluent had a mean reduction of 97.7% (median
97.3%) for BOD5. The mean  and median COD removal was  98.4% and the mean and median TSS
removal was 99.6%. The mean influent FOG concentration  was 370 mg /L  (median 140 mg/L). The
effluent mean FOG  concentrations was 5.1 mg/L (median 3.0  mg/L), resulting in a mean removal of
98.6% (median 97.5%). Fourteen of the 22 effluent samples showed an FOG concentration of <3 mg/L.

Table 2 presents the  results for TKN,  NH3-N, NO2+NO3, and TP. Total nitrogen (TN) was determined by
adding the concentrations of the TKN (organic plus ammonia nitrogen), and NO2 plus NO3 in the effluent.
The  overall system removal efficiency for TN was  80% (mean and median).  Mean TP  removal was
95.3% (median 97.3%).

Table 1.  BOD5, COD and TSS Data Summary

                      BOD5 (mg/L)                     COD (mg/L)                 TSS (mg/L)
                 Influent        Effluent       Influent        Effluent        Influent     Effluent
Mean
Maximum
Minimum
Std. Dev.
3,300
15,000
27
2,900
75
190
7
44
17,500
31,000
3,700
8,000
270
400
25
96
13,700
28,000
3,700
6,500
55
170
10
42
Note: Data in Table 1 are based on 22 samples of influent and 22 samples of effluent and do not include the results
     for the upset period that occurred in May 2009. During the upset, BOD5 removal was reduced to 43 - 74%
     and COD to 57 - 64%; TSS removal remained at 90 - 99% during the upset.

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Table 2.  Nitrogen and Phosphorus Data Summary
                                                     1,2
                  TKN (mg/L)                   Ammonia (mg/L)             Nitrite/Nitrate (mg/L)
            Influent        Effluent         Influent        Effluent        Influent        Effluent
Mean
Maximum
Minimum
Std. Dev.
440
550
170
100
83
170
42
35
93
160
8
48
60
120
14
30
3.2
15
0.05
5.3
3.8
13
0.05
3.7

                                  Total Nitrogen (mg/L)                 Total Phosphorus (mg/L)
                                 Influent         Effluent           Influent            Effluent
Mean
Maximum
Minimum
Std. Dev.
440
550
170
100
85
170
49
34
128
280
2.6
90
3.3
7.1
O.05
1.8
1  Data in Table 2 are based on 12 samples of influent and 12 samples of effluent and do not include the results for
  the upset period that occurred in May 2009.
2  Nitrogen data reported in mg/L as N; phosphorus data reported as mg/L as P.

The  nitrogen  data indicate that a large  percentage of the total nitrogen was organic  nitrogen.  A
comparison of the mean influent TKN (440 mg/L) with the mean influent ammonia concentration (93
mg/L) shows that organic nitrogen represented approximately 79% of the nitrogen in the wastes received
at the facility (nitrite-nitrate was low at 3.2 mg/L).  Based on review of the ammonia and nitrite-nitrate
data, it appears that the biosolids produced by the screw press contained a large  amount of the organic
nitrogen removed by  the  System.  If appreciable organic nitrogen reduction were  occurring in the
biological system aeration tanks, the ammonia and/or nitrite-nitrate concentrations in the  effluent would
increase significantly (which they did not).  The reduction in ammonia could be attributed to association
with the biosolids or possibly volatilization from aeration in the System.

The pH ranged from 12.1 to 12.9 during the initial 2-hour period after lime addition to the treatment tanks
and after 24 hours the pH ranged from 11.6 to 12.8. The programmable logic controller records show that
the proper screw press rate (38% motor speed) was maintained at all times ensuring the minimum contact
time in the screw press at elevated temperature was achieved. The screw-press temperature ranged from
90°C to 100° C, well above the minimum requirement of 72°C for a 20 minute contact time. Samples  of
the biosolids were collected and analyzed for regulated metals as part of this verification.  These data are
shown in  Table  3.  Based on the data  collected during the  verification test,  all batches  of biosolids
produced met the requirements to be classified as EQ Class A Biosolids.

Operation and Maintenance Results
Lime, used to raise the pH to meet the requirements for vector reduction in the biosolids and to aid in the
dewatering processes, can also enhance phosphorus removal. The mean quantity of lime used was 11 Ibs
of lime per 1000 treated gallons. Polymer was added to the lime treated waste material as it was pumped
from the holding tank to the thickener. A cationic polymer, Aquaben HF 748E, was used from September
2008 through July 2009 at mean addition rate of 0.63 gallons of concentrated polymer (as  purchased) per
1000 treated gallons. A different cationic polymer, ERC Associates ERC840HX was used from August
through October 2009 at a mean addition rate of 1.15 gallons of concentrated polymer (as  purchased) per
1000 treated gallons.  The concentrated polymer is diluted  in the injection  system used  to feed the
polymer. Muriatic acid was used to neutralize the filtrate extracted in the rotary screen thickener, which is
discharged to a blending tank ahead of the aerobic processing tanks. The acid was fed from the containers
                                              VI

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   Table 3.  Biosolids Metals Concentration
       Analyte
  Units
3/13/2009
                Pollutant Concentration
6/18/2009         Limits for EQ Class A
                      Biosolids
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
Total Solids
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
%
3.5
2.4
18
430
21
0.33
12
5.9
1,300
50
4.4
2.2
19
260
23
0.22
12
2.6
990
60
41
39
1,200
No standard
300
17
420
36
7,500
NA
   received from the supplier without intermediate dilution. The mean muriatic acid use was 0.55 gallons per
   1000 treated gallons.

   The electric power and natural gas use during the verification test was monitored using the facility electric
   and gas meters. These meters measured total use for the facility. Electrical use averaged 671 kWh per day
   based on 5-day operating periods treating two batches per week. Steam for heating the biosolids in the
   screw press was generated on-site with a gas fired boiler. Natural gas use averaged 25  cubic feet per day
   based on the 5-day operating periods treating two batches per week during the verification test.

   There were no major mechanical component failures or major downtime periods during the verification
   test. Operation and maintenance of the System was observed by the testing  organization representatives
   who were on- site for several days each month to collect samples and review operating records. These
   observations provided  information on System operability,  complexity, and  degree of maintenance
   required. The Big Fish System was found to be easily operated, requiring only routine maintenance, and
   was reliable during the verification period.

   Quality Assurance/Quality Control
   Prior to the start of the verification test, NSF completed a QA/QC audit of the RTI Laboratories (RTI).
   These audits included: (a) a technical systems audit to assure the testing was in compliance with the test
   plan, (b) a performance evaluation audit to assure that the measurement systems employed at the test site
   and by RTI were adequate to produce reliable  data, and (c) a data quality audit of at least 10 % of the test
   data to assure that the reported data represented the  data generated during the testing.  During testing,
   NSF conducted a QA/QC audit of the Big Fish Environmental test  site.  EPA QA personnel also
   conducted a quality systems audit of NSF's QA Management Program.
Original signed by
Sally Gutierrez
October 26, 2010
Sally Gutierrez                  Date
Director
National Risk Management Research Laboratory
Office of Research and Development
United States Environmental Protection Agency
        Original signed by
        Robert Ferguson
                  November 2, 2010
                          Robert Ferguson
                          Vice President
                          Water Programs
                          NSF International
                                            Date
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NOTICE:    Verifications  are  based  on  an  evaluation  of technology  performance  under  specific,
predetermined criteria and the appropriate quality assurance procedures. EPA and NSF make no expressed
or implied warranties as to  the performance of the technology and do not certify that a technology will
always operate as verified.  The end user is solely responsible for complying with any and all applicable
federal, state, and local requirements.  Mention of corporate names, trade names, or commercial  products
does not constitute endorsement or recommendation for use of specific products.  This report in no way
constitutes an NSF Certification of the specific product mentioned herein.	
Supporting Documents
Referenced DocumentsAQ CFR Part 503, Standards for the Use or Disposal of Sewage  Sludge, Subchapter O,
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr503_main_02.tpl
1)  A Plain English Guide to the EPA Part 503 Biosolids Rule, https://www.epa.gov/OW-
    OWM.html/mtb/biosolids/503pe/index.htm
2)  Test Plan for Big Fish Environmental, LLC Big Fish Environmental Septage Processing System, dated July 2008;
    https://www.epa.gov/etv/pubs/04_vp_wastewater.pdf
3)  The Protocol for Verification ofWastewater Treatment Technologies, dated April 2001 (see below for availability).

EPA's Office ofWastewater Management has published a number of documents relevant to this verification, including:
Handbook for Management ofOnsite and Clustered Decentralized Wastewater Treatment Systems,
https://www.epa.gov/owm/onsite
Onsite Wastewater Treatment Systems Manual, https://www.epa.gov/owm/mtb/decent/toolbox.htm

Source of Verification Information:
Copies of, Test Plan for Big Fish Environmental, LLC Big Fish Environmental Septage Processing System, dated July
2008, the Verification Statement, and the Verification Report are available from: ETV Water Quality Protection Center
Manager  (order  hard  copy),  NSF  International,   P.O.   Box  130140,  Ann Arbor,   Michigan 48113-0140
(http://www.nsf.org/etv (electronic copy); or https://www.epa.gov/etv (electronic copy)).  Appendices are not  included in
the Verification Report, but are available from NSF upon request.
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 Environmental Technology Verification Report

         Wastewater Treatment Technology
     for Septage and High Strength Wastewater
            Big Fish Environmental, LLC
Big Fish Environmental Septage and High Strength
           Wastewater Processing System
                        Prepared for

                      NSF International
                    Ann Arbor, MI 48105
                        Prepared by

                     Scherger Associates
                     Ann Arbor, MI 48105
  Under a Cooperative Agreement with the U.S. Environmental Protection Agency

                Raymond Frederick, Project Officer
               ETV Water Quality Protection Center
            National Risk Management Research Laboratory
             Water Supply and Water Resources Division
               U.S. Environmental Protection Agency
                   Edison, New Jersey 08837
                        August 2010
                           IX

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                                       Notice

The  U.S.  Environmental Protection  Agency  (EPA), through its  Office  of Research and
Development, has financially supported and collaborated with NSF International (NSF) under a
Cooperative  Agreement.  The Water Quality Protection Center (WQPC), operating under the
Environmental Technology Verification (ETV) Program, supported this verification effort.  This
document has been peer reviewed and reviewed by NSF and EPA and recommended for public
release.

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                                      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.
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                                  Table of Contents
Notice	x
Foreword	xi
Table of Contents	xii
Figures	xiv
Tables	xiv
Acronyms and Abbreviations	xv
Acknowledgments	xvii
  Chapter 1  Introduction	1
     1.1    ETV Purpose and Program Operation	1
     1.2    Testing Participants and Responsibilities	2
        1.2.1 NSF International - Verification Organization (VO)	2
        1.2.2 U.S. Environmental Protection Agency (EPA)	3
        1.2.3 Testing Organization (TO)	3
        1.2.4 Technology Vendor	4
        1.2.5 ETV Test Site	5
     1.3    Background and Objectives	5
     1.4    Test Site Description	6
     1.5    Historical Flow and Effluent Quality	8
  Chapter 2 Technology Description and Operating Processes	9
     2.1    Technology Overview	9
        2.1.1 Truck Unloading, Screens, and Equalization	9
        2.1.2 Lime Treatment and Solids Separation -Biosolids Production	11
        2.1.3 Aerobic Treatment, Settling and Discharge	12
        2.1.4 Operation and Maintenance	13
     2.2    Big Fish Environmental Claims	14
  Chapter 3  Methods and Test Procedures	15
     3.1    Verification Test Plan and Procedures	15
     3.2    Installation and Startup Procedures	15
     3.3    Verification Testing	16
        3.3.1 Introduction	16
        3.3.2 Objectives	17
        3.3.3 Verification Test Period	17
        3.3.4 Flow Monitoring	17
        3.3.5 Sampling Locations and Procedures	18
        3.3.6 Sampling Schedule	20
        3.3.7 Sample Preservation and Storage	21
        3.3.8 Chain of Custody	21
     3.4    Analytical Methods	22
     3.5    Operation and Maintenance	22
  Chapter 4 Results and Discussion	24
     4.1    Introduction	24
     4.2    Verification Test	24
        4.2.1 Verification Test - Flow Conditions	24
        4.2.2 BODs/COD, TSS, and FOG Results and Discussion	26
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        4.2.3 Nitrogen Reduction Performance	30
        4.2.4 Total Phosphorus Removal Performance	32
        4.2.5 Other Operating Parameters - pH, Alkalinity, Sodium, Chloride, Dissolved
             Oxygen, and Temperature	33
        4.2.6 Biosolids Production and Quality	38
    4.3    Operation and Maintenance	41
        4.3.1 Chemical Use	41
        4.3.2 Electric Power and Natural Gas Usage	43
        4.3.3 Operation and Maintenance Observations	45
    4.4    Quality Assurance/ Quality Control	46
        4.4.1 Audits	46
        4.4.2 Precision	47
         4.4.2.1   Laboratory Duplicates	47
         4.4.2.2   Field Duplicates	47
        4.4.3 Accuracy	49
        4.4.4 Representativeness	55
        4.4.5 Completeness	55
  Chapter 5 Vendor Discussion	57
Glossary of Terms	58
References	59
Bibliography	59
Appendices	61
    Appendix A Big Fish Supplied Data for Fecal Coliform; % Moisture; E. coli; Enterococci;
           Cryptosporidium,  and; Giardia	61
    Appendix B Verification Test Plan	71
    Appendix C Big Fish Operation and Maintenance Manual	72
    Appendix D Pictures of Test Site and Equipment	73
    Appendix E Spreadsheets with Calculations and Data Summary	74
    Appendix F Lab Data, QA/QC Data, Field Logs, and Records	75
                                          Xlll

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                                       Figures

Figure 1-1. Verification test site location map [[[ 7
Figure 2-1. Big Fish System overview of processing steps [[[ 9
Figure 2-2. Big Fish System process flow diagram [[[ 10
Figure 2-3. Big Fish System biosolids process description [[[ 11
                                       Tables
Table 1
Table 1

Table 4
Table 4
Table 4
Table 4
Table 4
Table 4
Table4
Table 4
Table 4
Table 4
Table 4
Table 4
Table 4
Table 4
Table 4
Table 4
Table 4
Table 4
Table4
Table 4
Table 4
        1. Discharge Permit Limits for the Big Fish Facility [[[ 7
        2. Summary Flow Rate and Water Quality Data for Test Site (January 2007 through
          January 2008) [[[ 8
        1. Batch Treatment Volume and Discharge [[[ 25
        2. BOD5 and COD Results [[[ 28
        3. TSS and FOG Results [[[ 29
       -4. Influent and Effluent Nitrogen Data [[[ 31
       -5. Total Phosphorus [[[ 33
       -6. pH and Total Alkalinity Results [[[ 35
       -7. Chloride  and Sodium Results [[[ 36
       -8. Temperature and Dissolved Oxygen Results [[[ 37
       -9. Biosolids - pH of Lime Treated Biosolids at 2 and 24 hour Holding Periods ............ 39
        10. Screw Press Operating Data Summary Temperature and rpm ................................. 40
        11. Biosolids Metals Results [[[ 41

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                           Acronyms and Abbreviations
ASTM
Big Fish
Big Fish System
BOD5
°C
COD
DO
DQI
ETV
°F
FOG
ft2
gal
gpd
gpm
GP
In.
Kg
L
Ibs
MDL
MDNRE
NH3-N
N02
N03
NRMRL
mg/L
mL
NSF
NIST
O&M
PM
ppb
QA
QC
RPD
SD
SOP
T
TKN
American Society for Testing and Materials
Big Fish Environmental, LLC
Big Fish Septage and High Strength Wastewater Processing System
5 -day biochemical oxygen demand
Celsius degrees
Chemical oxygen demand
Dissolved oxygen
Data quality indicators
Environmental Technology Verification
Farenheit degrees
Fats, oil, and grease
Square foot (feet)
Gallons
Gallons per day
Gallon(s) per minute
Generic protocol
Inch
Kilogram(s)
Liters
Pounds
Minimum detection level
Michigan Department of Natural Resources and Environment
Ammonia nitrogen
Nitrite
Nitrate
National Risk Management Research Laboratory
Microgram(s) per liter (ppb)
Milligram(s) per liter
Milliliter(s)
NSF International
National Institute of Standards and Technology
Operations and maintenance
Project Manager for the Testing Organization (TO)
Parts per billion (|ig/L)
Quality assurance
Quality control
Relative percent difference
Standard deviation
Standard operating procedure
Temperature
Total Kjeldahl nitrogen
                                         xv

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TO                 Testing Organization
TP                 Total phosphorus
TSS                Total suspended solids
USEPA             U.S. Environmental Protection Agency
VO                 Verification Organization (NSF)
VTP                Verification test plan
WWTP             Wastewater treatment plant
WQPC              Water Quality Protection Center
                                         xvi

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                                 Acknowledgments

The Testing Organization (TO), Scherger Associates, was responsible for managing the testing
sequence on site at the Big Fish Environmental facility in Charlevoix, MI, including collection of
samples,  checking that  equipment and  instruments were  being monitored and  maintained,
collection of field data, and data management. Mr. Dale Scherger was the Project Manager for
the TO. Mr. Randy Holecheck was the field technician responsible  for sample collection and
system observations.

RTI Laboratories, Inc. conducted the analytical work for this study, with primary contacts being
Mr. Brian Hall and Ms. Patricia Jennings.  RTI is  NELAC  accredited  to  drinking  water,
wastewater, and hazardous and solid waste in the State of Illinois, and the State of Michigan for
drinking water analysis. Mr. John Campbell is the manufacturer and assembler of the equipment
and facility

The  TO  thanks  NSF International,  especially  Mr.  Thomas  Stevens, Project  Manager,  for
providing guidance and program management. The TO also thanks Mr. Brian Darrah, the Big
Fish  System supervisor  for his efforts in maintaining all  the records required by the  ETV
program and assistance in scheduling the treatment system activities to meet the ETV sampling
schedule.
                                         xvn

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                              Chapter 1 Introduction


1.1    ETV Purpose and Program Operation

The U.S. EPA created the Environmental Technology Verification (ETV) Program to facilitate
the deployment of innovative or improved  environmental  technologies through performance
verification  and  dissemination  of information.   The  ETV  Program's goal  is  to  further
environmental protection by  substantially accelerating the  acceptance and use  of innovative,
improved and more cost-effective technologies.  ETV seeks to achieve this goal by providing
high quality,  peer-reviewed data on technology performance to those involved  in the design,
distribution, permitting, purchase, and use of environmental technologies.

ETV  works  in  partnership  with  recognized  standards   and  testing  organizations  (TOs);
stakeholders  groups  that consist  of buyers, vendor organizations, consulting  engineers, and
regulators; and the full participation of individual technology developers.  The program evaluates
the performance of innovative technologies by developing test plans that are responsive to the
needs  of stakeholders, conducting  field or laboratory tests (as appropriate),  collecting and
analyzing  data,  and preparing  peer-reviewed  reports.    All  evaluations  are  conducted in
accordance with rigorous quality assurance protocols to ensure that data of known and adequate
quality are generated and that the results are defensible.

In cooperation with EPA, NSF operates the Water Quality Protection Center (WQPC), one of six
centers under ETV.  This WQPC focuses on technologies  addressing wet weather flows and
source water protection (SWP), and includes the  verification testing of wastewater treatment
systems that  provide protection for groundwater and surface water sources. NSF International
(NSF) operates the WQPC under the sponsorship of the Urban Watershed Management Branch,
Water Supply and Resources  Division,  National Risk Management Research Laboratory.  The
role of NSF is to provide technical and administrative leadership in conducting the testing.

The ETV program  has developed verification  testing protocols that serve as templates for
conducting verification tests  for various technologies.   The Protocol for  the  Verification of
Wastewater Treatment Technologies, April 2001(1) was published as the guidance document for
test plan development for verification testing of decentralized wastewater treatment systems for
all non-residential (commercial and industrial) wastewater  and  for residential wastewater  with
flow rates greater  than 1,500 gallons per day (gpd). The goal  of the verification testing process is
to generate high quality data for verification of equipment performance.

