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Tuesday, September 04, 2007

Professor Harold Hill and 76 Trombones? Or a Mini-Tri-W in Every Yard? Or Bwa-hahah, Over My Dead Body?

Tom Murphy of Advanced Environmental Systems gave a brief presentation before some Los Ososians last week after he had presented his 53 page proposal for onsite systems for Los Osos to the BOS. Several years ago, he had come to town with an onsite system that claimed to match or exceed the discharge numbers then being proposed for Tri-W. However, the RWQCB has ruled NO ONSITE SYSTEMS BECAUSE IT’S NOW NO DISCHARGE OF POLLUTANTS WITHIN THE PZ.

So Mr. Murphy has come back with the “Reclamator,” a sort of in-tank, mini- Tri-W, MBR-type “treatment plant”, using “ultra filtration spiral wound membrane into the decanter” (i.e. part of the tank) that is able to “meet the Maximum Contaminant Level Goals” which is the EPA standard which defines water having no pollutants,” i.e. no “discharge” of “wastewater.”

At the Los Osos meeting, he stated he’d be at the RWQCB on Friday (since he isn’t on the agenda, all he can do is present the same 53 page information during Public Comment and ask that it be reviewed by staff and possibly agendized at a future meeting?) and supposedly he will be meeting with the county at some point.

What follows is from an email from Mark Low, who’s working with Mr. Murphy. It remains to be seen how this will be received, whose definition of “wastewater” and “discharge” prevails (RWQCB or EPA?) and whether the various testing data supports the “Nowastewater” claims of AES, Inc.

Not being a scientist or engineer or even playing one on TV, I vouch for none of this. Both the county and RWQCB will be taking a look at whatever test data is available. The CSD should also take a gander. Mr. Murphy could be Professor Harold Hill or his system could be the most cost effective alternative to what’s been proposed to date. IF his test results are accurate and the system actually does work like a little mini-Tri-W in an onsite tank with “clean” water coming out of the end, water that would be available onsite to water your petunias, and does it all for less than $100 a month, then the community will be in a quandary:

If the Reclamator doesn’t “discharge” wastewater, the RWQCB has no say in the matter since you don’t need a “discharge” permit if you’re not “discharging” anything. If the Reclamator doesn’t discharge “wastewater” there is no need for a 218 vote – individuals can simply sign up for the “service” being offered at the agreed upon price & etc. OR, If the Reclamator works, will the County be obliged under CEQA review, after the 218 vote, to do due diligence on it as an “alternative” and if the alternative actually works, doesn’t require a permit because it’s not “discharging” anything,” then is the County required under law to pick the best available technology that does the job at the cheapest price? (To date, no onsite systems have been looked at because of the RWQCB’s Hobson’s Choice game they’ve been playing for years on same. The “alternatives” the TAC looked at were all municipal collections/treatment systems, not really “alternatives” at all.) Or will this proposal simply be “forgotten to death,” the evaluations postponed (Gosh, we’re really busy here) until the clock runs out and it becomes a case of Death By Being Ignored To Death, Oh, Darn, If Only We’d Known, Too Late, Ooops, Heh-heh?

Either way, if the Reclamator works, expects battle to erupt over definitions, over who’s the controlling party (local? State? Feds?), be prepared for goal posts to get moved all over the place, obstacles of all kinds to be tossed up, legal threats, lord knows what. (To date the RWQCB has a history of making assertions not backed up with empirical scientific evidence and so relies on the victim of the assertion to personally finance a ruinously expensive court case to prove the assertion wrong, that is, “guilty before proven innocent,” not the other way around.)

Mr. Low stated that he’d soon be posting the 53 page report on line, so people could read it for themselves. For the rest, Mr. Murphy’s shoe has been dropped before the BOS and apparently the RWQCB.

Stay Tuned for The Reply.

Herewith, Mr. Low’s email:

Sent: 9/3/2007 2:22:37 PM
Subject: Test Results - A Water Reclamation Service Agreement/Dutyof Care/Drought Solutions/Annot...

Ann:

This will serve to keep the focus on the Technology as is required by USC Title 33 Chapter 26 (C26).

The last paragraph of the AES Technology Description defines the quality of the water produced by the RECLAMATOR.
The
The 1994 NSF Report demonstrates the "BESTEP" Process.
Tom, on his own volition, paid to have the Nitrogen testing done because he knew "then" the importance of it.

I know of no other "at source" alternative technology which can achieve the level of treatment as demonstrated in the testing data.

