THE ENVIRONMENTAL TECHNOLOGY VERIFICATION
                                         PROGRAM
        U.S. Environmental
        Protection Agency
                                         NSF International
                         ETV Joint Verification Statement
   TECHNOLOGY TYPE:
   APPLICATION:
WASTEWATER TREATMENT - CHEMICAL ADDITION,
FILTRATION AND BIOLOGICAL TREATMENT
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
infoi@,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,  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.
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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 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

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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 plan'-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.

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.

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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

                          BODS (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.

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
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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.

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
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 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
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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                                      Original signed by
  Sally Gutierrez	October 26, 2010           Robert Ferguson	November 2, 2010
  Sally Gutierrez                   Date                 Robert Ferguson                        Date
  Director                                                Vice President
  National Risk Management Research Laboratory        Water Programs
  Office of Research and Development                   NSF International
  United States Environmental Protection Agency
    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 Waste-water 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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