It is important  to note that verification of  the equipment does  not mean  or  imply that the
equipment is "certified" or "approved"  by NSF or USEPA. Instead, verification testing is a
formal mechanism by which the performance of equipment  can be determined, resulting in the
issuance of a  Verification Statement and report by NSF and USEPA.

The WQPC evaluated the performance of the Big Fish Environmental Septage and High Strength
Wastewater Processing System (Big  Fish System) for the removal  of contaminants present in
septage and high strength wastewater. These contaminants include total suspended solids (TSS),

                                           1

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biochemical oxygen demand (BOD5), COD, fats, oil, and grease (FOG), and nutrients, (including
phosphorus, total Kjeldahl nitrogen (TKN), ammonia nitrogen (NH3-N), and nitrite plus nitrate
nitrogen (NO2+NO3)).  This report provides the verification test results for the Big Fish System
in accordance with the GP (1), and the technology specific test plan,  Verification Test Plan for
Big Fish Environmental Septage Processing System, July 2008 (2) (VTP). The purpose of the
VTP is to assure performance of the product in accordance with manufacturer claims.

1.2    Testing Participants and Responsibilities

The  ETV testing of the  Big Fish  System was a cooperative  effort  between the following
participants:

   •   NSF
   •   Scherger Associates
   •   RTI Analytical Laboratories, Inc.
   •   Big Fish Environmental, LLC
   •   USEPA

1.2.1   NSF International - Verification Organization (VO)

The WQPC of the ETV is administered through a cooperative agreement between EPA and NSF.
NSF is the verification partner organization for the WQPC and the SWP area within the center.
NSF administers the Center and  contracts with  the Testing Organization (TO) to develop and
implement the VTP, conduct the verification test, and prepare the verification report.

NSF's responsibilities as the VO included:

   •   Review  and comment on the site specific VTP;
   •   Coordinate with peer reviewers to review and comment on the VTP;
   •   Coordinate with the EPA Project Officer and the technology vendor to approve the VTP
       prior to the initiation of verification testing;
   •   Review  the quality systems of all parties involved with the TO and, subsequently, qualify
       the companies making up the TO;
       Oversee the technology evaluation and associated laboratory testing;
       Provide  quality assurance/quality control (QA/QC) review and support for the TO;
       Carry out an on-site audit of test procedures;
       Oversee the development of a verification report and verification statement;
       Coordinate with EPA to review the verification report and sign the verification statement;
       and
   •   Prepare  and disseminate the Verification Report and Verification Statement.

The key contact at NSF for the VO is:

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       Mr. Thomas Stevens, Program Manager
       (734) 769-5347    email: stevenst@nsf.org

       NSF International
       789 N. Dixboro Road
       Ann Arbor, MI 48105
       (734)769-8010

1.2.2   U.S. Environmental Protection Agency (EPA)

The EPA Office  of Research and  Development, through the Urban Watershed Management
Branch,  Water Supply  and Water Resources  Division, NRMRL, provides administrative,
technical, and  QA guidance and oversight on all ETV WQPC  activities.  EPA reviews and
approves  each  phase of the verification project.   EPA's  responsibilities  with  respect  to
verification testing include:

   •   Review and approve verification test plan;
   •   Provide QA and technical review comments for verification report; and
   •   Review and sign verification statement.

The key EPA contact for this program is:

       Mr. Ray Frederick, Project Officer, ETV Water Quality Protection Center
       (732)-321-6627   email: frederick.rav@epa.gov

       U.S. EPA, NRMRL
       Urban Watershed Management Branch  (MS-104)
       2890 Woodbridge Ave.
       Edison, NJ 08837-3679

1.2.3   Testing Organization (TO)

The TO for the verification testing was consortium headed by  Scherger Associates. Mr. Dale A.
Scherger was the Project Manager (PM) for the TO. An experienced wastewater operator in the
Charlevoix, MI area, Mr. Randy Holecheck, collected all samples, prepared  and shipped the
samples to the laboratory,  and monitored the test site during the testing. Scherger Associates
developed the test plan, analyzed the data, and prepared the verification report. RTI Laboratories
performed  all of the analytical work. The laboratory was responsible for laboratory quality
assurance for the verification test through its QA group. NSF audited the laboratory prior to the
initiation of the test.

The responsibilities of the TO included:

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   •   Prepare the site specific VTP;
   •   Conduct verification testing, according to the VTP;
   •   Oversee the operation and maintenance of the system during ETV testing;
   •   Schedule and coordinate the activities of all verification testing participants, including
       establishing a communication network and providing logistical and technical support;
   •   Resolve any quality concerns encountered and report all findings to the VO;
   •   Manage, evaluate, interpret and report data generated by verification testing;
   •   Evaluate and report on the performance of the technology; and
   •   Document changes in plans for testing and analysis,  and notify the  VO  of any and all
       such changes before changes were executed.

The key personnel and contacts for the TO were:

Scherger Associates:
              Mr. Dale Scherger, P.E.
              Scherger Associates
              3017 Rumsey Drive
              Ann Arbor, MI 48105-9723
              (734) 213-8150 email: daleres@aol.com

RTI Laboratories, Inc.
              Mr. Brian Hall and Ms. Patricia Jennings
              RTI Laboratories, Inc.
              31628 Glendale Street
              Livonia, MI 48150
              (734)422-8000 email:  bhall@rtilab.com; pjennings@rtilab.com

1.2.4   Technology Vendor

The wastewater treatment technology evaluated was the Big  Fish System designed, assembled,
and installed by Big  Fish Environmental, LLC.  The vendor  was responsible for supplying the
equipment needed for the VTP, supporting the TO in providing needed information and facilities
for on-site  work,  and ensuring proper operation of the equipment during the verification test
period. Specific responsibilities of the vendor were:

   •   Initiate application for ETV testing;
   •   Provide input to the verification testing objectives to be incorporated into the VTP;
   •   Select the test site (Charlevoix site already in place);
   •   Provide complete  ready  to  operate  equipment, and the operations and maintenance
       (O&M) manual(s) typically provided with  the  technology (including  instructions  on
       installation, start-up, O&M) for verification testing;
   •   Provide any additional equipment, piping, pumps, valves, flow meters, tanks, etc. needed
       to setup the test (none required);

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   •   Provide any  existing relevant  performance data for the technology  if it has been
       tested/operated at other locations;
   •   Review and approve the site-specific VTP;
   •   Provide logistical and technical support;
   •   Operate the technology during the verification testing;
   •   Arrange for shipments of septage and other wastewaters or residuals to the facility during
       the verification test;
   •   Review and comment on the verification report;  and
   •   Provide funding for verification testing.

The key contact for Big Fish Environmental, LLC was:

              Mr. John  Campbell
              Big Fish Environmental, LLC
              12640 Taylor Road
              P.O. Box 528
              Charlevoix, MI 49720
              (231)547-4429     Email: info@bigfishenvironmental.com

1.2.5   ETV Test Site

As described  in Section 1.4, the verification test  was performed  at the Big  Fish facility in
Charlevoix, MI. Big Fish owns, operates, and maintains the septage processing system at this
location. As the owner Big Fish will:

   •   Provide space and utilities for the verification test; and
   •   Provide access to the existing  equipment, piping, pumps, valves, flow meters, tanks, etc.
       needed to setup the test.


1.3    Background and Objectives

Verification testing of wastewater treatment systems under the ETV WQPC is designed to verify
a technology's contaminant removal performance, and  the O&M of the commercial-ready
technology, following technically sound protocols and appropriate quality assurance and control.
A primary objective of the ETV is to measure the performance of these technologies through a
well-defined test plan that includes measurement of contaminants present in residential and non-
residential wastewaters, before and after application of the treatment technology.

The Big Fish Systems are designed to treat septage,  portable toilet waste, fruit processing waste,
wastewater treatment plant biosolids, waste  containing FOG and other high organic  strength
wastewaters to meet the regulatory requirements for discharge of treated effluent to a municipal
wastewater treatment system, while producing an Exceptional Quality (EQ) Class A Biosolids,
which can be used for agricultural or home garden use.  Actual numerical standards for discharge

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to municipal treatment systems will vary by location. The Big Fish System is designed to meet
pretreatment standards for discharge to most secondary wastewater treatment systems (typically
250-300 mg/L BOD5; 300-350 mg/L TSS;  50-70 mg/L NH3; and locally determined restrictions
for TP). The system that was tested in this verification is a full scale, commercially available unit
installed and operated by Big Fish in Charlevoix, MI. The effluent from the system discharges to
the City of Charlevoix Wastewater Treatment Plant (WWTP).

The objective of this Verification Test Plan (VTP) was to determine the performance attained by
the Big Fish System when used to treat a mixture of wastewaters.  These wastes contain organic,
solids, and nutrient constituents that can impact groundwater and  surface water if discharged or
disposed of untreated.  Reductions in contaminant  loads were  evaluated to  determine  the
effectiveness of the system to remove suspended solids, BOD, FOG, and nutrients (phosphorus
and nitrogen).  The production of biosolids  meeting one of the six treatment options for Class A
pathogen reduction and vector attraction reduction, as defined in 40 CFR 503.32 and 503.33,  and
the EQ designation in accordance with Tables 2-1 and 2-2 of the EPA Plain English Guide to the
EPA Part 503  Biosolids Rule, EPA/832/R-93/003, September 1994 was also verified during the
test.  The objective was achieved by implementing testing and monitoring procedures presented
in the VTP.

During the verification, the treatment system received septage from residential and commercial
septic tanks, portable toilet waste, fruit processing  waste, municipal WWTP secondary sludge,
and commercial wastes with FOG, containing solids,  organics, nutrients,  and other constituents
typically present  in  residential   and  commercial  septage and  related wastes.  During  this
evaluation, the term "wastewater" received at the test site is a combination of all of these waste
sources, in varying amounts. The treatment system  was challenged under a variety of hydraulic
loading conditions and contaminant loads during the 13 month test period. Waste generation  and
demand for treatment varied seasonally,  so the one-year test period covered high  and low
demand periods. The influent and effluent to/from the system were sampled and the samples
were analyzed for various  contaminants or  contaminant indicators, including BOD5; COD; TSS;
nitrogen compounds (TKN, NHa,  NO2+NO3), TP and FOG. The  results were used to  calculate
removal efficiencies and to determine the system treatment effectiveness. These parameters  and
other operating parameters (flow, pH, alkalinity, temperature, dissolved oxygen, per cent solids,
biosolids production) were monitored to meet the  ETV objective of providing an overall
assessment of the technology that can be used by  permit writers, buyers, and  users of the
technology.

The treatment  system was also observed for O&M characteristics, including the performance  and
reliability  of the equipment, the amount of personnel time required to operate the process, the
level of operator skill required,  the  maintenance required to maintain process operation  and
overall power and natural gas  consumption. Data were also  collected on the generation of
residues.

1.4    Test Site Description

The verification test was performed at the Big Fish facility in Charlevoix, Michigan, as  shown in
Figure 1-1.

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                                            .,  .     i  O7
                                            Alanson
                                 Harbor Springs
                                    O     _^/     riding

                                                                     Qrawav
                                                                       O "
                           Ei t U."4n
                              O
                                QF)
                     Central Lake    XTT"
                        O       V™_v
                                                                         Atlanta
                                                                           O
                                                                        NWTEQ200S
          Figure 1-1. Verification test site location map.

Big Fish has built a full-scale treatment system in Charlevoix to serve the surrounding area. Big
Fish owns, operates, and maintains the system as a private business under a permit issued by the
Michigan Department of Natural Resources and Environment (MDNRE) and in accordance with
the requirements of the  City of Charlevoix set forth in a letter  of determination.  The system
receives  septage waste from several  septic tank cleanout companies,  secondary sludge from the
City of Charlevoix WWTP, commercial  grease interceptor waste containing FOG from local
businesses, portable toilet waste and fruit processing waste. The current treatment system  has
been in operation for over three years. Treated effluent is discharged to the City of Charlevoix
municipal WWTP.  The MDNRE  permit and the  City of Charlevoix require that  monthly
operating reports be submitted to  document system performance. Table 1-1 shows the  permit
limits set for the Big Fish facility.
Table 1-1. Discharge Permit Limits for the Big Fish Facility
Parameter
Flow
pH
BOD5
TSS
Ammonia
TP
Sample Frequency
Every discharge period
Every discharge period
Every discharge period
Every discharge period
Every discharge period
Every discharge period
Sample Type
Meter
grab
Composite
Composite
Composite
Composite
Permit Limit
Report
pH 6 to 9
300 mg/L maximum.
350 mg/L maximum
65 mg/L (as N) maximum
3.01bs/day

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1.5    Historical Flow and Effluent Quality

The volume  of wastewater received and treated at the facility has  been collected as part of
normal facility operation and for reporting to the MDNRE. The system operates in a batch/semi
continuous mode.  Under normal operation, when the aerated equalization/receiving tanks are
full, wastewater is transferred to the completely mixed lime reaction/holding tank, where lime is
added to the wastewater to bring the tank contents to a pH of 12.  The contents are mixed for 24
hours to meet the pH holding time for Class A Biosolids vector attraction reduction, and are then
processed through the screw press over a 16-20 hour period (typical  process  time) to meet the
temperature requirement for Class A pathogen  reduction.  The filtrate from the screw press is
discharged to the aerobic treatment tanks, while the dewatered solids are collected in a bin for
subsequent transport of the biosolids to a storage area.  The filtrate displaces treated water in the
aerobic system and settling tanks  that had been in a  recycle mode  following  the previous
treatment period. The number of discharges per  month can vary from two or three, up to 10-15
during busy months. A summary of the average monthly flow rates and reported water quality
data for the period January 2007 through January 2008 (before the verification testing) is shown
in Table  1-2.

Table 1-2. Summary Flow Rate and Water Quality Data for Test Site (January 2007
           through January 2008)



Average
Maximum
Minimum
Average
Monthly
Effluent
(gal)
74,587
177,720
12,985
BOD5
(mg/L)

Inf.
3,300
4,380
1,980

Eff.
105
210
27
TSS
(mg/L)

Inf.
10,900
14,060
6,930

Eff.
123
266
15
NH3
(mg/L as N)

Inf.
Ill
407
26

Eff.
23
53
1.0

Inf.
310
652
32
TP
(mg/L as P)

Eff.
10
25
1.3
Eff
(Ibs/day)
1.6
2.8
0.04
  Calculated based on actual daily volume discharged and the effluent concentration associated with the discharge
  volume; effluent TP are in Ibs/day.
  Note: Influent and effluent water quality data was available from the monthly reports prepared for the MDNRE.
      These data show no violations of the MDNRE limits.

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          Chapter 2 Technology Description and Operating Processes


2.1    Technology Overview

The treatment of concentrated wastewaters, such as septage, presents a challenge to municipal
wastewater treatment systems due to the intermittent and highly variable volume of wastewater
being delivered. The Big Fish Environmental System has combined processes to treat these high
strength wastes, producing EQ Class A Biosolids and municipal strength wastewater, which can
be  discharged  for final treatment at a municipal  wastewater treatment system.   The system
combines solids treatment and handling with aerobic wastewater treatment to achieve the process
objectives.  An overview of the process steps is shown in Figure  2-1, Figure 2-2 provides a
process flow diagram for the entire process and Figure 2-3 shows the biosolids-processing
diagram. Each of the processes is discussed in detail in the following sections.
                       Receiving-

                       Screening—
                       Aerobic Introduction
                          j                           g
                       Homoginaion                     fc. | "]

                                                     PH
                       Vector Attraction Reduction and Pathogen       ^ _
                          I                           |  |
                       Screw Press Process	+•
                       Microbial Aerobic Process-
                          1
                       Quiescence
                                                x	 Waste W Eter Tre Sment Plant
                                                   - Future Possibility -
                                                    New Plants Discharge
                                                    to Ground Water
                                                 Big Fish Environmental.
                   Figure 2-1. Big Fish System overview of processing steps.

2.1.1    Truck Unloading, Screens, and Equalization

The Big Fish truck unloading is inside the main building adjacent to the aerobic treatment tanks
and other processing equipment. Trucks enter the unloading area and close the large roll-up door

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to control odors. The Big Fish site was designed with a biofilter for control of odors, but it was
not part of this verification. Trucks are unloaded by pressurizing the truck tank. A JWC Muffin
Monster Vi-in. (6 mm) screen is in line to remove any large inorganic particles or debris. A flow
meter records the  amount of wastewater unloaded from the truck, and an in-line pH  meter
monitors the wastewater to confirm the pH is greater than 4.0  and less than 9.0. The  screened
wastewater then  passes through a  de-grit  chamber  and  flows into the  first  11,000  gal
receiving/equalization tank.  This tank  is  aerated,  which  provides  mixing of  the  various
wastewater received and provides oxygen to maintain dissolved oxygen levels so that the stored
wastewater remains  aerobic. The first receiving/equalization  tank is  connected to a second
aerated  15,000 gal equalization tank. Large volume equalization is used to mix  the variety of
wastewater being received and to provide sufficient volume for the batch treatment in the vector
attraction and pathogen reduction treatment step  (lime treatment and subsequent  screw press
operation for solids separation).
                                         STOP-Retest  Ok-Tostreen
                                                Notok- Toinjudrid v
                                                   f   Hictery  \ii.i.i.i.
                                                    PraessMaferid 	*

                                                    Ciroistbn Aterrati\es  	V
                     dqlicdiallf aykhdE stridyprdilitedlrie ssalhoizedinat ace by
                     writhgfomBigEshEwrolmrta, ILC
Process Flow    5/21/07
Big Fish Environmental »
                   Figure 2-2. Big Fish System process flow diagram.
                                             10

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Once 20,000  gal  or more of  wastewater is accumulated  in the equalization  system,  the
wastewater is ready for transfer to the lime treatment system. A pump in the second equalization
tank is activated to transfer the wastewater to one of the lime treatment tanks.
                                         Aeration &
                                         Blending
Aeration
and
Lim e
Mix
                                        Lim e M ix 'A'
                                        Lim e M ix 'B'
                                        Flocculation
                                        Rotary Screen
                                          Thickener
                                           Screw
                                           Press
                                         N eutralize
                                         pH 7.5-8.0
                                          Big Fish
                                          P rocess
                                               Screw Press Flow  5/21/07
                                               Big Fish Environmental.
           Figure 2-3. Big Fish System biosolids process description.
2.1.2   Lime Treatment and Solids Separation - Biosolids Production

Figure 2-3 shows a process flow description of the biosolids treatment part of the  Big Fish
System. When a batch of wastewater is ready for treatment, the lime feed system is activated and
the equalization tank pump is started. Lime is added directly to the flowing wastewater as it is
transferred to a lime treatment tank. The lime  feed  system uses a standard lime feeder to
introduce hydrated lime directly into the flowing  wastewater. The lime dosage can be adjusted
by changing the lime feed rate and dosing time.
                                           11

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There are two 20,000 gal lime treatment tanks. Each tank mixes the material to ensure that all of
the wastewater and solids are brought to the elevated pH. Lime is added to the influent waste
mixture (septage, FOG, secondary biosolids, etc) to achieve pH 12 for a minimum of 2  hours,
and then is  held  at minimum  pH of 11.5 for a minimum of 22  hours. pH is monitored  and
recorded in the operation log to document that a pH of 12 or greater is maintained for at least two
hours.  Once these first pH criteria are  met, the wastewater continues to be treated in the lime
tank for a minimum of 22 additional hours. During this period, pH is monitored and recorded to
document that a pH >11.5 is maintained for the entire period.