Within the past 3 years, he has added an ultra filtration spiral wound membrane into the decanter to enable the BESTEP (UF-900) to meet the Maximum Contaminant Level Goals (MCLG) which is the US EPA Standard which defines water having no pollutants, the national treated drinking water standards. The MCLG, not to be confused with the MCLs, is "The level of a contaminant in drinking water below which there is no known or expected risk to health. MCLGs allow for a margin of safety and are non-enforceable public health goals." Please make note of the "non-enforceable" component of this definition.(See: http://www.epa.gov/safewater/contaminants/index.html ) When the "discharge of pollutants" is eliminated, the requirement for a "discharge permit" is also eliminated, as a "discharge permit" is a measure of enforcement. Additionally, C26, Section 1311 (a) additionally clarifies no discharge permit is required unless there is a discharge of pollutants. The BESTEP UF-900 does not discharge pollutants.

A Membrane is a physical "definite" barrier the discharge of pollutants. Unlike a process which solely uses biological treatment, the addition of a definite barrier membrane "consistently and reliably" assures the quality of water which is produced. The quality of water (reclaimed/repurified) produced by the BESTEP UF-900 is: 100% removal of colloids and particulates larger than 10 nano meters, turbidity less than 0.1 NTU, over log 6 removal of bacteria (99.9999% removal), over log 4 removal of viruses (99.99% removal), and removal of large molecular weight organic compounds (above 100,000 Daltons).

BESTEP + Membrane = BADCT (best available demonstrated control technology)

The BESTEP eliminates the need for any collection system and thereby complies with the requirements of C26. The post federal grant cost to each DUE will be $3,500 with a monthly service fee of $45.75 per month.

Any other area-wide waste management solution which might be proposed by the County, as is required by C26, would have to have a life-cycle cost of not more than 15% of the most cost effective alternative. (See Sec. 1281 (j)) This means that, to comply with federal law, such solution if it were to be proposed by the County, would 1) have to be equal in technology and performance, and 2) be required to cost no more than $20 million dollars "installed".

BADCT is required to be promulgated and used when possible, as required by C26.

Howard Kolb previously communicated to Mr. Murphy that if the LOCSD had
proposed the BESTEP 10 as the solution for Los Osos, the State WaterBoard would have approved it.

Mark
480.363.1154

19 comments:

4crapkiller said...

Ann: Good work and thank you. We await full details of the system and hopefully it is not experimental, and has been proven to work in numerous places. Nobody get your hopes up yet until full facts and data is available.

This is not a reason to vote NO on the 218 vote. If this device actually works, only the county will have the legal resources to change the course of thinking of the CCRWQCB, and they will need our assessment money to persue this change.

4crapkiller said...

Another comment:

AB2701 REQUIRES the county to perform "due diligence". They would be in violation of the law if they did not completely investigate this system.

4crapkiller said...

Another comment:

A google search showed nothing about BESTEP-10 or BESTEP UF-900.

Area51 said...

"This is not a reason to vote NO on the 218 vote. If this device actually works, only the county will have the legal resources to change the course of thinking of the CCRWQCB, and they will need our assessment money to persue this change."

Well put Crap, but I am more than cynical enough to believe that is EXACTLY why the cargo is gonna start flying right now: to attempt to persuade people to vote against the 218. Timing is everything, and the closer we get to the vote, the more cargo will fly. Just another "better, cheaper, faster," or "$100.00 per month, we're ready to go" claim. The sewer saga is replete with attempts by those who who oppose paying for ANY sewer to confuse, obfiscate, misdirect, pray for cargo, lie, cajole, threaten, manipulate, and promise the moon if it means avoiding a project. Ask Al Barrow, the master of manipulation, he of the "I can delay a sewer for eternity" fame. Can't help but think his hands are all over this one....again.

But than again, like I said, maybe I'm just a cynic. Don't know how THAT happened.

TCG said...

I agree that, in no way, should this concept impair the 218 vote. Without a successful vote, the County can not fully investigate ideas such as this one, or the decentralized plan of a few months ago.

The staff stated very clearly at their recent Prop 218 hearing that the amount of the assessments being voted on is the maximum that can be assessed on the properties. If the actual cost is less, they must assess less.

So, this appears to me to be just one more idea that is probably too good to be true, but will get it's full review through the County process if the people support A PROJECT by voting yes.

4crapkiller said...

I agree totally with area51 and tcg. "Due diligence" from all of us is required. Ann, our leader, has hammered this home. Beware of Greeks bearing gifts! If this is just another "headless brown trout" it will be seen as such, otherwise it will be seen as what it is.
Thank you both for your comments.

