I've seen several reports over the years, but I don't know which one you're referring to, so I don't know if I've seen that one. If you have a copy, I'd appreciate your sending me one...I can send you my email address via PM.
The major flaw in most of the reports is that they use the standard set forth in the CFR--a max bacteria count of 1000/100 ml--when the ACTUAL bacteria count from two of the only 3 treatment devices made in the US (Raritan LectraSan/ElectroScan and PuraSan) is <10/100 ml and is -0- from Groco ThermoPure.
If those who tested the Groco didn't get that result, it's most likely because they didn't know how it works. It uses heat to kill bacteria, so requires both 115v/AC power for the heater and DC power for the overboard pump. Plus, unlike the Raritan devices, it's fairly complex and takes a LOT of time to treat completely, plus it's VERY expensive...making it really only suitable on boats 40'+. You can read all about how it has to work here
Groco Thermopure-2 Owners Manual and pay close attention to the Treatment Capacity section.
So if the EPA used the ThermoPure as the basis for making ANY waters a NDZ, they based it on a device that's unlikely to be installed on even as many as .5% (that's 1/2 of 1%) of boats in the whole US...fewer 5% have any treatment device!
--Peggie