After lime treatment is complete, the wastewater/solids are pumped from the lime treatment tank
through a flocculation tank and a rotary screen thickener to build solids particle size and thicken
the solids prior to entering the screw press.  Polymer is added  to the material  entering the
flocculation tank.  Typically, the  solids content after flocculation and thickening is 17-18%.
Filtrate extracted in the rotary  screen  thickener is discharged to a blending  tank. The  pH is
adjusted with muriatic acid to approximately pH 7.5 - 8.0.

The thickened sludge is processed in a screw press that also heats the solids to a minimum  of 72°
C (162° F) for a minimum of 20 minutes. The screw press is a hollow core design that has proven
very effective in increasing the solids content to 40-50%. The combination of the lime treatment
and the elevated temperature in the screw press meets the treatment requirements of the EPA
Biosolids Rule to produce EQ Class A  Biosolids. A boiler  supplies steam that  is circulated
through the  screw press to provide the  heat to  raise the solids temperature. The temperature of
the solids  exiting the  screw  press is measured and  recorded  to  document the operating
conditions. Solids are collected in a hopper and the transferred to an outside covered storage
area. The filtrate from  the screw press  is discharged to the first aerobic  treatment tank for
subsequent biological treatment.

2.1.3   Aerobic Treatment, Settling and Discharge

The aerobic treatment  system consists of a series of aerated tanks followed by  a quiescent
settling tank, a re-aeration tank, and two discharge tanks. The aerobic treatment tanks have a
combined volume of 27,000 gal. There is one 15,000-gal tank and eight (8) 2,000 gal tanks. Each
tank is aerated and has one or more White Knight™ microbial generators, in-the-tank breeding
columns that introduce, cultivate  and release select groups of microorganisms, installed  in the
tank. These  White Knight™ generators are suspended in  the aerated and well-mixed treatment
tanks   to  provide  a   source  of microorganisms  in addition   to  the naturally occurring
microorganisms in the suspended growth aerobic system.

A hatchery is used as part of the Big Fish system to supplement the quantity of microorganisms.
The hatchery is a 250 gal tank that holds "seed" material from the main aeration system.  The
microbial population is kept alive by periodic feeding with molasses or other organic food. This
simple system maintains an acclimated culture that can be used when the system is upset or to
start the system  after  cleaning. The large capacity  of the aeration tanks provides time for
biological treatment to  reduce the very high organic loadings that are normally still present in
septage type wastes, even after solids removal.
                                           12

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Treated water from the aerobic system enters a 2,000 gal settling tank. This is a standard tank,
with no special settling enhancements such as weirs or  sludge collecting rakes. The quiescent
settling tank  provides sufficient time for the solids to separate. The clarified wastewater then
enters the 2,000 gal re-aeration tank where the dissolved  oxygen is increased prior to discharge.
The aerated water then flows into two 2,000 gal discharge tanks. Solids that accumulate in the
settling tank  are periodically removed and placed back  into the receiving tank for processing
through the lime treatment and screw press processes.

When  liquid  is discharged from the screw press and  thickener, the water balance within the
system demands that water (effluent) be discharged from the  system. The  discharge pump is
activated to pump the effluent to the municipal sewer system. The effluent passes through a flow
meter to record the volume of the discharge and  a sampler on the  discharge  line collects  a
composite sample over the period of discharge.

As shown in the summary flow data (Table 1-2), the volume of wastewater delivered/treated can
vary from 13,000 to 178,000 gal per month. This means that the system operation can vary from
as few as one batch in a month to as many as 10-15 batches (2-30 operating days). Big Fish has
stabilized the operation  of the aerobic system by using a combination of internal  recycle,
organism augmentation, and food addition during periods of low demand and between actual
production/discharge days. When material is not being processed through the thickener  and
screw press, the discharge pump is not used and the liquid within the biological treatment system
is recycled back to the first aerobic treatment tank. Thus, liquid is always moving through the
aerobic, settling, re-aeration, and discharge tanks in the treatment system. Big Fish monitors the
system on a periodic basis to determine if additional organisms or food need to be added to the
system. The  White Knight™ microbial generators are  the primary  approach to  maintaining
healthy microorganism  populations during extended recycle periods. In addition, an  on-site
hatchery (aerated tank with organism from the main  system) is maintained and fed with molasses
or other food sources  to grow and maintain an adapted  culture of mixed  organisms. These
microorganisms can  be  added to the treatment  system if prolonged recycling  periods are
encountered  or if upset conditions occur. This  also  reduces  the time  needed to reestablish
operating conditions after a tank clean-out has been done and restarting is necessary. Further, if
the  organic  content  of  the main aerobic treatment  system gets very low due  to  lack of
septage/wastewater to be processed, supplemental food sources can be added to the system to
maintain a healthy population of microorganisms. These additions of  organisms and  food
generally are only needed in the winter months when incoming wastewater volumes are  very
low.

2.1.4   Operation and Maintenance

The Big Fish System is typically operated by one person in an eight hour day. During months
when demand is  high and three or more batches  per  week are being processed, additional
personnel are used to support the operation.

Incoming truckloads of septage are unloaded by truck drivers using an automated  system that
tracks the flow of material being unloaded and the pH of the incoming material. If the pH is out
                                           13

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of range (<4.0 or >9.0), the system automatically stops the unloading process. Material flows
into the screen and grit removal systems and enters an aerated, mixed, holding tank. This process
can occur anytime without an onsite operator being present.

While  some parts  of the system are  automated (discharge  pump from the effluent tank,
temperature monitoring of the screw press, etc.), the operator initiates all transfers from the
holding tank to the lime treatment tanks, starts the lime addition, and collects samples for pH
measurements, etc. After lime treatment is complete and pH is confirmed, the operator manually
transfers treated wastewater to the thickener, starts the polymer and acid pumps,  and starts the
screw press. Once  started, the process operates with only minimal oversight, while the operator
performs other support duties such  as  on-site laboratory tests (pH, TSS,  BODs, ammonia,
temperature, dissolved oxygen, etc.). The effluent discharge pump starts automatically when the
water level increases in  the discharge tank, and the automatic  sampler  starts collecting the
effluent composite sample.

The operator maintains a set of logs that are used to track all pertinent operating data. These data
included discharge flow  volume,  tank levels, biosolids production volume, electrical usage,
various temperature readings, pH, dissolved oxygen, etc. The programmable logic controller on
the screw press monitors and records the biosolids temperature and screw press speed. These
records document  the operating  conditions that are used to  evaluate system  performance  and
provide data for the monthly reports to regulatory agencies.

Major  maintenance activities  are  recorded  in  a  maintenance logbook. Routine  maintenance
activities such as cleaning, lubrication, clearing lines, etc. are not specifically documented.

2.2    Big Fish Environmental  Claims

Big Fish claims their treatment system can treat septage, portable toilet waste, fruit processing
waste,  municipal secondary sludge, and FOG wastes to produce  EQ Class A Biosolids and a
wastewater that meets criteria for discharge to municipal wastewater treatment systems as shown
in Table 2-1.

Table  2-1. Big Fish System Wastewater Treatment Claims

            Parameter                     Effluent Characteristics after Treatment
  BOD5                                                 < 300 mg/L
  TSS                                                  < 350 mg/L
  NH3-N                                              < 65 mg/L (as N)
  TP                                                 5-15 mg/L (as P)
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                    Chapter 3 Methods and Test Procedures
3.1    Verification Test Plan and Procedures

This section summarizes each of the testing elements performed during verification, including
sample collection methods, analytical protocols, equipment startup, and equipment operation.
QA/QC procedures and data management approach are discussed in detail in the VTP.

The VTP, Verification Test Plan for Big Fish Environmental, LLC,  July 2008 (2), is included in
Appendix B. The  VTP details the procedures  and analytical  methods used  to  perform  the
verification test, including  the various tasks designed to verify the performance of the Big Fish
System and to obtain information on O&M requirements. The VTP covered two distinct phases
of fieldwork: evaluation of the startup of the unit and a 13 month verification test that included a
monthly sampling program. The verification test was completed between September 2008 and
October 2009.

Given the nature of the wastes received at this facility and its location in northern Michigan, it
was expected that a significant seasonal variation in wastewater volumes would  occur. Septic
tank pumping, portable toilet use and the generation of fruit processing waste typically only
occurs from  April through October/November due to the cold temperatures in the winter and the
presence of seasonal dwellings in the service area. Based on these factors, the initial test program
sampling requirement (composite  samples over four days,  once per month) was modified for
winter months to allow for two batches of material to be processed on different weeks rather than
in one week.  Under this  approach, the number of BODs, COD, TSS,  FOG, and alkalinity
samples (samples that are not composited over several days) remained at two per month, and the
nutrient samples were  actually increased from one composite per month  to two samples  per
month of both influent and effluent. Sufficient wastewater was available during the verification
test such that the "normal" two batch weekly composite approach was achieved during twelve of
the 13 sampling periods. One month, March 2009, included only a single sampling event, i.e. one
batch of wastewater was processed and sampled.

3.2    Installation and Startup Procedures

The Big Fish System was installed and  operating at the test site for over two years prior to the
verification test.  The System had  been  treating various wastewaters and meeting the State of
Michigan  discharge permit limits. The  existing system was in  use on a regular  basis to treat
customer wastes. Therefore, the test plan did not include or require observation  of the actual
installation of the tanks and equipment.

In the  planning process, Big Fish agreed to demonstrate startup of the system  during a low
demand month in either  January or  February. Therefore, the system  cleaning  and  restart
procedure described below were developed to allow  observation of system startup,  which should
be representative of a new  system  startup or a restart of an existing  system that has experienced
                                          15

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an upset condition. Big Fish emptied the aerobic treatment tanks, the settling  tanks, and the
discharge tank. These tanks were cleaned, visually inspected, and placed back into service. Once
the System was clean, it was restarted using normal startup procedures.

The tank cleaning procedure included pumping all of the wastewater out of the aerobic treatment
tanks, the settling tank, re-aeration tank, and final discharge tank. This wastewater was sent to
the municipal treatment system. This work was accomplished in  one day. The tanks were then
rinsed and cleaned to remove solids buildup in the tanks. Once the tanks were clean, they were
filled with a combination of processed wastewater from the screw press process. Microorganisms
were seeded to the aerated tanks by adding  1500 gal of material from the  hatchery tank. The
White Knight™ microbial generators were hung in place in accordance with standard operating
practice.

The startup period was completed in less than thirty days, so no special  sampling under the ETV
plan was required. The normal January 2009 verification sampling was performed three weeks
after startup. The  Big  Fish operators performed daily field tests (pH,  dissolved oxygen and
temperature) and settleable solids were monitored three times per week  during the startup. Table
3-1 shows the startup monitoring data and observations recommended by  Big Fish. All field test
data collected during startup were recorded in the logbook. Visual observations and any changes
made to the  system were recorded in the logbook to track the startup process.

Big Fish management and the on-site operator determined that the startup  was  complete  after
approximately three weeks and,  after consultation  with  Scherger  Associates  and NSF, the
verification testing was resumed. This decision was based on reviewing the operating conditions
and the  effluent quality, which indicated the system was stable and operating in accordance with
the Big Fish specifications.

3.3   Verification Testing

3.3.1    Introduction

The Big Fish  System was designed to treat septage and similar wastewater to  meet typical
discharge standards to  municipal  treatment  systems,  as  established by  state  and local
governments. This verification test was designed to  determine the effluent quality achieved by
the Big  Fish treatment system. This was achieved for liquid effluent by  collecting and analyzing
samples of the treated water discharged from the aerobic treatment system. Biosolids quality was
determined by monitoring and evaluation of operating parameters according to the published
Federal  Rule to demonstrate that EQ Class A Biosolids criteria were  met for all  dewatered
biosolids produced.
                                           16

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Table 3-1. Startup Monitoring - Typical Big Fish System Recommended Schedule
Sample Schedule
Parameter
Flow rate (gpd)
pH
Temperature
Settleable solids
Dissolved oxygen
Frequency
Daily
Daily
Daily
3/week
Daily
Sample
Type
Meter
Grab
Grab
Grab
Grab
Recordkeeping
Recorded by time and date
Recorded by time and date
Recorded by time and date
Recorded by date
Recorded daily during startup
3.3.2   Objectives

The objectives for the experimental design for this verification test were:

   •   Determine the level of treatment performance of the Big Fish  System in removing key
       target constituents, including TSS, BOD5, COD, FOG, TKN, NH3, and TP;
   •   Determine if the biosolids meet EQ Class A requirements;
   •   Document the basic operation and maintenance requirements during the test;
   •   Document the solids residuals produced by the system; and
   •   Document the chemical use and power consumption of the system.

3.3.3   Verification Test Period

The test period began in September 2008 and continued for 13 months.  No more than 36 days of
upset  conditions or downtime was allowed by the protocol  during the verification test period.
Sampling  was  suspended from  mid-March  through  April  2009 due  to  reduced  incoming
wastewater volume, thought to be the result of the economic downturn. Sampling resumed in
May 2009. A system upset occurred in May due to a very high organic content waste entering the
system, which was reflected in the May samples. The system was back to normal operation
within a couple of weeks and the June sampling showed that the system had recovered from the
upset. The test included a full range of flow conditions and influent characteristics.  Historical
data and general information available about the test site indicated that with reasonable spacing
of sampling, all types of conditions were monitored over the 13 month period.

3.3.4   Flow Monitoring

The volume and type of waste  from each truckload received at the  site  was recorded  for
characterization. When the system was ready for treatment of a batch of wastewater, the volume
of liquid placed in the lime treatment tank was recorded,  based on  the time the pump was
operated and the wastewater level  in the lime treatment tank after the transfer was complete.

The effluent discharged to  the municipal  collection system from the Big  Fish System was
monitored by a Seametrics electromagnetic flow meter on the discharge line to the  municipal
                                          17

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system. The discharge volume was recorded and provided the flow record for the verification
test.

3.3.5  Sampling Locations and Procedures

Sampling locations included  the untreated wastewater  influent  (mixed wastewater  in  the
equalization tank) and the final treated effluent discharged to the municipal  treatment system.
The untreated wastewater was collected as grab samples from the equalization tank prior to the
transfer of a batch of wastewater to the lime treatment tank. This mixed wastewater represented
the entire mixture of wastewater being treated for that batch,  and was  matched  with  the
discharged wastewater that occurred when the lime treated wastewater was processed through
the screw press  and the resultant liquid processed through the aerobic treatment system. The
treated effluent was collected using the existing composite  sampler located on the discharge line
just prior to the effluent entering the municipal wastewater collection system. This location is the
official sampling location for the facility operating permit. Composite samples were collected for
the duration  of the  discharge, which was  typically  12-16  hours, but  could extend  longer
depending on batch size and discharge rate. The composite  sampler collected equal aliquots on a
time basis, which was equivalent to a flow weighted composite sample as the discharge was
pumped to the municipal system at a constant flow rate.

In  addition  to the influent and  effluent sampling  locations, the  individual truckloads  of
wastewater were monitored for volume and pH, as previously described, and were  available
along with a description of the type wastewater being received.  Samples were collected  for pH
from the lime treatment tank to document the pH and time of treatment of the tank contents to
confirm the requirements for Class A Biosolids were met.  After lime treatment, the wastewater
pH was adjusted to 7.5 - 8.0 using muriatic acid, and the adjusted pH was recorded. Temperature
was monitored at the screw press to document that the biosolids were heated to the required
greater than 72° C for a minimum of 20 minutes.

Both grab and composite samples were collected during all sampling events. The type of  sample
depended on the requirements and the holding time for each analysis. Grab samples at both the
influent and effluent sample locations were collected each sample day  for pH, temperature,
dissolved oxygen, and FOG. Grab samples of the influent mixed wastewater were also collected
for TSS, BOD5,  COD, alkalinity, TKN, NH3-N, NO2+NO3, and TP. Composite samples of the
discharge were collected each  sampling day for TSS, BOD5, COD, Alkalinity, TKN, NH3-N,
NO2+NO3, TP, chloride and sodium. A refrigerated automatic composite sampler was used to the
collect the effluent composite  samples.  For all  monthly  sample periods except March 2009,
where  two consecutive  days  of discharge and  sampling occurred,  an  aliquot of the daily
composite sample was taken each day  to create a two-day  composite sample for TKN, NH3-N,
NO2+NO3, TP, chloride and sodium. Table 3-2 shows a summary of the sample collection and
analysis program.
                                          18

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Table 3-2. Summary of Sampling Collection and Analysis
Parameter
pH
T
FOG
TSS
BOD5
COD
Alkalinity

TKN
NH3-N
NO2 +NO3
TP
Sodium

Chloride

Sample
Type
Influent
Grab
Grab
Grab
Grab
Grab
Grab
Grab

Grab
Grab
Grab
Grab
Grab

Grab

Sample Type
Effluent
Grab
Grab
Grab
24-hour composite
24-hour composite
24-hour composite
24-hour composite
9 6 -hour
composite(3)
96-hour
composite1-3-1
96-hour
composite1-3-1
96-hour
composite(3)
96-hour
n't
composite^ ;
96-hour
•, (3*1
composite
Frequency
Daily(1)
Daily(1)
Daily(1)
Daily(1)
Daily(1)
Daily(1)
Daily(1)

One per event(1)
One per event1-1 -1
One per event1-1-1
One per event(1)
One per event1-1 -1
r
One per event1-1-1
r
Number
25
25
25
25
25
25
25

13
13
13
13
13

13

Estimated
Number of
Samples (2)
50
50
50
50
50
50
50

26
26
26
26
26

26

(1)  Influent grab samples were collected when the process was started by filling the batch lime tanks, normally
    twice per week on Monday and Wednesday. The two influent grab samples were then composited for
    parameters listed as one per event. Effluent samples were composited when a discharge occurred usually form
    Tuesday afternoon to Wednesday morning, and from Thursday afternoon to Friday morning. Effluent composite
    samples from the two discharges were composited into a single composite for those parameters listed as one per
    event.
(2)  Number of samples is based on two (2) sampling locations, untreated influent and the final treated effluent.
(3)  A composite was made by taking the 24 hour daily composite, preserving it, and combining the preserved daily
    composite samples over a five-day period to form a single, event composite covering the treatment of two
    batches.

Dewatered biosolids were produced from the screw press. Treatment conditions were designed to
produce Class A Biosolids, according to EPA requirements (40 CFR Part 503) which  are based
on treatment conditions and  include pathogen reduction and vector attraction reduction.  While
this  designation is not based on detailed analysis  of the biosolids,  Class A designation does
require testing for fecal coliform with the frequency based biosolids  production. Fecal coliform
were monitored by Big  Fish, using the same  laboratory that was performing the verification
analysis, and were reported to the State of Michigan in their annual report. These data  are in
Appendix  A. While routine  analyses were not required  of the  biosolids,  the verification test
included analysis for  heavy metals and  moisture/solids content.  Grab  samples of the biosolids
were collected twice during the verification and were analyzed for percent solids and metals (As,
                                              19

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Cd, Cr, Cu, Hg, Pb, Ni, Se, Zn). The heavy metals data were to verify that the EQ requirements
were achieved,  as they  are based on  heavy metals  concentration. The  volume of biosolids
produced by the screw press was recorded for each sampling event.

3.3.6   Sampling Schedule

The verification test consisted of twenty-five (25) sampling days over the 13-month test period.
In  the original test plan design, sampling varied during high and low flow months. During high
flow months (six months during the test), the two days of sampling for the month were designed
to  occur on consecutive processing days with batch sizes of a minimum of 5,000 gal treated and
discharged per day. During the remaining six months (lower flow demand periods), due to the
anticipated lack of wastewater volume, the two sampling days were allowed anytime the system
was treating wastewater and discharge occurred, even if they were not consecutive days. As
stated in the VTP, it was expected  that the  schedule may  require adjustment based on actual
incoming waste loads to the faculty.

Wastewater volumes and planning of incoming loads allowed for the normal  two consecutive
batch processing approach to be performed during all of the months except March and April
2009. In March only one batch of processed wastewater could be  sampled, and sampling was
suspended for the month of April 2009 because of low influent volume. Once waste delivery and
sampling resumed in May 2009, there was sufficient wastewater volume  to use the normal
processing  approach contained in the ETV protocol,  i.e.  processing  and sampling  of two
consecutive batches. Influent samples were taken on the first and third days of the week,  and
effluent samples (composite over the discharge time) were started on day two and four, generally
being completed by the morning of the next day (days three and five).