Sewertoons said...

If they have not installed one - or better - thousands of these in "Reclamators" in California, I sure don't want Los Osos to be the canary in the mine that "tests" the Water Board. They have no website that I can find. No reference to the product "Reclamator" except on this start-up site. A little short of 10 years nitrogen reduction perhaps?

http://www.gobignetwork.com/profiles/Annette-Dundas2.aspx?Keywords=reclamator&page=1&PageSize=10&SortBy=6&SearchType=FS&ReturnURL=%2fsearch%2fstartups%2fall.aspx%3fKeywords%3dreclamator

4crapkiller said...

Sort of troubling. Why is there no information trail on this? Maybe I have been not looking for the right thing or in the right place. I await additional information as I am sure the engineers on the staff of the BOS await. Maybe their 53 page document will bring forth information. Hope we can get our eyes on it soon.

Shark Inlet said...

Speaking of flying cargo, I got in the mail today a huge flyer chock-full-o-questionable-info. So, who the heck is the "Committee for Los Osos Property Owners"? Just like Ann, they raise good questions and then they give answers which I think are entirely unfounded and then they suggest the conclusion that voting no on the 218 is a good way to get a far lower costing project that will be completed far sooner.


Hopeful optimism such as is seen in this flyer is what brought us the original CSD and then the recall. Both times we were told something like "better, faster, cheaper" and now yet another group is promising the same snake oil.

Is it just hopeful optimism or is it something else ... a deliberate attempt to manipulate the situation to stall the sewer yet again for some unstated purpose.

Mike said...

Just another pea in the "Let's-all-delay-any-sewer" shell game!

4crapkiller said...

To Sharky:

I got the same big yellow flyer and it came standard presorted mail. This is a very impressive flyer for the uninformed. I wonder who paid for it? Who is the committee?

The first thing I did was to go to GE Capital. There is no way Orenco/Ripley is going to get a loan at 5.5% interest from GE Capital. GE Capital loans money to make money. Like a bank, they borrow money, and then loan it out at a profit. Currently Aaa Corporate Bonds are returning very close to 6% to large investors. GE would be paying about the same for money. They would have to be loaning money at at least 2 1/2 percentage points higher to very well capitalized companies. While it is true that GE loans money at cost, it is only done to it's own insurance company, and it is short term. Thus this is the first blatantly obvious piece of misinformation. GE does not publish its rates in the story of it's recent deals.

I cannot understand how GE Capital would allow it's name to be used, unless GE stands for Gerald Edwards. I am also surprised that Ripley would allow it's name to be used when so many costs are uncertain. Then there is the CCRWQCB that made Ripley reconsider its figures originally to handle nitrate reduction.

In the meantime this is the best collection of truths with half truths and outright BS I have ever seen. Absolutely beautiful!

Maybe I should put out a flyer that says vote YES because there are Senators and Representatives in The US Congress that will make sure we only pay $10 a month.

Churadogs said...

SPOILER ALERT: Crap sez:" agree totally with area51 and tcg. "Due diligence" from all of us is required. Ann, our leader, has hammered this home. Beware of Greeks bearing gifts! If this is just another "headless brown trout" it will be seen as such, otherwise it will be seen as what it is.
Thank you both for your comments.

12:10 PM, September 04, 2007"

DING! DING! DING! FRAUD ALERT HERE
In previous postings, Crap made a clear pronouncement regarding property ownership vis a vis stating opinions. She/he even went to far as to access property records to see if I was a property owner. The reason given by CRAP was as followers (10:02 a.m. Sept 04,07) "Opinions and pronouncments are backed up by a stake in an issue. The weight of these are determined by the size of the stake. Get it?" and a previous entry of 1:13 p.m. August 31, 1007," This [property ownership] gives a GREAT AMOUNT of weight to your opinions. It also shows that YOU are not operating as a FRAUD in property owner matters."

The problem here for Crap? Crap is an anonymous poster pretending to be a property owner. Because she/she is anonymous there is no way to check his/her status as a property owner via the county records. Therefore, a FRAUD ALERT to all who read Crap's "opinions." Until she/he identifies herself/himself so her property owning status can be verified, we shouild all heed her/his own words that she/he may well be a FRAUD and so no weight can be given to his/her opinions.

Shark Inlet said...

Um ... Ann ...

Weight should be given to all opinions presented here. The weight given to the opinions should be in some way related to the quality of those opinions, the reasonability of the poster and what we know about the biases of the poster. If we know that someone is a property owners, for example, we know that the individual will be ... for sure ... be affected differently by the very real consequences than if we know the individual is a renter.