Test Schedule:       September 22-26, 2008
                    October 13-17, 2008
                    November 10-14,  2008
                    December 8-12, 2008
                    January 26-30, 2009
                    January 26-30, 2009
                    February 16-20, 2009
                    March 9-11, 2009
                    May  18-22,2009
                    June 22-26, 2009
                    July 20-24, 2009
                    August 17-21, 2009
                    September 21-25, 2009
                    October 19-23, 2009
                                         20

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3.3.7  Sample Preservation and Storage

The sample bottles required for the various analyses were provided by RTI, the subcontracted
laboratory for this work. Table 3-3 shows the bottle types, sample size, and preservation required
for each parameter. The bottles were provided with preservative, as needed, and were labeled by
analysis type. The samples were logged, placed in coolers with ice to maintain temperature, and
shipped to the laboratory by overnight express  shipment.
Table  3-3. Preservation, Bottle Type, and Sample Size by Analysis
 Sample Matrix	Analyses	Bottle Type/Size	Preservation/Holding Time
Wastewater pH
T
FOG
TSS
Alkalinity
BOD5
COD
TP
TKN
NH3-N

NO2+NO3
Sodium
Chloride
Solids Metals
Percent solids
Plastic 250 mL
Plastic 250 mL
Glass 1 L
Plastic, 200 mL
Plastic, 250 mL
Plastic, 500 mL
Plastic, lOOmL
Plastic, 500 mL
Plastic, 500 mL
Plastic, 500 mL

Plastic, 500 mL
Plastic 100 mL
Plastic lOOmL
Plastic or glass,
250 mL or larger
Plastic or glass, 500 mL
None, analyze immediately
None, analyze immediately
Cool to 4° C,
pH < 2 H2SO4, 28 days
Cool to 4° C, 7 days
Cool to 4° C, 7 days
Cool to 4° C, 24 hours
Cool to 4° C,
pH < 2 H2SO4, 28 days
Cool to 4° C,
pH < 2 H2SO4, 28 days
Cool to 4° C,
pH < 2 H2SO4, 28 days
Cool to 4° C,
pH < 2 H2SO4, 28 days
Cool to 4° C,
pH < 2 H2SO4, 28 days
pH<2HNO3, 180 days
Cool to 4° C, 28 days
Cool to 4° C, 6 months
Cool to 4° C, 7 days
3.3.8   Chain of Custody

Chain of Custody was maintained for all samples collected during the verification test and sent to
the outside laboratory. The  TO operators filled  out  a  chain of custody form  for each set of
samples. The form was signed and dated for each set of  samples delivered to RTI. The receiving
technician acknowledged receipt of the samples by signing the chain of custody form.  All copies
of the chain of custody records were maintained by the TO and by the chemical laboratory for all
samples.  Copies of the completed chain of custody  forms were included with all  laboratory
reports transmitting final analytical results.
                                           21

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3.4    Analytical Methods

All analytical methods used during the verification test were USEPA approved methods(3'4)
                                                              or
                                                     ,th T^J:^	(5)
methods from Standard Methods for the Examination of Water and Wastewater, 20  Edition'
All were in the Test Plan  and QAPP approved by USEPA.  Table 3-4 shows the analytical
methods used for the verification test and the typical detection limits that were achieved by these
methods.
Table  3-4. Analytical Methods
 Sample Matrix
Analyses
Reference Methods
Reporting Detection Limit for
          Matrix
Liquid pH
T
DO
FOG
Alkalinity
TSS
BOD5
COD
TP
TKN
NH3-N
NO2 + NO3
Chloride
Sodium
Solid Metals
Total solids
SM 4500-H B
SM2550B
SM 4500-O G
EPA 1664A
SM 2320 B
SM 2540 D
SM5210B
EPA 410.4
SM4500PF
EPA 35 1.2
SM 4500 NH3 D
SM 4500 NO3 H
EPA 300.0
EPA 200. 8
EPA 200. 8/245.1
SM 2540 B
N/A
N/A
0.5 mg/L
3.0
10 mg/L
3 mg/L
3 mg/L
20 mg/L
0.05 mg/L
0.1 mg/L
0.04 mg/L
0.02 mg/L
1.0 mg/L
0.5 mg/L
Varies by metal and solids content
10 mg/kg
Three parameters were measured in the field - pH, dissolved oxygen, and temperature. RTI
conducted all other analyses. All work was performed in accordance with QA/QC protocol as
described in the Quality Assurance Project Plan developed for the verification test.

3.5    Operation and Maintenance

The  Big Fish System  was  operated during the verification test by  Big Fish personnel in
accordance with the Operating Manual. The TO monitored the system during the test, including
review of operating conditions, maintenance performed and operating records.
                                          22

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The  Operating Manual,  which  provided  detailed information for each unit operation,  was
available for  review  before  the verification  test began. The detailed instructions included
descriptions of the operating data (pH, times, temperature, flows,  etc.) that  are recorded in the
facility operating log. A field logbook was maintained by the TO to provide written notes for
each visit to the site.

Any major  maintenance  activity performed by Big Fish personnel was logged in an on-site
maintenance log and was reviewed by the TO.

The Big Fish operators recorded the level in each chemical solution tank (acid and polymer) at
the end of each treatment period and recorded when  a new tank of solution was prepared or
placed into use.  The  quantity of lime used was determined by recording the length of time the
lime feeder was operating and calculating total pounds  fed to the batch of material being treated.
These records were reviewed by the TO on a monthly basis. Chemical use during the verification
test was determined form these records.

Power consumption was  monitored on a  daily basis. A standard electrical power meter  was
already installed at the site. Meter readings were taken daily throughout the test and recorded in
the operating logbook. The electrical meter included the power by all the equipment and  also
included power for lighting, heater fans, and other general power used in the building dedicated
to the  System. The natural gas used to heat  the boiler that feeds the  screw press was  also
monitored from the gas meter at the site, and the readings were recorded in the logbook.

Any other observations on the operating condition of the unit, or the test system as a whole, were
recorded in the logbook.

Odor, if any, was observed on each TO visit to the site (minimum of three  to four days per month
while processing). Also, any citizen complaints are part of the operating record and are included
in the verification test record.

The plant operating and maintenance logbooks provided the information to validate the flow and
operating conditions  during the test periods. They served as the  basis for making qualitative
performance determinations regarding the unit's operability and the level/degree of maintenance
required. These plant O&M logs were maintained by Big Fish personnel and reviewed by the TO
throughout the verification test.
                                           23

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                         Chapter 4 Results and Discussion
4.1    Introduction
This chapter presents the verification  test results for the Big  Fish  System, including the
laboratory results for influent and effluent samples, operating data for the facility during the test,
and observations on the O&M of the system during startup and normal operation. Supporting
laboratory reports, spreadsheets and logs are available in Appendices E, and F.

4.2    Verification Test

The  verification test officially  started in September 2008, with initial  characterization data
collection performed in August 2008. All results for the  remainder of the test  period  were
considered part  of the verification  test.  The startup evaluation described in Sec. 3.2 was
performed in the middle of the verification test  four  months  after the  verification started and
conducted during a  low demand period to minimize the down time encountered during the
verification testing process.

4.2.1    Verification  Test - Flow Conditions

The  Big Fish System operates as a batch type process with waste material  from the waste
receiving (holding) tanks being pumped to the lime treatment tank on  a batch by batch basis.
Once the lime treatment is complete and the proper pH conditions are confirmed, the lime treated
waste is pumped to the thickener after neutralization by acid and polymer addition. The clarified
liquid from  the  thickener flows to the  aeration  system and the thickened  solids  are pumped
through the heated screw press. The liquid from the screw press (liquids from solids dewatering)
also flows to the aeration system and the biosolids are discharged into a storage hopper.

The  facility has a  flow meter that measures all  water discharged from  the facility to the
municipal sewer system. The total flow from the facility includes not only  the liquid from the
thickener and screw press operation, which is the actual liquid from the solids removal processes,
but also all other water used in the process and in  the facility. Water used for  wash-down and
equipment cleaning goes through the meter as well as the water from the treatment process. In
order to obtain a more direct measurement of the flow of liquid from  the treatment of incoming
waste material, the  actual volume of lime treated material  pumped from the lime tank to the
thickener and screw press was recorded. Also,  the volume  of material transferred from the
holding tank to the lime treatment tank was recorded so that  lime use could be matched to actual
waste volume treated in the lime system. There was no "dilution" effect  on the effluent samples
collected and analyzed as the effluent samples  included only  wastewater that  was discharged
from the treatment tanks.

Table 4-1 shows the volumes of lime treated material processed for each batch processed through
the thickener and  screw press.  These batches  represent the  time periods when  verification
sampling and analysis were performed and are typical of the batches the facility processed prior
                                           24

-------
to the verification test. The actual total discharge to the municipal system is also shown in Table
4-1.  Observation of the  facility operation  indicates  that these are reasonable batch sizes to
process in this size facility. The smallest batch size was 6,886 gal, which was larger than the
minimum of 5,000 gal specified in the test  plan. The volume of the waste material transferred
from the holding tank to the lime treatment system is shown in Table 4-13 with the lime use data.
Table 4-1.  Batch Treatment Volume and Discharge
               Date
     Influent
Effluent
       Lime Tank
Transfer to dewatering and
   liquid treatment (gal)
   Flow Meter
Discharge to City
      (gal)
09/22/08
09/24/08
10/13/08
10/15/08
11/10/08
11/12/08
12/08/09
12/10/09
01/26/09
01/28/09
02/16/09
02/18/09
03/09/09
05/18/09
05/20/09
06/22/09
06/24/09
07/20/09
7/22/090
08/17/09
08/19/09
09/21/09
09/23/09
10/19/09
10/21/09
Number of

batches
Mean
Median
Maximum
Minimum
Std. Dev.
09/24/08
09/26/08
10/15/08
10/17/08
11/12/08
11/14/08
12/10/09
12/12/09
01/28/09
01/30/09
02/18/09
02/20/09
03/11/09
05/20/09
05/22/09
06/24/09
06/26/09
07/22/09
07/24/09
08/19/09
08/21/09
09/23/09
09/25/09
10/21/09
10/23/09








12,240
14,998
15,484
10,301
11,420
15,523
6,886
10,993
10,627
16,035
12,304
13,940
16,190
11,442
13,930
12,581
11,767
12,209
13,187
12,117
13,078
12,301
10,249
10,593
17,185

25

12,703
12,301
17,185
6,886
2,330
15,240
19,671
14,860
10,769
17,523
19,684
10,826
13,646
11,943
16,767
14,340
18,507
16,196
15,436
21,068
22,957
16,145
23,053
19,838
16,992
20,095
20,456
17,589
17,942
19,357

25

17,236
17,523
23,053
10,769
3,372
                                           25

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4.2.2   BODs/COD, TSS, and FOG Results and Discussion

Tables 4-2 and 4-3 present the influent and effluent BOD5, COD, TSS and FOG concentrations
measured during the  verification test. Over  the course of the verification, the influent waste
material had a mean BOD5 of 3,300 mg/L and median concentration of 2,700 mg/L with a range
of 48 to 15,000 mg/L. The mean influent COD was 17,500 mg/L and the median was 20,000
mg/L with a range of 3,700 to 31,000 mg/L. Influent TSS ranged from  3,700 to 28,000 mg/L
with a mean value of 13,700 mg/L and a median of 14,000 mg/L. The influent FOG ranged from
34 to 2,200 mg/L with a mean of 370 mg/L and a median of 140 mg/L. These concentrations
showed that the septage material and other wastes  (holding  tank waste,  fruit waste,  municipal
sludges) were highly concentrated waste materials, as expected.  The concentrations were in the
typical concentration ranges expected in septage type materials.

As shown in Table 4-2, the BODs concentration in the final treated effluent had a mean value of
75 mg/L and a median concentration of 72 mg/L with a range of 7 to 190 mg/L. The Big  Fish
System achieved  a  mean BOD5 removal of 97%. The treated effluent had  a mean COD
concentration of 270 mg/L, a median concentration of 280 mg/L with a range of 25 to 400 mg/L.
The mean COD removal was 98.4%.

The effluent TSS mean concentration was 55  mg/L with a median concentration  of 43 mg/L and
a range of  10 to 170 mg/L.  TSS removal was very high during the verification with  a mean
removal of 99.6%, a median removal of 99.6%, and a range of 98.3% to 99.9% removal.

The system removed most of the FOG present in the waste material to below the detection limit
of 3  mg/L.  Effluent concentration was below 3 mg/L on 18 of the  25  samples collected and
analyzed. The mean FOG concentration was calculated to be 5.1  mg/L,  based  on  setting
concentrations  below  the detection limit to the  reporting limit  of 3 mg/L. The  median
concentration was <3 mg/L. The highest concentration in the discharge was 28 mg/L.

All of the data collected for the 13 months when verification test sampling occurred are included
in  Tables 4-2 and 4-3. However, data from the months of March and May 2009 are excluded
from  the summary statistics.  The ETV  protocol calls for  removing upset  periods from the
summary statistics, but all data is to be reported. As discussed below, an  upset occurred in May
2009 and the BODs results for the March effluent sample appeared suspect. Therefore, these data
are not included in the summary statistics. There was no sampling in April 2009 due to business
conditions at that time. Suspension of sampling for the month of April was approved by NSF and
EPA.

There was an upset period in May 2009 when BOD5 removal was reduced to between 43% and
74% with effluent concentrations of 5,500 mg/1 and 5,700 mg/L in the two batches treated. COD
concentrations  in  the effluent also increased to  11,000  mg/L and  8,600 mg/L, as  would be
expected. It is believed the cause of this upset was due to the addition of highly concentrated
fruit waste  to the untreated  material in  the holding tank. This increased the influent BOD5
concentration to 21,000 mg/L and the COD to 31,000 mg/L. This very high organic loading was
                                          26

-------
a  seven-fold increase over  the  mean  influent BOD5 concentration  measured  during the
verification test. Following the upset, the system was  operated in the normal aeration recycle
mode without additional new material being processed or effluent discharged until June 1, a ten-
day period.  A  batch  of  material was then  processed from the holding tank and  discharge
occurred. This effluent showed a BOD5 of 810 mg/L (facility generated data), which indicated
the system was recovering, but not yet back to the more typical discharge concentrations of 50 to
100 mg/L BODs. The system continued to operate with the aeration tanks in the normal recycling
mode. Ten days later, on June 10, another batch of waste material was processed and the effluent
BOD5 concentration dropped to 110 mg/L. A  subsequent batch of material processed on June 12
confirmed that the system had returned to normal operating conditions with the effluent having a
BODs concentration of 96 mg/L. The ETV verification  testing for June was performed the week
of June 22 and  the data, presented in Table 4-2, shows that the system had recovered from the
shock to the system due to the high organic loading the week of May 18th.

The March 2009 ETV data for the batch material treated from March 9 to 11, 2009 indicated that
there  may be a  problem with BOD5 removal. The reported BOD5 concentration in  the effluent
was 930  mg/L.  However, the COD concentration was reported to be 400 mg/L, less than the
BOD5 concentration and in the normal range  of previous measurements. The TSS concentration
in the effluent was also in the normal range.  Two subsequent batches processed on  March 25th
and 27th  showed effluent  BOD5 of 60 and 59 mg/L (facility generated data). It would appear that
the effluent BOD5 results for the verification  test batch in March were an anomalous value and
most likely no upset had occurred. Give the uncertainty of this value, these data are not included
in the summary  statistics presented in Table 4-2.
                                          27

-------
Table 4-2. BOD5 and COD Results
       Sample Date
          BOD5 (mg/L)
  Influent
Effluent
Influent    Effluent
                                     Removal
                                                            COD (mg/L)
Influent    Effluent
                                                                                          Removal
09/22/2008 09/24/2008
09/24/2008 09/26/2008
10/13/2008 10/15/2008
10/15/2008 10/17/2008
11/10/2008 11/12/2008
11/12/2008 11/14/2008
12/08/2009 12/10/2009
12/10/2009 12/12/2009
01/26/2009 01/28/2009
01/28/2009 01/30/2009
02/16/2009 02/18/2009
02/18/2009 02/20/2009
03/09/2009 03/11/2009
05/18/2009 05/20/2009
05/20/2009 05/22/2009
06/22/2009 06/24/2009
06/24/2009 06/26/2009
07/20/2009 07/22/2009
07/22/2009 07/24/2009
08/17/2009 08/19/2009
08/19/2009 08/21/2009
09/21/2009 09/23/2009
09/23/2009 09/25/2009
10/19/2009 10/21/2009
10/21/2009 10/23/2009
Number of Samples
Mean
Median
Maximum
Minimum
Standard Deviation
1,300
2,600
5,200
3,600
2,800
2,800
15,000 (1'5)
2,600
48 0)
110 (2)
1,600 (1)
3,000
4,100 °'3)
21,000 (1'4)
10,000 (4)
4,800
2,500
2,200
4,800
2,100 (1)
4,000
2,400
3,700
4,100 (1)
2,400(1)
22
3,300
2,700
15,000
27
2,900
51(1)
110
29
72 0)
97
83
74 0)
41
30
r\*i (132)
110
130
930 °'3)
5,500 (1'4)
5,700 (4)
99 0)
72
62
130
190 (1)
7(D
26(1)
44 0)
57(1)
110 0)
22
75
72
190
7
44.1
96.1
95.8
99.4
98.0
96.5
97.0
99.5
98.4
37.5
75.5
93.1
95.7
77.3
73.8
43.0
97.9
97.1
97.2
97.3
91.0
99.8
98.9
98.8
98.6
95.4
22
97.7
97.2
99.8
37
NA
22,000
22,000
31,000
26,000
24,000
14,000
18,000
20,000
6,400
3,700
6,300
5,600
36,000 (3)
31,000(4)
20,000 (4)
18,000
6,200
25,000
20,000
18,000
8,200
21,000
21,000
28,000
20,000
22
17,500
20,000
31,000
3,700
8,032
25
380
210
250
400
390
180
270
210
290
300
320
400 (3)
11,000(4)
8,600 (4)
180
380
220
360
290
160
200
320
240
400
22
270
280
400
25
95.5
99.9
98.3
99.3
99.0
98.3
97.2
99.0
98.7
96.7
92.2
95.2
94.3
98.9
64.5
57.0
99.0
93.9
99.1
98.2
98.4
98.0
99.0
98.5
99.1
98.0
22
98.4
98.4
99.9
92.2
NA
NA - not applicable
(1)  Dissolved oxygen depletion for these BOD5 results was less than the 2 mg/L guidance when adjusted for the
    seeded blank. Results should be considered an estimate of the BOD5 concentration. See QA Section 4.5.3 for
    discussion.
(2)  Lab reported data as influent of 27 mg/L and effluent of 110 mg/L. It is believed that the BOD5 samples were
    incorrectly labeled based on review of the other sample results - e.g. TSS and COD.
(3)  March 2009 data is excluded from the summary statistics as the BOD5 effluent data is suspect or, if correct,
    indicate an upset occurred. There were no samples collected in April 2009.
(4)  Per protocol, data from May 2009 when an upset occurred are not included in the summary statistics, but are
    reported for informational purposes.
(5)  Influent sample on 12/8/2008 missed holding time by one day due to snow storm delivery delay.
                                                 28