That we don't know FOR SURE that Crapkiller owns property doesn't make her opinion worthless as you suggest ... just something that should be taken with perhaps a bit more salt than if we knew her real name. Even then, I would suggest that we don't even know that the author of this blog, churadogs is the REAL Ann Calhoun who owns those properties in Los Osos.

4crapkiller said...

Ann: You are absolutely correct! Since I an anonymous, it may be ASSUMED that I am a fraud. You make lots of ASSUMPTIONS but you are not a fraud: Just biased to a fault. Or: "don't want to pay, just delay", maybe?

My writing has always stood on it's own merits. It just does not have the same weight as your writing. After all, this is your blog, and it is proven you own two pieces of property in the PZ!

DING DING DONG DAMMIT! FRAUD ALERT!

Your accepted argument goes two ways: The yellow flyer I received came from a totally unidentified "Committee for Los Osos Property Owners". Besides the content, it must be ASSUMED fraudulent! We will be going down to the SLO post office to find out who owns Permit #7 (Federal Public Record) and perhaps file a complaint for MAIL FRAUD. In addition there has to be a law somewhere to stop this kind of voting FRAUD from going on.

Another point: If you believe without documentation the pronouncements of Murphy and Low, then it is all the more reason to vote YES on the assessment. We will need the county to bring this to fruition and get the CCRWQCB to allow this. No SPOILING HERE!

In any case the ballot for one of my properties came yesterday. $35K plus assessment. I await the other one. Probably today. Bargain! Since I bought my property, the equity has increased eight fold in ten years (800%). Soon as we get a sewer, it will go up even more, and easily pay for the assessment and interest. Vote YES! When you do be sure to make copies of your signed ballot for evidence or other action if the YES vote fails.
You may need it to mitigate a $900 a month discharge permit.

Of course, many will be looking at how YOU vote, since you have been an outspoken anti-sewer activist.

Time comes when you have to put your money where your mouth or script falls. My money goes with a YES! YES!

You might look at you own property. Sort of ridiculous to be "penny wise and pound foolish".

Figure it out. The demand for clean air coastal property will always continue to climb after the glut is cleared. Where else is building allowed on the coast? Where else can one live without high air conditioning and heating bills? And where else is such a central location on the coast within easy reach of SF, LA, Bakes, and Frisbee? Great schools! One of the finest universities in the nation!

Already, SLO county is considered one of the finest places in the US to live.

Conspiracy Boy said...

CrapKiller:

Keep Dreamin'

You wait, in one year the house prices will drop further. People will really be able to get some real deals here. Houses are selling now for in the $300,000 - $400,000 range. Wow, these same homes would have sold for $500,000 - $600,000 a few years ago. Some up for sale are real nice. People with cash that can wait for a year or two are going to get a tremendous deal in Los Osos (while thousands have to leave their homes.)

That's what your blind vote/blank check vote is going to cost you.

Let's see, you'll loose $200,000. right off the bat.

Another two years, more lowering of the house prices.

You fool.

P.S. Are you Gordon?

Sewertoons said...

cb, are you a realtor? Do you work in an escrow company?

Mike said...

Hey CB,

I'll give you $300K right now!!!

30 day escrow! You won't have to wory about the continual decline in prices, just pack and go, no more worries...

4crapkiller said...

I think CB is like Al Barrow. If it took 2 cents to go around the world, he probably could only go fifty feet.

Churadogs said...

Crap sez: Of course, many will be looking at how YOU vote, since you have been an outspoken anti-sewer activist."

Wrong again. I have never been anti-sewer. You've blinded yourself by your language. Not good, Crap. But you have self-identified as a FRAUD. Thanks. I'll need to keep reminding folks of that.

Crap, the FRAUD, sez:"and perhaps file a complaint for MAIL FRAUD. In addition there has to be a law somewhere to stop this kind of voting FRAUD from going on."

If I'm not mistaken, mail fraud involves selling phony stuff and using the U.S. mails to do it. This is an opinion/campaign flyer. Whoever wrote it is not selling something for, I think, five bucks or more, that they know to be worthless, and using the U.S. mails, so to my knowledge it's not mail fraud. Doesn't your "male friend," you know the one show's great pals with the Supreme Court, have a clearer definiton as to what constitutes mail fraud? I thought you implied he was some kind of legal expert who was going to hold people responsible for their opinions and other ridiculous "threats," from a person now self-identied as a FRAUD. Hmmmmm, again, not good Crap.