-------
Table 4-3. TSS and FOG Results
           Date                      TSS (mg/L)
FOG (mg/L)
  Influent      Effluent    Influent   Effluent   Re™°7al    Influent   Effluent    Rem°Val
9/22/2008 9/24/2008
9/24/2008 9/26/2008
10/13/2008 10/15/2008
10/15/2008 10/17/2008
11/10/2008 11/12/2008
11/12/2008 11/14/2008
12/8/2009 12/10/2009
12/10/2009 12/12/2009
1/26/2009 1/28/2009
1/28/2009 1/30/2009
2/16/2009 2/18/2009
2/18/2009 2/20/2009
3/9/2009 3/11/2009
5/18/2009 5/20/2009
5/20/2009 5/22/2009
6/22/2009 6/24/2009
6/24/2009 6/26/2009
7/20/2009 7/22/2009
7/22/090 7/24/2009
8/17/2009 8/19/2009
8/19/2009 8/21/2009
9/21/2009 9/23/2009
9/23/2009 9/25/2009
10/19/2009 10/21/2009
10/21/2009 10/23/2009
Number of Samples
Mean
Median
Maximum
Minimum
Standard Deviation
26,000
14,000
28,000
13,000
15,000
11,000
13,000
15,000
4,400
7,100
3,700
5,800
70,000 (3)
2,100(4)
20,000 (4)
13,000
3,900
14,000
13,000
14,000
15,000
23,000
18,000
18,000
14,000
22
13,700
14,000
28,000
3,700
6,482
29
170
23
60
84
74
10
55
22
23
31
34
73 (3)
220 (4)
170 (4)
62
68
18
150
50
28
19
66
35
97
22
55
43
170
10
42
99.9
98.8
99.9
99.5
99.4
99.3
99.9
99.6
99.5
99.7
99.2
99.4
99.9
89.5
99.2
99.5
98.3
99.9
98.8
99.6
99.8
99.9
99.6
99.8
99.3
22
99.6
99.6
99.9
98.3
NA
2,200 (1)
680 (1)
120
110
34
140
37
350
54(2)
36
120(2)
380
130 (3)
240 (4)
240 (4)
170
270
140
490
140
2,100(2)
190
96
?6(2)
110
22
370
140
2,200
34
600
<3
13
<3
<3(2)
<3
<3(2)
<3(2)
<3(2)
<3
<3
<3
<3
9.4 (3)
3.3 (4)
3.5 (4)
<3
<3
3.6
<3
28(2)
13(2)
<3
<3
<3
<3
22
5.1
3
28
3
5.9
99.9
98.1
97.5
97.3
91.2
97.9
91.9
99.1
94.4
91.7
97.5
99.2
92.8
98.6
98.5
98.2
98.9
97.4
99.4
80.0
99.4
98.4
96.9
96.1
97.3
22
98.6
97.5
99.9
80.0
NA
Note: Values below the detection limit are set equal to the DL for calculating statistics.
NA - not applicable
(1)  Analyzed 5-7 days beyond 28 day hold time. Data were considered useable given the high concentrations,
    nature of the FOG from septage and maintained under refrigeration. Data could be biased slightly low.
(2)  Lab control sample and/or lab control sample duplicate has low recovery. See QA section 4.5.3.
(3)  March 2009 data is excluded from the summary statistics as the BOD5 effluent data is suspect or if correct
    indicate an upset occurred.
(4)  Per protocol the data from May 2009 when an upset occurred are not included in the summary statistics, but are
    reported for informational purposes.
                                                 29

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4.2.3   Nitrogen Reduction Performance

Table 4-4 present the results for the TKN, NH3-N, NO2+NO3 in the influent and effluent during
the verification test. Total nitrogen (TN) results are also presented in Table 4-4. TN is calculated
by adding the TKN (organic plus ammonia nitrogen) and nitrite-nitrate nitrogen concentrations.

The  influent  wastewater  had  a mean  TKN  concentration of 440  mg/L with  a median
concentration  of 470 mg/L and  a range of  170 to 550  mg/L.  The influent mean NH3-N
concentration was 93  mg/L with a median concentration of 88 mg/L and  a range of 8 to 160
mg/L. These high concentrations were expected based on the type of waste materials received.
The nitrite plus nitrate concentration in the influent was typically low with a mean concentration
of 3.2 mg/L and a range of <0.05 to 15 mg/L.

The effluent mean TKN concentration was 83 mg/L with a median value of 78 mg/L and a range
of 42 to 170 mg/L.  The effluent NH3-N mean concentration was  60 mg/L with a median of 64
mg/L and a range of 14 to  120 mg/L. The nitrite plus nitrate mean concentration was 3.8 mg/L
with a median concentration of 3.0 mg/L.

The mean removal  of total nitrogen  over the verification test period was  80% with a median
removal of 80%. The verification test was designed to measure overall performance and did not
include intermediate  process samples  to differentiate  which processes  were removing the
nitrogen from  the system. However, review of all  of the nitrogen  data suggests that most of the
nitrogen removal was in the solids separation process with the nitrogen being removed with the
biosolids.

The data indicate that a large percentage of the total nitrogen was organic nitrogen. Comparing
the mean influent TKN (440 mg/L) with the mean influent ammonia concentration of 93 mg/L
shows that the organic nitrogen  represented approximately 79% of the nitrogen in the untreated
septage material.  Nitrite-nitrate was low at 3.2 mg/L. The largest reduction in nitrogen content
appears to be  due to the removal of organic  nitrogen with the biosolids removed by the screw
press. This conclusion is based on reviewing the ammonia and nitrite-nitrate data, which indicate
that there was no appreciable nitrification occurring in the biological system aeration tanks. If
nitrification were occurring, it would be expected that the nitrite-nitrate concentration would
increase significantly. However, as shown in Table 4-4, the effluent nitrite-nitrate concentration
showed only a minor increase based upon comparing either the mean values or the individual
batch data. Based on the indication that nitrification was not occurring  to any large  extent, the
lowering of the ammonia levels from  a mean of 93 mg/L in the influent to a mean of 60 mg/L in
the effluent is also likely due to some removal  of ammonia in the biosolids along with the
organic nitrogen.

Removal of a large  amount of the nitrogen in the biosolids production step  is beneficial to their
use as a soil amendment. Further, removal of the organic nitrogen and some ammonia with the
solids means  that it is not converted  to nitrite-nitrate  in  downstream aerobic process  (e.g.,
municipal treatment system) or  require a full  nitrification-denitrification system. A moderately
high concentration of total nitrogen, particularly ammonia nitrogen, does  remain in the effluent,
                                           30

-------
Table 4-4.  Influent and Effluent Nitrogen Data
Event
Composite'1'
09/26/08
10/17/08
11/14/08
12/12/09
01/30/09
02/20/09
03/1 1/09 (5)
05/22/09 (6)
06/26/09
07/24/09
08/21/09
09/25/09
10/21/09
10/23/09
Number of
samples
Mean
Median
Maximum
Minimum
Std. Dev.
TKN-N
(mg/L as N)
Influent Effluent
550
460
510
500
170
340
260
470
480
430
430
480
510
400
12

440
470
550
170
100
55
42
100
170
45
71
64
50
67
110
89
92
82
73
12

83
78
170
42
35
NH3-N
(mg/L as N)
Influent Effluent
160
61
91
64
7.7 (3)
38
47
38
140
130
160
98
78
84
12

93
88
160
8
48
83
14
77
59
27
42
42
5.1
63
120
24
81
67
65
12

60
64
120
14
30
NO2+NO3-N
(mg/L as N)
Influent Effluent
<0.05 (2)
<0.05
0.71
<0.05
0.56
<0.3
7.6
<0.3(4)
4.6(7)
<0.5
15
<0.5
<2.5(7)
13
12

3.2
0.5
15.0
<0.05
5.3
<0.05 (2)
13
<0.50
0.44
3.5
5.6(4)
<0.3
<0.3(4)
<3.0(4)
2.8
<1.2
7
4.3
1.3
9

3.8
3.0
13.0
<0.05
3.7
Total Nitrogen
(mg/L as N)
T m ± ™m ± Removal
Influent Effluent ,0/,
550
460
511
500
171
340
268
470
485
431
445
481
513
413
12

440
470
550
171
100
55.1
55.0
NR
170
48.5
76.6
64.3
50.0
70.0
113
90.2
99.0
86.3
74.3
12

85
77
170
49
34.4
90.0
88.0
NC
65.9
71.6
77.5
76.0
89.4
85.6
73.8
79.7
79.4
83.2
82.0
12

80
80
90
66
7.2
Note: Values below the detection limit (DL) are set equal to the DL for calculating statistics.
NC - not calculated; NR - not reported
(1)  Influent sample is a composite of two grab samples from the holding tank representing two batches processed.
    Effluent sample is a composite of the two composite samples from the two batches processed.
(2)  Analyzed 6-8 days beyond 28-day hold time. Data were considered useable given that no detectable nitrate-
    nitrite was found and sample was preserved with refrigeration. Data could be biased slightly low.
(3)  Reanalyzed with a result of 4.3 mg/L; TKN is lower than NH3 - lab not sure what the nature of the analytical
    problem is- other analyses appear normal.
(4)  Samples exceeded holding time of 48 hours on unpreserved sample. Times were 48 hours beyond holding time
    for samples in data not used in statistics.
(5)  Only one batch processed in March; data is excluded from the summary statistics as the BOD5 effluent data is
    suspect or if correct indicate an upset occurred.
(6)  Per protocol, the data from May 2009 when an upset occurred are not included in the summary statistics, but are
    reported for informational purposes.
(7)  Samples exceeded holding time by  10-11 hours (48-hour hold time). Data was considered useable as it would
not be expected  that significant denitrification would occur in a refrigerated oxygenated sample in a few hours
beyond the holding time.

-------
which can have an impact on downstream wastewater treatment plants receiving the effluent.
However, the levels should be more manageable than the full strength untreated septage.

4.2.4   Total Phosphorus Removal Performance

Table 4-5  presents the results for TP in the influent and effluent during the verification test.
Table 4-5  also presents a summary of the data (mean,  median, maximum, minimum, standard
deviation).

The influent had a mean TP concentration of 128 mg/L and median concentration of 115 mg/L
with a range of 2.6 to 280 mg/L. The effluent mean concentration over the 13-month test was 3.3
mg/L with a median  of 3.3  mg/L  and a range of 0.1 to 7.1 mg/L. The mean TP removal was
95.3% with a median  removal of 97.3%.

As was the case with nitrogen, the verification test did not collect process specific data to try to
identify which  process(s)  removed the most  phosphorus. Rather the verification test was
designed to  measure  overall performance. However, basic knowledge of phosphorus removal
processes  would  suggest that the majority of the phosphorus  is removed in the biosolids
dewatered by the screw press. The only chemical  treatment, namely  lime, occurs in the lime
holding tank prior to the screw  press.  It would be  expected that the treatment with lime  and
subsequently with polymer before the thickener and screw press would encourage phosphorus
precipitation and removal with the biosolids. Assuming this is the case, the phosphorus would be
a benefit to the soil amendment/fertilizer value of the finished biosolids product.

There may also be some uptake of phosphorus in the  aeration system as part of the biological
treatment step. The amount of phosphorus uptake was not measured and would be expected to be
negligible compared with the large amount of phosphorus present in the septage and removed by
the system.
                                          32

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    Table 4-5. Total Phosphorus

    Event Composite (1)
                                  Influent
TP (mg/L as P)
    Effluent
Removal (%)
09/26/08
10/17/08
11/14/08
12/12/09
01/30/09
02/20/09
03/1 1/09 (2)
05/22/09 (3)
06/26/09
07/24/09
08/21/09
09/25/09
10/21/09
10/23/09
Number of samples
Mean
Median
Maximum
Minimum
Standard Deviation
160
53
75
11
0.45
2.6
18
350
280
260
120
97
220
150
12
128
115
280
2.6
90
2.0
1.9
2.0
3.0
<0.01
<0.05
1.4
9.0
3.6
4.1
4.8
4.4
7.1
4.2
12
3.3
3.3
7.1
<0.05
1.8
98.8
96.4
97.3
72.7
>97.8
>98.1
92.2
97.4
98.7
98.4
96.0
95.5
96.8
97.2
12
95.3
97.3
98.8
72.7
7.2
Note:  Values below the DL are set equal to the DL for calculating statistics.
(1) Influent sample is a composite of two grab samples from the holding tank representing two batches processed.
   Effluent sample is a composite of the two composite samples from the two batches processed.
(2)  Only one batch processed in March; March 2009 data is excluded from the summary statistics as the BOD5
   effluent data is suspect or if correct indicate an upset occurred.
(3)  Per protocol, the data from May 2009 when an upset occurred are not included in the summary statistics, but
   are reported for informational purposes.
4.2.5  Other Operating Parameters  - pH, Alkalinity, Sodium,  Chloride, Dissolved
       Oxygen, and Temperature

Several operating parameters including pH, temperature and dissolved oxygen were measured on
a regular basis by the operating staff.  The data obtained on verification sample collection days
are presented in Tables 4-6 through 4-8. Total alkalinity, sodium and chloride were monitored as
part of the verification test. These results are also shown in Tables 4-6 through 4-8.

The pH  of the influent ranged from 6.7 to  8.9 with  a median value  of 7.8. The effluent data
showed a median pH of 7.8 with a range of 7.3 to 8.4. Dissolved oxygen was generally very low
                                             33

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in the influent samples from the holding tank as would be expected. Typically, dissolved oxygen
was less than 1.0 mg/L. The effluent DO had a mean of 5.2 mg/L with a median of 4.8 mg/L.

Temperature  can impact biological  systems  by  slowing  growth rates, particularly  in  cold
northern climates, in areas such as Charlevoix. One of the benefits of the totally enclosed Big
Fish System, with  all tanks buried underground and inside a building, is the control  of
temperature in  the  winter.  The  influent  temperature ranged  from 51° F to 80° F. Effluent
temperature, indicative of the aeration system temperature, ranged from 53° F to 85° F. There was
no noticeable temperature impact on the system over the 13-month test period.

The influent had a mean total alkalinity concentration of 710 mg/L as CaCOs, and the median
concentration was 770 mg/L as CaCO3. The effluent had a lower mean alkalinity concentration
of 290 mg/L as  CaCOs  and median of 300 mg/L as CaCOs. Sodium and chloride concentrations
were also  monitored during the test.  The  mean chloride concentration in the influent was 270
mg/L and  the effluent was 310 mg/L. The mean sodium concentration in the influent was 170
mg/L and the effluent mean concentration was slightly lower at 130 mg/L.
                                          34

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Table 4-6.  pH and Total Alkalinity Results
Date
Influent Effluent
09/22/08 09/24/08
09/24/08 09/26/08
10/13/08 10/15/08
10/15/08 10/17/08
11/10/08 11/12/08
11/12/08 11/14/08
12/08/09 12/10/09
12/10/09 12/12/09
01/26/09 01/28/09
01/28/09 01/30/09
02/16/09 02/18/09
02/18/09 02/20/09
03/09/09 (1) 03/11/09
05/1 8/09 (2) 05/20/09
05/20/09 (2) 05/22/09
06/22/09 06/24/09
06/24/09 06/26/09
07/20/09 07/22/09
7/22/090 07/24/09
08/17/09 08/19/09
08/19/09 08/21/09
09/21/09 09/23/09
09/23/09 09/25/09
10/19/09 10/21/09
10/21/09 10/23/09
Number of samples
Mean
Median
Maximum
Minimum
Standard Deviation
Influent
7.9
8.0
7.8
7.8
7.7
7.7
7.5
8.9
8.3
6.7
6.8
7.6
6.5
7.9
8.0
7.8
8.2
6.8
7.4
8.5
8.4
7.1
6.9
7.9
8.0
22
NA
7.8
8.9
6.7
NA
pH
Effluent
8.0
7.9
7.6
7.3
7.7
7.8
8.2
8.2
8.0
7.8
7.8
7.8
8.3
6.6
6.9
7.9
7.5
8.4
7.6
7.9
8.1
7.9
7.3
7.5
7.8
22
NA
7.8
8.4
7.3
NA
Alkalinity
Influent
920
820
540
810
920
690
600
750
530
600
500
520
1300
NR
430
970
980
130
760
860
230
1,100
770
840
780
22
710
770
1100
130
240
(mg/L as CaCO3)
Effluent
210
340
250
250
350
360
250
240
310
190
170
290
230
430
380
330
310
280
280
360
360
350
340
280
320
22
290
300
360
170
57
NR - not recorded/not analyzed
NA - not applicable
(1) March 2009 data is excluded from the summary statistics as the BOD5 effluent data is suspect or if correct
   indicate an upset occurred.
(2) Per protocol, the data from May 2009 when an upset occurred are not included in the summary statistics, but are
   reported for informational purposes.
                                                  35

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Table 4-7.  Chloride and Sodium Results
     „    , „       .,                Chloride (mg/L)                      (Sodium mg/L)
     Event Composite         T  „           v  *'     .           . „   V         s   '
                ^              Influent           Effluent           Influent          Effluent
09/26/08
10/17/08
11/14/08
12/12/09
01/30/09
02/20/09
03/1 1/09 (1)
05/22/09 (2)
06/26/09
07/24/09
08/21/09
09/25/09
10/21/09
10/23/09
Number of samples
Mean
Median
Maximum
Minimum
Standard Deviation
740
280
110
73
350
300
320
9.9
160
100
470
160
350
160
12
271
220
740
73
192
770
210
150
130
350
590
110
18
430
23
77
270
570
210
12
315
240
770
23
232
280
240
130
250
200
210
150
94
50
12
320
110
150
82
12
170
175
320
12
96
180
160
85
120
180
150
170
72
97
110
96
92
190
140
12
133
130
190
85
38
(1)  March 2009 data is excluded from the summary statistics as the BOD5 effluent data is suspect or if correct
    indicate an upset occurred.
(2)  Per protocol, the data from May 2009 when an upset occurred are not included in the  summary statistics, but are
    reported for informational purposes.

Note: Chloride data in February, June, August, and September 2009 did not balance between influent and effluent as
     well as might be expected. This may be due to the nature of the batch system, where there is a large quantity
     of wastewater in the aeration tanks that is displaced by treated influent filtrate exiting the screw press.
     Therefore, the influent grab from before lime treatment and processing through the screw press does not match
     exactly to the effluent from the aerobic treatment as there is mixing with previously treated batches.
                                                  36

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Table 4-8. Temperature and Dissolved Oxygen Results
                                        DO (mg/L)
Date
     Influent
       Effluent
                                                    Temp (°F)
Influent
Effluent
Influent
Effluent
09/22/08
09/24/08
10/13/08
10/15/08
11/10/08
11/12/08
12/08/09
12/10/09
01/26/09
01/28/09
02/16/09
02/18/09
03/09/09
05/18/09
05/20/09
06/22/09
06/24/09
07/20/09
7/22/090
08/17/09
08/19/09
09/21/09
09/23/09
10/19/09
10/21/09
09/24/08
09/26/08
10/15/08
10/17/08
11/12/08
11/14/08
12/10/09
12/12/09
01/28/09
01/30/09
02/18/09
02/20/09
03/11/09
05/20/09
05/22/09
06/24/09
06/26/09
07/22/09
07/24/09
08/19/09
08/21/09
09/23/09
09/25/09
10/21/09
10/23/09
Number of samples
Mean
Median
Maximum
Minimum




Standard Deviation
0.3
4.8
0.3
4.2
0.3
0.2
0.5
4.3
0.2
0.1
0.1
0.5
0.2
2.4
1.1
0.1
0.4
0.4
0.4
0.2
0.3
0.3
0.3
0.8
0.5
25
1.2
0.4
7.2
0.1
1.9
6.1
4.5
5.6
4.7
4.5
4.5
4.8
4.8
5.1
4.5
4.7
4.2
4.7
4.2
4.8
7.3
4.6
6.5
6.5
5.1
5.4
4.8
6.3
5.4
6.1
25
5.2
4.8
7.3
4.2
0.8
70
79
68
77
67
65
59
70
57
58
54
60
51
65
64
66
80
72
75
80
77
74
73
66
65
25
68
67
80
51
8.2
73
81
78
75
64
65
71
70
61
60
60
60
53
72
69
78
77
82
79
85
79
76
74
67
67
25
71
72
85
53
8.3
                          37

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4.2.6   Biosolids Production and Quality

The Big Fish System is designed with a main objective to produce EQ Class A Biosolids which
are regulated under the Federal rules 40 CFR Part 503, more commonly referred to as the "503
Rules." These Rules establish several options to meet the Class A Biosolids designation, with all
options including treatment methods to reduce pathogens and provide vector control. In addition,
a monitoring program to demonstrate that biosolids meet fecal coliform standards is required for
Class A designation  and the measurement of heavy metals is required to  meet the EQ limits
shown in Table 4-11. The treatment options used by the Big Fish System are a combination of
elevated pH for vector control and elevated  temperature  (time-temperature  combination) for
pathogen control.

A summary of the pH data for all of the batches of biosolids produced during the verification test
is shown in Table 4-9. As can be seen, the pH met the 503 Rule requirements at all times. The
PLC records were provided by Big Fish to the TO for review. These data show that the proper 38
rpm  screw-press rate was maintained at all times ensuring the minimum  contact time in the
screw press  at elevated temperature was achieved. Big Fish typically  operates the screw press
such that the biosolids achieve a temperature of 90° to 100° C, well above the 503 Rule minimum
requirement. A screw press setting of 38 rpm provides approximately 20 minutes of contact time.
Under the time-temperature  relationship requirements of the 503 Rule Option A, a  minimum
time requirement at 90° C is less than one minute. The screw press operating data is summarized
in Table 4-10.

In  addition to monitoring the  pH and the thermal  treatment process, Big Fish  also collects
samples of the biosolids to demonstrate that the fecal coliform is below the  Class A standard of
1000 MPN per gram -  dry weight. These data were  obtained from Big Fish and show that the
biosolids meet the fecal coliform requirement. The data are presented in Appendix A, containing
vendor supplied information and data.

Based on the data collected during the verification test and the fecal coliform data presented in
Appendix A, all batches of biosolids produced  met the requirements to  be classified as EQ Class
A Biosolids.
                                           38

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Table 4-9. Biosolids - pH of Lime-Treated Biosolids at 2 and 24 hour Holding Periods
Date
09/22/08
09/24/08
10/13/08
10/15/08
11/10/08
11/12/08
12/08/08
12/10/08
01/26/09
01/28/09
02/16/09
02/18/09
03/09/09
05/18/09
05/20/09
06/23/09
06/25/09
07/20/09
07/22/09
08/17/09
08/19/09
09/21/09
09/23/09
10/19/09
10/21/09
Initial
12.5
12.1
12.2
12.4
12.2
12.1
12.2
12.5
12.3
12.3
12.4
12.3
12.5
12.1
12.5
12.2
12.3
12.1
12.3
12.5
12.0
12.2
12.0
12.2
12.1
pH
After 2 hours
12.3
12.1
12.3
12.0
12.3
12.2
12.4
12.5
12.3
12.5
12.5
12.5
12.5
12.2
12.2
12.2
12.6
12.9
12.4
12.3
12.0
12.2
12.0
12.3
12.1
After 24 hours
12.2
12.0
12.5
11.8
12.3
11.9
12.5
12.6
12.3
12.5
11.8
12.6
12.6
11.6
12.3
11.9
12.5
12.8
12.3
11.6
11.5
11.7
11.6
12.2
11.6
                                        39

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Table 4-10. Screw Press Operating Data Summary Temperature and rpm
Batch Date
09/22/08
09/24/08
10/13/08
10/15/08
11/10/08
11/12/08
12/08/08
12/10/08
01/26/09
01/28/09
02/16/09
02/18/09
03/09/09
05/18/09
05/20/09
06/23/09
06/25/09
07/20/09
07/22/09
08/17/09
08/19/09
09/21/09
09/23/09
10/19/09
10/21/09
Temperature ( °C)
Mean Maximum
99
99
100
100
100
101
100
99
99
99
100
100
99
100
99
98
97
100
100
98
98
99
100
99
99
100
100
101
101
102
102
101
101
101
102
101
101
102
102
102
100
99
101
102
101
100
101
102
100
101
Minimum
91
90
90
91
94
89
92
93
76
93
92
97
86
88
89
79
84
97
92
79
85
89
92
91
93
% Motor
setting (1)
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
0.38
(1) Percent motor setting is related to rpm which sets the time the solids are in the heated screw press.
                                             40

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Table 4-11. Biosolids Metals Results
     Analyte
Units
3/13/2009
                    Pollutant
6/18/2009       Concentration Limits
                 for EQ Biosolids
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
Total Solids
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
%
3.5
2.4
18
430
21
0.33
12
5.9
1300
50
4.4
2.2
19
260
23
0.22
12
2.6
990
60
41
39
1,200
No standard
300
17
420
36
7,500
NA
NA - not applicable
The volumes of biosolids produced during the verification test were estimated based on the size
and number of hoppers of biosolids that were filled from the screw press. When a hopper was
filled, it was then emptied by placing the biosolids in the storage area outside the main building.
Table 4-12 shows the volume of biosolids produced form each  batch of material treated  during
the verification test runs.

4.3    Operation and Maintenance
The O&M performance of the Big Fish System was monitored throughout the verification  test by
the TO during regular visits to the site. Big Fish operators were  responsible for routine O&M of
the system. Various data and observations were recorded by the  Big Fish operators as part of
their normal work practices. The field  logs used  to collect the operating data are included in
Appendix F.

There were no major mechanical component failures during the verification test. There were also
no major downtime periods during the test due to maintenance requirements.

4.3.1   Chemical Use

Lime was used to raise the pH to meet the requirements for vector reduction in the biosolids and
to aid in the dewatering processes. Lime can  also enhance phosphorus removal. Lime use was
monitored for each batch of waste material processed,  and the quantity of lime used and the
volume of waste pumped to the lime treatment tank were recorded. Table 4-13 presents the lime
usage data and the volume of waste treated.
                                           41

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Table 4-12.  Volume of Biosolids Produced
                    Date
      Start Batch
End Batch
Biosolids Volume Produced

      (cubic yards)
09/22/08
09/24/08
10/13/08
10/15/08
11/10/08
11/12/08
12/08/09
12/10/09
01/26/09
01/28/09
02/16/09
02/18/09
03/09/09
05/18/09
05/20/09
06/22/09
06/24/09
07/20/09
7/22/090
08/17/09
08/19/09
09/21/09
09/23/09
10/19/09
10/21/09
09/24/08
09/26/08
10/15/08
10/17/08
11/12/08
11/14/08
12/10/09
12/12/09
01/28/09
01/30/09
02/18/09
02/20/09
03/11/09
05/20/09
05/22/09
06/24/09
06/26/09
07/22/09
07/24/09
08/19/09
08/21/09
09/23/09
09/25/09
10/21/09
10/23/09
4.5
3.0
4.0
2.3
3.3
5.5
2.8
2.5
2.0
1.8
2.0
2.0
3.0
3.0
3.0
3.0
3.8
4.3
3.3
3.0
3.3
5.0
4.8
6.0
5.5
Polymer was added to the lime-treated waste material after the 24 hour holding period as it was
being pumped from the holding tank to the thickener. A cationic polymer, Aquaben HF 748E,
was used from September 2008 through July 2009. A different source material, ERC Associates
ERC840HX cationic  polymer was used from August through October 2009. The quantity of
polymer used is  shown in Table  4-13. The  volume recorded was the amount of concentrated
liquid polymer consumed. The concentrated polymer was diluted within the injection system
used to feed the polymer to the waste material.

Muriatic acid was used to neutralize the overflow liquid from the thickener and the filtrate from
the screw press as it was pumped from the thickener and screw press to the aerobic processing
tanks. The  acid  was fed from the containers that were received from  the  supplier without
intermediate dilution. Table 4-13 shows the acid used for each batch of material processed. The
                                          42

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records indicate that no acid was used for five of the batches processed. This data is considered
suspect, as the pH of the lime treated material for those batches was above 12 for four of the
batches and above 11.5 for the other batch. Effluent pH was in the usual range (6.6 to 8.2) for
these batches. It would appear that some acid must have been added to these batches to lower the
pH, but the records do not reflect the acid addition.

4.3.2  Electric Power and Natural Gas Usage

The  electric power and natural gas  use during the verification test was monitored using the
facility electric and gas meters. These meters measured total use for the facility. The steam for
heating the biosolids in the screw press was generated on-site with a gas fired boiler. The impact
of the  boiler to heat the screw press was seen in the twice per week spike in natural gas use.
Electrical use did not vary widely as the daily demands of the aeration system and recirculation
pumps, which run 24 hours per day appear to dominate the electric requirements. Table 4-14
shows  the electric and gas use for the verification test periods.

Table  4-13. Chemical Use
Date
Start Batch
09/22/08
09/24/08
10/13/08
10/15/08
11/10/08
11/12/08
12/08/09
12/10/09
01/26/09
01/28/09
02/16/09
02/18/09
03/09/09
05/18/09
05/20/09
06/22/09
06/24/09
07/20/09
7/22/090
08/17/09
08/19/09
09/21/09
09/23/09
10/19/09
10/21/09
End Batch
09/24/08
09/26/08
10/15/08
10/17/08
11/12/08
11/14/08
12/10/09
12/12/09
01/28/09
01/30/09
02/18/09
02/20/09
03/11/09
05/20/09
05/22/09
06/24/09
06/26/09
07/22/09
07/24/09
08/19/09
08/21/09
09/23/09
09/25/09
10/21/09
10/23/09
Lime Tank
Volume (gal)
18,865
11,685
19,342
7,578
11,797
15,333
9,628
7,987
11,259
16,290
18,993
17,693
18,221
11,532
16,508
13,392
8,636
19,170
12,312
17,561
13,051
15,377
10,344
18,817
9,830
Lime Fed
(Ibs)
160
122
192
32
164
160
128
176
128
176
192
192
208
128
128
112
128
212
64
272
192
160
128
192
160
Polymer
(gal)
6.84
9.4
11.97
12.83
6.84
8.55
6.84
9.4
5.13
8.55
8.21
6.84
6.2
5.13
7.7
12.83
9.4
14.54
10.26
11.1
13.68
17.1
16.2
20.5
18.8
Acid
(gal)
7.62
0.8
3.175
1.59
1.56
3.175
0
0
0
20.3
19.05
0
4.76
0
12.7
7.9
12.7
7.14
14.22
5.6
7.1
8.7
4.8
7.9
9.5
                                           43

-------
Table 4-14. Electricity and Natural Gas Use
Date
09/22/08
09/23/08
09/24/08
09/25/08
09/26/08
10/13/08
10/14/08
10/15/08
10/16/09
10/17/08
11/10/08
11/11/08
11/12/08
11/13/08
11/14/08
12/08/09
12/09/08
12/10/09
12/11/08
12/12/08
01/26/09
01/27/09
01/28/09
01/29/09
01/30/09
02/16/09
02/17/09
02/18/09
02/19/09
02/20/09
03/09/09
03/10/09
03/11/09
Electricity
(kWh)
736
752
751
648
597
638
767
690
697
689
934
903
929
1053
493
773
966
571
798
562
383
810
605
719
492
673
839
787
521
521
391
103
500
Natural Gas
(ft3)
NR
NR
NR
NR
NR
0
47
3
36
3
34
53
4
78
0
8
50
5
50
0
0
46
4
55
0
0
47
1
77
0
0
78
0
Date
05/18/09
05/19/09
05/20/09
05/21/09
05/22/09
06/22/09
06/23/09
06/24/09
06/25/09
06/26/09
07/20/09
07/21/09
7/22/090
07/23/09
07/24/09
08/17/09
08/18/09
08/19/09
08/20/09
08/21/09
09/21/09
09/22/09
09/23/09
09/24/09
09/25/09
10/19/09
10/20/09
10/21/09
10/22/09
10/23/09



Electricity
(kWh)
712
663
602
642
730
636
656
634
607
603
679
723
669
687
662
647
832
495
844
807
672
680
644
652
609
612
710
603
722
565



Natural Gas
(ft3)
3
46
0
71
6
3
41
0
40
0
3
54
2
49
39
0
55
0
38
45
3
49
0
39
1
3
56
0
57
80



NR- not recorded
                                          44

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4.3.3   Operation and Maintenance Observations

The O&M of the Big Fish System was observed by the TO representatives who were on site for
several days  each month to collect samples  and review operating records.  The goal of these
observations was to develop information on the  system operability, complexity, and degree of
maintenance  required.  These observations serve  as the basis for the qualitative performance
information provided herein.

The Big Fish System is a relatively simple system to operate, as it is a batch-type operation that
involves mostly mechanical equipment, such as tanks,  pumps, valves, aerators, level controllers,
etc. The screw press has a programmable logic controller to control the operation and record data
on temperature, speed,  etc. The procedures and description for equipment O&M are described in
the O&M manual provided by Big Fish (Appendix C).

The potentially more complicated part of the system is the  biological  system. As with most
biological treatment  systems,  when  the facility is  running  smoothly,  the  operation  is
straightforward. Monitoring and controlling flows (for  Big Fish this is controlling batch size and
ensuring  recycle flows are operating), DO/aeration, pH, and observing biomass condition are
sufficient  to maintain  good treatment. However, if an upset occurs or the wastes  are  highly
variable, biological systems require a reasonable level  of expertise to understand and correct the
problem.

The Big Fish startup was  straightforward and accomplished in less than 3  weeks. The system
also recovered from the May upset caused by an extreme shock load in less than 4 weeks. The
operator's ability to stop treating new batches, and not discharge during these periods allowed
the microbial population to  recover while operating in the standard re-circulation mode. This
relative ease of the startup and recovery from upsets seems to be because of the larger volume of
aeration capacity with  continuous recycle providing a buffer to upsets and allowing for quick
recovery.  Further, the  batch style operation and large holding tanks provide capacity to hold
incoming  material and respond to changing conditions. In  addition, the system is designed to
maintain a "hatchery"  or source of biomass that can  be used to augment the system should a
problem occur. The simulated startup demonstrated that in the "worst case" the entire system
could be emptied and  cleaned in 2-3  days. Restart is then accomplished by adding  processed
(lime treated) waste to the aeration tanks and seeding with biomass from the on-site supply.

As with any biological treatment system, operator skill  and knowledge are important, particularly
during startups and if an  upset occurs.  It would be  expected that in a  stand-alone facility a
licensed wastewater operator with basic biological treatment  knowledge and mechanical skills
would be  required to operate the system. If the Big Fish System were installed at a  municipal
treatment plant with several levels of operators, the system could easily be operated by an entry-
level operator as long as an operator with biological  treatment experience  was available if a
problem or upset occurs.

The Big  Fish System  with the incoming waste loading conditions that occurred  during  the
verification test (two or three, 20,000 to 30,000 gal batches  of waste per week) can be operated
                                           45

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by one operator. In fact, the system was run by one operator during most of the verification test.
The largest demand on the operator's time is performing the laboratory and field tests (pH, DO,
temp, BOD, NHs, TSS, NOs, TP, etc.),  plus collecting and maintaining the operating records.
Based on observation of the operation at a load of two batches per week, it would appear that if
the processing load increased to three or more batches per week (>30,000 gal per week), an
additional part time helper would be needed to assist the main operator. If the system were at a
municipal treatment facility, one  operator could handle  the system at full  capacity if the
laboratory work and some record keeping were performed by others at the larger plant.

4.4    Quality Assurance/ Quality Control

The  VTP  included  a Quality  Assurance  Project  Plan  (QAPP)  that  identified  critical
measurements and established Data Quality  Objectives (DQO). The verification test procedures
and data collection followed the QAPP, and summary results are reported in this section. The
laboratory reported QA/QC data with each set of sample results as part of the laboratory reports.
Each report included the results of blanks,  laboratory duplicates, spikes, and other lab control
sample results for  the  various analyses. These QA data are  incorporated with the laboratory
reports presented in Appendix F.

4.4.1   Audits

NSF conducted an audit of the RTI laboratory prior to the verification test. The laboratory audit
found that RTI followed approved analytical methods and documented the  methods and QA/QC
in an acceptable manner. The audit also provided the opportunity to explain the ETV program
and the requirements for a successful verification test to the participants.

The laboratory had a firmly established QA/QC program, and  observation  of the analyses and a
records review  found that  appropriate  QC data was being performed with the analyses.  All
members of the testing team were  reminded that ETV requires that copies of all logs and raw
data records be delivered to NSF at the end of the project.

NSF conducted a  field audit  at the Big  Fish  site on September 25,  2009  to review test
procedures,  review  documentation, and   observe  the  sampling  collection  and  shipment
procedures. The field audit found that all critical procedures were being appropriately followed
and in accordance with QAPP and the  Test Plan. The audit identified that the  sample volume
being placed in the sample bottles was not being recorded, but sample volume had been adequate
for the laboratory. It was also noted that a neighbor odor complaint had not been recorded in the
operating log. Corrections were made to address these comments. It  was also noted that the
composite samples over multiple days were not exact flow proportional composites, but it was
demonstrated that the method being used and the consistent batch sizes and flows meant that
there was little  or no difference in the methods for compositing over multiple days. All issues
raised were resolved.
                                           46

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4.4.2   Precision

4.4.2.1   Laboratory Duplicates
The analytical laboratory performed sample duplicates for all parameters at a frequency of at
least one duplicate for every ten samples analyzed or one per batch if less than ten samples in a
batch. The results of laboratory duplicates were reported with all data reports received from the
laboratory. Table 4-15 shows the acceptance limits used by the laboratory.

The Relative Percent Difference (RPD) was calculated using the standard formula:

              RPD = [(Ci- C2) •*• ((Ci + C2)/2)] x 100%

              Where:

              Ci = Concentration of the compound or element in the sample
              C2 = Concentration of the compound or element in the duplicate

              Table 4-15.  Laboratory Precision Limits

                       „      ,                   Acceptance Limits
                       Parameter                       (RPD)
                TSS                                      20
                Alkalinity                                  25
                BOD5                                     25
                COD                                     25
                TKN                                     25
                NH3-N                                    20
                NO2/NO3                                  20
                Total P                                    20
                Na                                       25
                Chloride                                   25
The laboratory precision for all parameters, as measured by the laboratory duplicates, was found
to meet the QA objectives for the verification test.

 4.4.2.2  Field Duplicates
Field duplicates were collected  on three sets of samples.  There were not specific  quality
objectives set for field duplicates, but these were included in the plan for informational purposes.
Precision is often highly variably for field duplicates as these samples account for all factors that
can impact sample collection in addition to laboratory handling and analysis.
                                           47

-------
Tables 4-16 and 4-17 show the results from the field duplicate  samples collected during the
verification test. Most of the results are within expected ranges. There are a couple of results that
were investigated to see if the cause for the lack of precision could be identified. The first
influent TKN  duplicate had a very low TKN of 4.4 mg/L, which  was 100 times below the
sample, below the typical values for the influent, and lower than the corresponding ammonia
values  (TKN includes ammonia plus organic nitrogen). The lab reanalyzed the sample and the
result was 4.3  mg/L. The laboratory control sample (LCS) spike recovery for the analytical set
was 101% and the analytical set duplicate was within normal precision limits. The cause of the
discrepancy was not found and subsequent sample duplicates  showed reasonable precision.
A similar situation occurred with nitrite-nitrate on the first effluent duplicate. The duplicate was
four times higher than the effluent sample and much higher than the typical values found in the
effluent samples. An investigation did not find the cause of the discrepancy. Subsequent samples
were within expected  precision ranges.  One effluent FOG showed the sample  below the
detection limit, whereas the duplicate was measured at  31 mg/L. The entire sample  was
consumed in the analysis  so it  could not be rerun  or checked. The  other FOG duplicate tests
within  expected ranges, given that FOG is  collected as single glass bottle grab sample  and is
known to vary widely in wastewater matrices.

Table 4-16.  Duplicate Field Sample Summary - Nutrients
Sample

Influent
Effluent
Influent
Effluent
Influent
Effluent
Sample

Influent
Effluent
Influent
Effluent
Influent
Effluent

Repl
(mg/L as N)
480
92
510
82
400
73

Repl
(mg/L as N)
<0.50
7
<2.5
4.3
13
1.3
TKN
Rep 2
(mg/L as N)
4.4
140
560
80
420
83
NO2+NO3
Rep 2
(mg/L as N)
0.59
27
<1.2
3.5
18
1.7

RPD
(%)
197
41
9.3
2.5
4.9
13

RPD
(%)
NC
118
NC
21
32
27

Repl
(mg/L as P)
98
81
78
67
84
65

Repl
(mg/L as P)
97
4.4
220
7.1
150
4.2
NH3-N
Rep 2
(mg/L as P)
89
73
88
68
84
65
TP
Rep 2
(mg/L as P)
100
4.3
220
8.2
120
4.8

RPD
(%)
9.6
10
12
1.5
0
0

RPD
(%)
3.0
2.3
0
14
22
13
NC - Can not be calculated.
                                          48

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fable 4-17. Duplicate Field Sample Summary - BOD5, COD, TSS,

Sample
Influent
Effluent
Influent
Effluent
Influent
Effluent
Sample
Influent
Effluent
Influent
Effluent
Influent
Effluent

Sample
Influent
Effluent
Influent
Effluent
Influent
Effluent

Repl
(mg/L)
3,700
44
4,100
57
2,400
110
Repl
(mg/L)
18,000
66
18,000
35
14,000
97

Repl
(mg/L)
96
<3
76
<3
110
<3
BOD5
Rep 2
(mg/L)
4,000
50
5,800
55
3,100
87
TSS
Rep 2
(mg/L)
18,000
45
22,000
36
13,000
86
FOG
Rep 2
(mg/L)
59
<3
97
31
67
<3

RPD
(%)
7.8
13
34
3.6
25
23
RPD
(%)
0
38
20
2.8
7.4
12

RPD
(%)
48
0
26
NC
49
0

Repl
(mg/L)
21,000
320
26,000
240
20,000
400
Repl
(mg/L)
770
340
840
280
780
320







Alkalinity, FOG
COD
Rep 2
(mg/L)
28,000
360
28,000
210
16,000
360
Alkalinity
Rep 2
(mg/L)
730
330
830
290
790
320








RPD
(%)
29
12
7.4
13
22
11
RPD
(%)
5.3
3.0
1.2
3.5
1.3
0







  NC - Can not be calculated.
4.4.3   Accuracy

Method accuracy  was  determined and  monitored using  a combination  of matrix spikes,
laboratory  control samples  (known concentration  in  blank water),  and  proper  equipment
calibration and traceability depending on the analytical method. Recovery of the spiked analytes
was  calculated  and monitored  during  the verification test. The laboratory used the control
samples and recovery limits as shown in Table 4-18 and reported the data with each set of
analytical results.

The equations used to calculate the recoveries for spiked samples and laboratory control samples
are as follows:
                                           49

-------
Matrix Spike Samples:
             Percent Recovery = (Cr- C0)/Cf x  100%

             Where:    Cr = Total amount detected in spiked sample
                       C0 = Amount detected in un-spiked sample
                       C f = Spike amount added to sample.
Lab Control Sample:
             Percent Recovery = (Cm/ CknOWn) x 100%

             Where:    Cm   = measured concentration in the spike control sample
                             = known concentration
Table 4-18.  Laboratory Control Limits for Accuracy
Parameter
TSS
Alkalinity
BOD5
COD
FOG
TKN
NH3-N
NO2+NO3
Total P
Sodium
Chloride
Method
Blank
X
X
X
X
X
X
X
X
X
X
X
Lab Control A/r , . c ..
c . Matrix Spike
Sample r
x NA
x NA
x (1) NA
x x
x NA
X X
X X
X X
X X
X X
x NA
Recovery Limits
(%)
NA
NA
84-115(1)
80-120
78-114
80-120
75-125
75-125
75-125
75-125
80-120
 (1) Seed Control Sample
  x - Denotes sample collected
 NA - Not applicable

All of the specific requirements to document method accuracy are detailed in the QAPP in the
VTP, which is included in Appendix B. The laboratory supporting data is  included with the
laboratory reports in Appendix F. Review of the laboratory data shows that the accuracy data met
the quality objectives except  for low LCS recoveries for some FOG analyses and some BOD5
results did not meet the DO depletion guidance of > 2 mg/L.

It was noted during the NSF  QA data review that some samples for FOG were associated  with
low spike recoveries in the  LCS. Several of the LCS  or laboratory control  spike duplicate
(LCSD) recoveries for FOG were below 78%, which is below the QA data quality objective of
                                          50

-------
78-114%. A total of 14 samples was associated with recoveries below the target. Six results were
for sample sets with a single LCS result and eight sets had both LCS and LCSD results. Of the
eight sets with both a LCS and LCSD sample, 5 sets of results had at least one of the recoveries
above the minimum recovery and the other 3 sets showed low recovery for both LCS and LCSD.

All of the FOG LCS/LCSD  data are shown  in Table  4-19. The associated FOG data were
reviewed and found to be useable data within the objectives of this test. Most of the recoveries
were only slightly below the lower window established in the test plan. The actual sample results
may be biased low, but given the high concentrations of FOG in the influent waste material and
the low concentrations in the effluent, the data  are useable to demonstrate performance for FOG
removal.

Table 4-19 shows the FOG mean and median results for the data set with and without the results
associated with the low recoveries.  The mean concentrations  of the influent and effluent are
actually slightly lower when the data associated with the low recoveries removed. The overall
removal of FOG by the  system  is not significantly impacted,  with a removal of 98.6% based
upon using all the data, and a removal of 98.7% based on the data set which excludes the data
associated with the low recoveries. Therefore, while the low recoveries might suggest that some
of the results could be biased low, comparison of the data sets with and without these data shows
that  system removed a large  percentage of the  FOG, producing an effluent  with  FOG
concentrations generally  at or below the reporting limit of 3 mg/L.

In reviewing the BODs bench sheets and raw data, it was noted by NSF that 19 of the 50 BODs
results were based on DO depletion of less than the 2 mg/L prescribed in the test method. This
depletion is based on the DO depletion in the sample and then also accounting for the depletion
in the seeded blank. Overall, DO depletion of  less than 2 mg/L can impact the accuracy of the
BODs  test. All  of the impacted BODs data in the final ETV report in Table 4-2 have been
qualified with a footnote indicating when the DO depletion was less than 2 mg/L.

Table 4-20 shows the BODs and COD results with the DO depletion with and without seeded
blank adjustment. The laboratory procedure was to set 4 or 5 dilutions of the each sample in
order to cover a wide range of BODs concentrations. However,  with the variability of BODs
particularly in the influent,  some samples even with  4-5  dilutions did not met  the 2 mg/L
guidance. Furthermore, BODs cannot be re-run as the sample cannot be preserved and any data
from reanalysis after 5 days would be suspect.

As can be seen in Table 4-20 the range of BODs in the influent was from 27 to 21,000 mg/L and
the effluent ranged from 7 to 190 mg/L (excluding the upset in May).  The test plan included
analyzing COD on every sample that was scheduled for BODs as it was recognized that BODs
results can be variable and particularly problematic in septage-type wastes. The COD results can
be used when reviewing BOD5  data to determine  if the BOD5 results are in the  "range" that
would be  expected.  In  all  cases the COD data indicates that the BODs results,  where DO
depletion  was  low, are  reasonable estimates  or representative of  the expected  BODs
concentration.
                                          51

-------
Also, the individual data sheets for each sample were reviewed and the other dilutions used for
the test in most cases showed no significant DO depletion (too high a dilution) indicating that the
BODs concentration was equal to or less than the value calculated.

Based on the review of the COD data, the individual BOD5 dilutions, and the overall treatment
system conditions at the time of each sample, the BOD5 data was judged to be useable  for the
purposes of this verification. The BODs removal averaged 97.7% with the influent being very
high in BOD5 as expected, and the effluent data showed low to moderate BOD5 concentrations.
In fact,  5 of the samples with low DO depletion  occurred  in effluent samples for August to
October 2009, when the system performance was  the best and the BOD5 concentrations were
much lower than the overall average. The low BODs in these samples was why the  lowest
dilution did not meet the DO depletion target.

When DO  depletion of 2 mg/L was not achieved, the BOD5  results were typically used as
estimates of the BODs concentration. Even if the BODs data for these  samples were over/under
by 50%, it did not change the overall results that show the large reduction in BOD5 and that the
effluent BOD5 can meet typical municipal discharge standards (250-300 mg/L).

Finally,  if all of the BODs data with DO depletion  of < 2 mg/L  and the upset periods in March
and May 2009 are removed from the data set, the final results do not change significantly over
the 14 month test. The BOD5 removal using all the data was 97.7% and 97.3% for the data set
with the low depletion DO samples removed. BOD5 for the influent averaged 3,300 mg/L for all
the data and 3,000 for the smaller data set. Similarly the effluent BODs averaged 75 mg/L using
all the data and 81 mg/L with the smaller data set.

The comparisons to the COD data, among the data sets, and  review of the detailed data suggest
that the BODs results with  low DO depletion are reasonable  estimates of the  actual BODs
concentrations, consistent with other data, and useable for this verification.

The balance used for TSS analysis was calibrated routinely with weights that were National
Institute of Standards and Technology (NIST) traceable. Calibration records were maintained by
the laboratory and inspected  during the on-site audit.  The temperature of the drying oven was
also monitored using a thermometer that was calibrated with a NIST-traceable thermometer. The
pH meter was calibrated using a three-point calibration curve with purchased buffer solutions of
known  pH.  Field   temperature  measurements   were  performed using  a  NIST-traceable
thermometer. All of these traceable  calibrations  were  performed to ensure the accuracy of
measurements.
                                          52

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Table 4-19.  FOG Samples with Low LCS Recovery
Influent
Sample
09/22/2008
09/24/2008
10/13/2008
10/15/2008
11/10/2008
11/12/2008
12/8/2009
12/10/2009
01/26/2009
01/28/2009
02/16/2009
02/18/2009
03/9/2009
05/18/2009
05/20/2009
06/22/2009
06/24/2009
07/20/2009
07/22/090
08/17/2009
08/19/2009
09/21/2009
09/23/2009
10/19/2009
10/21/2009
Effluent
Sample
09/24/2008
09/26/2008
10/15/2008
10/17/2008
11/12/2008
11/14/2008
12/10/2009
12/12/2009
01/28/2009
01/30/2009
02/18/2009
02/20/2009
03/11/2009
05/20/2009
05/22/2009
06/24/2009
06/26/2009
07/22/2009
07/24/2009
08/19/2009
08/21/2009
09/23/2009
09/25/2009
10/21/2009
10/23/2009
Number of Samples
Mean
Median
Std. Dev.
Notes: N/A



- Not analyzed.
Influent
Sample
2,200(1)
680(1)
120
110
34
140
37
350
54
36
120
380
130(2)
240(3)
240(3)
170
270
140
490
140
2,100
190
96
76
110
22
370
140
600
Effluent
Sample
<3
13
<3
<3
<3
<3
<3
<3
<3
<3
<3
<3
9.4(2)
3.3(3)
3.5(3)
<3
<3
3.6
<3
28
13
<3
<3
<3
<3
22
5.1
3
5.9
NA - Not applicable. NR
Removal
(%)
99.9
98.1
97.5
97.3
91.2
97.9
91.9
99.1
94.4
91.7
97.5
99.2
92.8
98.6
98.5
98.2
98.9
97.4
99.4
80
99.4
98.4
96.9
96.1
97.3
22
98.6
97.5
NA
- Not reported
Influent
LCS (%)
100
83.5
83.5
83.5
98.5
95
92.5
57
77.7
93
64.3
96.8
84
81.5
74.3
79
71.8
91.3
93.3
81.5
65.5
83
94
72.2
83
25
83.2
83.5
11.3
in statistics
Influent
LCSD (%)
83.5
83.5
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
87.2
87.8
88.5
79.3
86
94.3
83.2
72.8
94.3
96.2
61.6
90.7
14
84.9
86.6
9.2

Effluent
LCS (%)
83.5
83.5
81
72.3
95
76.8
57
57
92.2
92.2
96.8
85.5
83
74.3
86.3
71.8
71.8
93.3
93.3
65.5
65.5
94
47.3
83
83
25
79.4
83
13.3

Effluent
LCSD (%)
83.5
N/A
N/A
N/A
N/A
97.5
N/A
N/A
N/A
N/A
N/A
N/A
N/A
87.8
86.2
79.3
79.3
94.3
94.3
72.8
72.8
96.2
86
90.7
90.7
14
86.5
87
8.1

Noted in
Narrative



not noted

noted
noted
noted
noted

noted


not noted
not noted
not noted
not noted


noted
noted


noted






Influent
Sample
2,200(1)
680° )
120
110
34
140
37
350
NR
36
NR
380
130(2)
240(3)
240(3)
170
270
140
490
140
NR
190
96
NR
110
21
300
140
464

Effluent
Sample
<3
13
<3
NR
<3
NR
NR
NR
<3
<3
<3
<3
9.4(2)
3.3(3)
3.5(3)
<3
<3
3.6
<3
NR
NR
<3
<3
<3
<3
19
4.0
<3
2.7

(1) Analyzed 5-7 days beyond 28-day hold time. Data were considered useable given the high concentrations, nature of the FOG from septage and samples were maintained under
    refrigeration. Data could be biased slightly low.
(2) March 2009 data is excluded from the summary statistics as the BOD5 effluent data is suspect, or if correct indicate an upset occurred.
(3) Per protocol, the data from May 2009 when an upset occurred are not included in the summary statistics, but are reported for informational purposes.
                                                                           53

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Table 4-20. BOD5 DO Depletion QA Table
Sample Date
Influent Effluent
09/22/2008
09/24/2008
10/13/2008
10/15/2008
11/10/2008
11/12/2008
12/08/2009
12/10/2009
01/26/2009
01/28/2009
02/16/2009
02/18/2009
03/09/2009
05/18/2009
05/20/2009
06/22/2009
06/24/2009
07/20/2009
07/22/2009
08/17/2009
08/19/2009
09/21/2009
09/23/2009
10/19/2009
10/21/2009
09/24/2008
09/26/2008
10/15/2008
10/17/2008
11/12/2008
11/14/2008
12/10/2009
12/12/2009
01/28/2009
01/30/2009
02/18/2009
02/20/2009
03/11/2009
05/20/2009
05/22/2009
06/24/2009
06/26/2009
07/22/2009
07/24/2009
08/19/2009
08/21/2009
09/23/2009
09/25/2009
10/21/2009
10/23/2009
Number of Samples
Mean
Median
Maximum
Minimum
Std. Dev





BOD5 mg/L
Removal
Influent Effluent (%)
1,300
2,600
5,200
3,600
2,800
2,800
15,000
2,600
48
110(1)
1,600
3,000
4,100
21,000
10,000
4,800
2,500
2,200
4,800
2,100
4,000
2,400
3,700
4,100
2,400
22
3,300
2,700
15,000
27
2,935
51
110
29
72
97
83
74
41
30
27(D
110
130
930
5,500
5,700
99
72
62
130
190
7
26
44
57
110
22
75
72
190
7
44.1
96.1
95.8
99.4
98.0
96.5
97.0
99.5
98.4
37.5
75.5
93.1
95.7
77.3
73.8
43.0
97.9
97.1
97.2
97.3
91.0
99.8
98.9
98.8
98.6
95.4
22
97.7
97.2
99.8
37
NA
Influent
DO
Depletion
Without
seed/with
seed adj.
2.52/2.13
4.75/4.34
4.74/4.35
3.32/2.97
2.74/2.37
4.95/4.63
1.49/1.26
2.41/2.19
1.41/0.80
2.45/2.24
1.70/1.33
2.78/2.52
1.97/1.69
1.99/1.75
4.52/4.15
4.21/3.97
5.50/5.14
4.29/3.99
6.40/6.22
2.03/1.78
3.55/3.35
4.23/3.94
2.74/2.47
1.75/1.37
1.88/1.61






Effluent
DO
Depletion
Without
seed/with
seed adj.
2.12/1.71
4.12/3.72
5.23/4.88
1.5/1.2
3.55/3.23
2.99/2.76
1.44/1.22
3.73/3.40
2.72/2.51
2.06/1.85
3.78/3.52
2.2/2.09
1.81/1.55
4.93/4.56
4.19/3.82
2.01/1.65
2.71/2.39
2.25/2.07
4.59/4.41
1.79/1.59
1.30/1.11
1.14/0.87
1.66/1.45
1.18/0.91
2.02/1.75






COD
Influent
22,000
22,000
31,000
26,000
24,000
14,000
18,000
20,000
6,400
3,700
6,300
5,600
36,000
31,000
20,000
18,000
6,200
25,000
20,000
18,000
8,200
21,000
21,000
28,000
20,000
22
17,500
20,000
31,000
3,700
8,032
mg/L
Effluent
25
380
210
250
400
390
180
270
210
290
300
320
400
11,000
8,600
180
380
220
360
290
160
200
320
240
400
22
270
280
400
25
95.5
NA - Not applicable.
                                        54

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4.4.4  Representativeness

The field procedures were designed to ensure that representative samples were collected of both
influent and effluent wastewater. The composite sampling equipment was  checked on a routine
basis to ensure that proper sample volumes were  collected to  provide flow-weighted sample
composites. Field duplicate samples and supervisor oversight provided assurance that procedures
were being followed. There was some variability in the field duplicate samples; however, review
of the overall data set for influent and effluent samples did not show specific sampling bias for
any of the parameters. These data indicated that while individual sample variability may occur,
the data were representative of the concentrations in the wastewater.

The laboratory used standard analytical methods and written SOPs for each method to provide a
consistent approach to all analyses. Sample handling, storage, and analytical methodology were
reviewed during the on-site audit to verify that standard procedures were being followed. The
use of standard methodology, supported by proper QC information  and audits, ensured that the
analytical data were representative of the actual wastewater conditions.

4.4.5  Completeness

The QAPP set a goal of 80% completeness for sample collection in the field, and for reporting
acceptable  analytical  results  by  the  laboratory.  The completeness goals were  met for all
parameters.  Table 4-21 shows the  number of samples/analyses anticipated and the number
actually collected and analyzed during the verification test.

Table 4-21. QA Completeness
        „       ,            ~   , XT   ,          Actual Number         Completeness
        Parameter          Target Number          „     .    ,               „.
                               fe                  Completed               %
Sampling days/batches
Flow/Volume
pH
Temperature
TSS
BOD5
COD
FOG
Alkalinity
TKN
NH3-N
NO2+NO3
TP
Sodium
Chloride
24
24
48
48
48
48
48
48
48
24-36 (1)
24-26 (1)
24-36 (1)
24-36 (1)
24-36 (1)
24-36 (1)
25
25
50
50
50
50
50
50
49
28
28
25
28
28
28
104
104
104
104
104
104
104
104
102
108 (2)
108 (2)
96(2)
108 (2)
108 (2)
108 (2)
 (1) See text for discuss of ranges per memo to NSF and EPA.
 (2) Based on a target of 26 samples; 12 months at two per month and one month with one sample (see test for
   further explanation).
                                           55

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The test plan called for 12 months of sampling with two batches processed each month, for a
total of 24 batches. In months with sufficient waste volume, the batches were to be consecutive
and the nutrients, sodium and chloride composited from both batches into one set of samples
(one influent and one effluent). It was anticipated that some low volume months would not allow
for consecutive batch processing, so it was approved in the test plan to sample non-consecutive
batches during those months. Nonconsecutive batch months were limited to six of the twelve
months during the test. For months when batches were not consecutive, the nutrients, sodium and
chloride would be sampled and analyzed for each batch; i.e., not be composited. In the test plan,
it was assumed that six months would meet the consecutive batch requirement (six sets of
influent and effluent samples for a total of 12 samples) and six months would be single batches
generating two sets of samples per month for a total of 24 samples (two sets per month - influent
and effluent for six months). The test plan table showed a target of 36 samples (12 plus 24) for
nutrients, sodium and chloride. The test plan table should have set a range of target samples from
the ideal where all batches were consecutive for 12 months yielding 24 samples to the maximum
allowed six months  with  non-consecutive  samples for  a total of 36  samples. During the
verification test, it was possible to meet the consecutive batch processing objective for 12 of the
13 months. The target number of samples for nutrients, sodium, and chloride was clarified in a
memo to NSF and EPA dated September 29, 2009. EPA and NSF concurred that the target range
should be 24  to 36 samples depending on the actual number of non-consecutive batch months
that were sampled.

The completeness calculation for nutrients (TKN, NH3-N, NO2+NO3, TP), sodium and  chloride
were  based on 26 samples.  This  represents the  12 months  when consecutive batches were
processed (12 months at one influent and one  effluent per month = 24 samples) plus the  one
month of March when a single batch was processed (one influent and one effluent sample = two
samples).

As shown in Table 4-21, the completeness target of 80% was achieved for all parameters. Even if
the upset period in May and the questionable BOD5 data  in March are removed from  the total
number of sample and analyses, the completeness for all analytical parameters exceeds 90%.
                                          56

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                          Chapter 5 Vendor Discussion
During the verification test, Big Fish sampled the biosolids on a periodic basis  and sent the
samples to the same contract laboratory used for verification testing for fecal coliform  and
percent moisture analyses.  The data has not been independently reviewed by the TO or NSF for
quality purposes but is presented in  Appendix  A  for informational  content in support of
performance claims made by Big Fish Environmental, LLC.

Big Fish Environment,  LLC, also arranged with Michigan State University (MSU) during the
verification testing, to analyze samples of raw septage  (influent) and effluent from the system for
E. co//', enterocci, Cryptosporidium, and Giardia. A report of the findings by MSU for samples
collected during the period of December,  2008  through  January, 2010 was prepared  and
submitted to Big Fish Environmental, LLC.  The report has not been reviewed by the TO or NSF
for quality purposes, and  is provided by Big Fish Environmental, LLC in  Appendix  A for
additional, but non-verified information in support of performance claims made by the vendor.
                                          57

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                                  Glossary of Terms

Accuracy - a measure of the closeness of an individual measurement or the average of a number
of measurements to the true value and includes random error and systematic error.

Bias - the systematic or  persistent distortion of a measurement process that causes errors in one
direction

Comparability - a qualitative term that expresses confidence that two  data sets can contribute to
a common analysis and interpolation.

Completeness - a qualitative term that expresses confidence that all  necessary data  have  been
included

Precision - a measure of the agreement between replicate measurements of the same property
made under similar conditions.

Protocol - a written document that clearly states the objectives, goals, scope and procedures for
the  study. A protocol shall be used for reference during Vendor participation in the verification
testing program

Quality Assurance Project Plan - a written document  that describes the implementation of
quality assurance and quality control activities during the life cycle of the project.

Residuals - the waste streams, excluding final effluent,  which are retained by or discharged
from the technology.

Representativeness -  a measure of the degree to which data accurately and precisely represent a
characteristic  of a population  parameter  at  a   sampling point,  a  process  condition,  or
environmental condition

Source Water Protection Stakeholder Advisory Group - a group of individuals consisting of
any or all  of the  following: buyers and  users of in drain removal and other technologies,
developers and vendors, consulting  engineers, the finance and export communities, and permit
writers and regulators.

Standard Operating Procedure - a written document containing specific procedures and
protocols to ensure that quality assurance requirements are  maintained

Technology Panel -  a  group of individuals with expertise and  knowledge  of decentralized
wastewater treatment technologies

Testing Organization - an independent organization qualified by the  Verification Organization
to conduct studies and testing of technologies in accordance with protocols and test plans
                                           58

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Vendor - a business that assembles or sells decentralized wastewater treatment equipment.

Verification - to establish evidence on the performance of in drain treatment technologies under
specific conditions, following a predetermined study protocol(s) and test plan(s).

Verification  Organization  -  an organization qualified by  USEPA to  verify environmental
technologies and to issue Verification Statements and Verification Reports.

Verification Report - a written document containing all raw and analyzed data, all QA/QC data
sheets, descriptions of all  collected data,  a detailed description of all procedures and methods
used in the verification testing, and all QA/QC results.  The Test Plan(s) shall be included as part
of this document.

Verification  Statement - a document that summarizes the Verification  Report reviewed and
approved by USEPA.

Verification Test Plan - A written  document prepared to describe the procedures for conducting
a test or study according to the verification protocol requirements for the application of treatment
technology.  At a minimum, the Test Plan shall include detailed instructions for sample and data
collection, sample handling and preservation, precision, accuracy, goals,  and  quality assurance
and quality control requirements relevant to the technology and application.
                                     References

(1)   NSF International, Protocol for the Verification  of Wastewater Treatment Technologies,
      Ann Arbor, MI, April 2001.
(2)   NSF International, Verification Test Plan for Big Fish Environmental, LLC., July 2008.
(3)   United States Environmental Protection Agency, Methods and Guidance for Analysis of
      Water, EPA 821-C-99-008, Office of Water, Washington, DC, 1999.
(4)   United States Environmental Protection Agency, Methods for Chemical Analysis of Water
      and Wastes, EPA 600/4-79-020, revised March 1983.
(5)   APHA,  AWWA,  and  WEF, Standard  Methods  for  the Examination  of Water and
      Wastewater,  19th Edition, Washington, DC, 1998.
                                    Bibliography

American National Standards Institute/ASQC, Specifications and Guidelines for Quality Systems
     for Environmental Data Collection and Environmental Technology Programs (E4), 1994.
NSF  International,  Environmental  Technology  Verification - Source  Water Protection
      Technologies Pilot Quality Management Plan, Ann Arbor, MI, 2000.
                                          59

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United States  Environmental  Protection  Agency, USEPA Guidance for Quality Assurance
     Project  Plans,  USEPA  QA/G-5,  USEPA/600/R-98-018,  Office of Research  and
     Development, Washington, DC, 1998.
United States  Environmental  Protection  Agency:  Environmental  Technology  Verification
     Program  -  Quality  and Management Plan  for the Pilot  Period  (1995  - 2000),
     USEPA/600/R-98/064, Office of Research and Development, Cincinnati, OH,  1998.
United States Environmental Protection Agency, Guidance for the  Data Quality Objectives
     Process,  USEPA QA/G-4, USEPA/600/R-96-055, Office of Research and Development,
     Washington, DC, 1996.
United States Environmental Protection Agency, Plain English Guide  to the EPA Part 503
     Biosolids Rule, USEPA/832/R-93/003, September 1994.
                                         60

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                        Appendices
 Appendix A Big Fish Supplied Data for Fecal Coliform; %
Moisture; E. coli; Enterococci; Cryptosporidium, and; Giardia
                             61

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Big Fish Supplied Data for Fecal Coliform in Biosolids



         _.  ,                 T                  Fecal Coliform        Percent Moisture
         Date                Location           /n™^/   •    ^\             /n/\
                                               (MPN/ g-dry wt)	(%)
1 1/06/08
01/27/09
05/13/09
05/13/09
07/01/09
10/06/09
10/24/09
Pile A
Pile A
Pile A
PileB
Pile A
Pile A
Pile A
<21
<18
<13
<26
<23
<26
<9.3
53
43
24
61
57
58
57
                                          62

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Report on Analysis of Treated and Raw Septage Samples
         from Big Fish Septage Treatment Plant


                       Prepared by

                   Sangeetha Srinivasan
             Department of Crops & Soil Sciences
                 Michigan State University

                   Date: 28th April 2010
                           63

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1. Introduction:

The Big Fish Environmental  Septage Processing  System operating at Charlevoix, Michigan
utilizing an aerobic biological treatment system to treat septage wastes and discharge the treated
effluent to the municipal sewer system. The treatment also produces Class A biosolids  after the
dewatering of solids.

Septage is pumped from the trucks into screens and a de-grit chamber, which then flows into an
equalization tank. The waste then goes through lime treatment process, after which it is pumped
through a  flocculation  tank  and a rotary screen  thickener  for biosolids  production.  Solids
produced are processed in a FKC screw press that heats up to a minimum of 50°C for a minimum
of 20minutes; the combination of lime and high temperature treatment reduces microorganisms
in the solids. Water extracted during solid production is then discharged into series of aerobic
treatment  tanks.  These  large  tanks  have  microbial  generators  that provide a source of
microorganisms. The  organic wastes  are reduced from the wastewater by  these organisms in
combination with naturally occurring microorganism. Water then enters into settling tanks, the
solid collected goes through lime treatment and screw press  processes. The clarified  water is
aerated further after which it is discharged as effluent into the municipal sewer system.

Fecal indicator organisms are used to assess the fecal contamination of water bodies as they
represent the presence of potential  enteric pathogens in water. Escherichia coli (E. coll) and
Enterococcus spp.  are the most commonly used indicator bacteria. Septage is one of the sources
of fecal contamination  of water bodies; others  include wastewater treatment plants,  manure
runoffs, wild life etc.

Our objectives were to analyze the level of indicator organisms (E. coli and enterococci) present
in influent and treated effluent by cultivation and qPCR methods and to evaluate the microbial
quality of Class A biosolids.  We also evaluated  the raw septage samples for Cryptosporidium
and  Giardia levels in  order  to assess  the  prevalence  of  these  parasitic pathogens in the
community and compare the trends of occurrence to those of sewage.

2. Methods:

2.1.  Sample collection:

Triplicates  of 50mL raw septage, SOOmL effluent and biosolids samples were collected, placed
on ice and  shipped to Water Quality and Health Laboratory at Michigan State University, East
Lansing, MI. Samples were collected on the following dates in 2009 for indicator analyses: June
23, June 25, June 30, July  1,  July 14, July 16, November 12 in 2009 and Jan 12  in 2010.
Immediately  upon arrival, the samples were processed. For Cryptosporidium analysis,  samples
were collected on the following dates:  Dec 17, 2008, and in 2009, Jan 28 , Feb 19, June  23, June
25, July 14, and July 21.
                                           64

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2.2. Sample processing:

One ml of raw septage  samples was serially diluted and these dilutions were used for further
bacterial indicator analysis. For effluent samples, volumes of O.lml, 1ml and 10ml were used for
analysis. Biosolids samples were processed by dispensing 30gm of the sample in 270ml of sterile
PBW and thoroughly vortexed. 10ml of this suspension was used for further analysis.

For qPCR analyses, 600|il of raw septage was directly used for DNA extraction. For effluent
samples, 50ml of the sample was centrifuged  at SOOOg for 20 minutes. The supernatant was
discarded and 1ml of the pellet was left behind. From this, 600 jil was used for DNA extraction.

2.3. Bacterial indicator analyses by cultivation method:

Samples were analyzed for E. coli and enterococci by using EPA membrane filtration Methods
1603  and 1600, respectively. Briefly, appropriate volumes were filtered through 0.45 um pore
size membrane filters. The  filters were then placed on mTEC and mEI plates for E .coli and
enterococci respectively. The mTEC  plates were incubated at 36°C for 2 ± 0.5 hrs after which the
plates are packed in a double Whirlpak bags and incubated in the waterbath at 44.5 °C  for 20 ±
2.0 hrs. The mEI plates were incubated at 41°C for 24±2.0 hrs. Colonies developed were counted
after the incubation period.

2.4. qPCR analysis:

The DNA extraction  was carried out from processed samples using Roche MagNa Pure  LC
instrument (Roche Applied Sciences, Indianapolis, Ind.). The qPCR analysis was carried out for
E. coli and enteroocci using primers and probes developed in  our lab and previously described
elsewhere (Frahm & Obst 2003).

2.5. Cryptosporidium analysis:

In brief, parasite  detection  was performed by  processing 5 ml of septage  according to EPA
Method 1623. This method  describes the examination of sample matrices for Giardia cysts and
Cryptosporidium oocysts.   Collectively, the environmental  form of these parasite  are termed
(oo)cysts.   5 ml of  septage was  diluted with  5  ml of reagent water in  a Leighton  tube.
The(oo)cysts were separated from the resuspended materials using the Dynal Immunomagnetic
Separation  Technique (IMS) (Dynabeads  CG-combo Kit, Dynal Biotech, Inc., Lake Success,
NY, USA). Modifications of  the  1623  protocol included  a second HC1 wash step  and
neutralization of the IMS concentrate within a microcentrifuge tube rather than on a  glass slide.
When  necessary,  excess debris was diluted by the  addition of 200 ul of sterile phosphate
buffered saline  (pH = 7.4). The (oo)cyst suspension was placed on  slides  and allowed to  dry
before samples were  fixed  with methanol and stained.  The  methanol also permeablized  the
(oo)cyst wall prior to staining with DAPI to help visualize nucleic acid content. Following the
DAPI  staining, an immunofluorescent assay (IFA) staining method, which uses monoclonal
antibodies   (EasyStain,   Biotechnology   Frontiers,   Australia)  tagged   with   fluorescein
isothiocyanate is used to specifically stain the  (oo)cyst walls. Microscopic examination of the
                                           65

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slides after IFA results in total  counts of oocysts and cysts in the sample. Positive staining
controls  consisted  of slides  with purified  Giardia  and  Cryptosporidium (EasyStain kit,
Biotechnology Frontiers, Australia. Negative staining controls consisted of slides prepared with
phosphate buffered saline in place of the sample.  These control slides were fixed, stained, and
read with each set of samples processed.

2.5.1. Recovery efficiency

Recovery efficiencies in laboratory reagent water were assessed by seeding 5 ml of reagent water
with  a  known  concentration of  Cryptosporidium  and Giardia  (EasySeed, Biotechnology
Frontiers, Australia). These ongoing precision and recovery (OPR) samples were processed  as
described above.  After processing, counts of Giardia and Cryptosporidium were compared  to
the number of seeded organisms  and a  method blank of  10 ml laboratory  reagent  water
containing no seeded Giardia and Cryptosporidium to calculate the method's efficiency. At least
one method blank and one  OPR were performed per week that  samples were analyzed.  To
determine recovery efficiencies in sample matrices, duplicate septage samples were seeded with
a known concentration of Cryptosporidium and  Giardia (EasySeed,  Biotechnology Frontiers,
Australia). These matrix spike samples were processed as described above. After processing,
counts of Giardia and Cryptosporidium were compared to the number of seeded organisms and
the number of naturally occurring Giardia and Cryptosporidium in the associated field sample to
calculate the method's efficiency  in the environmental matrices. At least one efficiency test using
water from sample sites was performed per week that samples were analyzed.

3. Results:

The  concentrations  of E.  coli and enterococci in raw septage and effluent samples for all
sampling dates as measured by cultivation methods are shown in Figures 1 &  2 respectively. The
average log transformed concentrations of E. coli were found to be 6.47 in raw septage and 3.96
in effluent with standard deviations of 0.45 and 0.86 respectively. The average log transformed
concentrations of enterococci were found to be 6.36 in raw septage and  4.07 in effluent with
standard deviations of 0.82 and 0.96 respectively.

The  concentrations  of E.  coli and enterococci in raw septage and effluent samples for all
sampling dates as measured by qPCR methods are shown in Figures 3 & 4 respectively. The
average log transformed concentrations of E. coli were found to be 7.33 in raw septage and 3.51
in effluent with standard deviations of 0.68 and 0.67 respectively. The average log transformed
concentrations of enterococci were found to be 7.31 in raw septage and  5.32 in effluent with
standard deviations of 0.36 and 0.28 respectively.

Log removal, as measured by cultivation methods, of E. coli during treatment ranged from 1.40
to 3.78  and that of enterococci ranged from  1.50 to 3.15. qPCR analyses showed log removal
ranging from 2.88 to  4.75 of E.  coli and that of enterococci  ranged from 1.34 to 2.46. These
results are summarized in Table 1.
                                           66

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All of the biosolid samples had concentrations of E.coli and enterococci below the detection
limit, which is 0.33cfu/g. qPCR analyses was not performed for the biosolid samples.

Giardia was found in all untreated septage samples. Cryptosporidium was found in 3 out of 7
samples. Giardia was between 2 to 3 logs higher than Cryptosporidium which is a trend common
in sewage.  There was variability in detection of Giardia even though it was always detected.
Variability with 2 logs was observed.
   o
   uj
   £  £
8.00
7.00
6.00
5.00
4.00
3.00
2.00
1.00
0.00
           fe-
Figure 1: Comparison of log transformed concentrations of E. coli in raw septage and
effluent by cultivation methods.
  •
  8.00
  7.00
  6.00
  5.00
  4.00
  3.00
  2.00
  1.00
  0.00
Figure 2: Comparison of log transformed concentrations of enterococci in raw septage and
effluent by cultivation methods.
                                          67

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   £
   o
   o
    V
                                     V
Figure 4: Comparison of log transformed concentrations of enterococci in raw septage and
effluent by qPCR analysis.
                                           68

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Table 1: Log removal of E. coli and enterococci during treatment through the Big Fish
Environmental Septage Processing System
Sampling
dates
6.23.09
6.25.09
6.30.09
7.1.09
7.14.09
7.16.09
11.12.09
1.12.10
E.coli
cfu/lOOml
3.78
3.41
2.49
3.23
2.57
1.52
1.71
1.40
Enterococci
cfu/lOOml
3.08
3.15
1.76
2.91
2.50
1.58
1.83
1.50
E.coli
cells/lOOml
3.91
2.88
3.40
3.35
4.18
4.75
4.23
3.85
Enterococci
cells/lOOml
2.26
2.11
2.02
1.77
2.15
1.79
2.46
1.34
Table 2: Levels of Giardia and Cryptosporidium in raw septage samples

Date
Collected

12/17/2008
1/28/2009
2/19/2009
6/23/09

6/25/09

7/14/09

7/21/09

Volume
Collecte
d
(liters)
1
1
1
1

1

1

1


Organism

Giardia
Cryptosporidium
Giardia
Cryptosporidium
Giardia
Cryptosporidium
Giardia
Cryptosporidium
Giardia
Cryptosporidium
Giardia
Cryptosporidium
Giardia
Cryptosporidium
Sample
Volume
Examined
(mL)
5
5
5
5

5

5

5


Total Organisms
Detected

262
0
38
0
1591
1
1165
0
1278
1
757
2
759
0

Concentration
Organisms /mL

52.4
<0.2
7.6
<0.2
318
0.2
233
0.2
255.6
0.2
151
0.4
151.8
0.2
References:

 Frahm, E., and U. Obst. 2003. Application of the fluorogenic probe technique (TaqMan PCR)
to the detection of Enterococcus spp. and  Escherichict coli in water  samples. J. Microbiol.
Methods 52, 123-131.

Method 1600: Enterococci in Water by Membrane Filter using membrane
Enterococcus Indoxyl-B-D-Glucoside Agar (mEI). 2002. EPA-821-R-02-022. Office of Water,
Washington D.C.
                                         69

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Method 1603: Escherichia coli (E. coli) in Water by Membrane Filtration using
Modified membrane-Thermotolerant Escherichia coli Agar (modified mTEC). 2005. EPA 821-
R-04-025. Office of Water, Washington D.C.
                                          70

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           Appendix B Verification Test Plan
(NOTE: Appendices are not included in the Verification Report. Appendices are
available from NSF upon request.)
                                71

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Appendix C Big Fish Operation and Maintenance Manual
   (NOTE: Appendices are not included in the Verification Report.  Appendices are
   available from NSF upon request.)
                                  72

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  Appendix D Pictures of Test Site and Equipment
(NOTE: Appendices are not included in the Verification Report.  Appendices are
available from NSF upon request.)
                              73

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Appendix E Spreadsheets with Calculations and Data
                       Summary
(NOTE: Appendices are not included in the Verification Report. Appendices are
available from NSF upon request.)	
                              74

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Appendix F Lab Data, QA/QC Data, Field Logs, and Records
     (NOTE: Appendices are not included in the Verification Report.  Appendices are
     available from NSF upon request.)
                                  75

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