Dear Mr. Briggs: The Reclamator Dialogues Continue
The following email is from Mr. Murphy to Mr. Briggs of the RWQCB. Now, will somebody – a judge? Mr. Briggs? Jerry Brown? Paavo Ogren? -- please come forward and tell us what “discharge” means, what levels of coliform are allowed out of a “wastewater” pipe, what “wastewater” means, what "pollutants" and other good stuff means. OR explain why the RWQCB doesn't have to define these terms and rule on whether the Reclamator does or does not meet whatever standards and definitions are or are not defined. Or something? Somebody? (Interesting note vis a vis fecal coliform. If the surface soil around our homes was tested right now, how much fecal coliform would be found from . . . dogs, cats, gophers, mice, birds, humans? And how much can be found in our drinking water coming out of the faucet? Hmmmm
Dear Mr. Briggs,
Please see attached data of the RECLAMATOR.
Fecal Coliform is “Not Detected”. The spiral wound ultra-filtration membrane is designed to provide a “definite barrier” to fecal coliform in excess of “2” MPN/100ml. (Title 22 requirements is: Fecal/Total Coliform less than 2.2 MPN/100ml, however, Title 22 requirements only applies to public agencies and does not apply to applications on private property, which all RECLAMATOR applications are on.)
Total Coliform has no Maximum Contaminant Level (MCL) in itself and is:
“Not a health threat in itself; it is used to indicate whether other potentially harmful bacteria may be present5 (“Potential Health Effects from Ingestion of Water”, USEPA Safe Drinking Water Standard, pg. #3)
5 Fecal coliform and E. coli are bacteria whose presence indicates that the water may be contaminated with human or animal wastes. Disease-causing microbes (pathogens) in these wastes can cause diarrhea, cramps, nausea, headaches, or other symptoms. These pathogens may pose a special health risk for infants, young children, and people with severely compromised immune systems.” (“Sources of Contaminant in Drinking Water”, USEPA Safe Drinking Water Standard, pg. #3)
Additionally, “Coliforms are naturally present in the environment; as well as feces; fecal coliforms and E. coli only come from human and animal fecal waste.” (USEPA Drinking Water Standard)
In typical wastewater industry practices, “definite barrier” means to control Fecal Coliforms are not utilized, but only methods of disinfection of wastewater effluents using typically chlorine and UV. Fecal Coliforms will frequently pass through these types of disinfection methods without detection and presents of Total Coliforms will indicate such possibility of Fecal Coliforms passing. However, in the case of the RECLAMATOR’s physical control technology (a spiral wound back-washable ultra filtration membrane with ultimate integrity) has been employed to guarantee no such possible passage and therefore, a presence of Total Coliforms for non-drinking water applications does not pose a public health risk and therefore is not an issue.
Maximum Contaminant Level Goal (MCLG) - 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.
As “there is no known or expected risk to health” from a presence of Total Coliforms when a “definite barrier” membrane is in place that assures NO Fecal Coliform is present in excess of “2” MPN/100ml, a Total Coliform count represents “no known or expected risk to health” and as such, is a “non-enforceable public health goal”.
Upon your awareness of this information, AES demands the Central Coast Regional Quality Control Board expediently promulgate, as is their fiduciary duty under U.S.C Title 33 Chapter 26, the requirement for the application of the RECLAMATOR, as best available control technology economically achievable as is defined within the U.S.C Title 33 Chapter 26, at each private point source discharge of each source within your jurisdiction to comply with the pretreatment requirements of such U.S.C. as the other than publicly owned treatment works (privately owned) part of a community collection and treatment project (publicly owned treatment works) within Los Osos Prohibition Zone. (U.S.C Title 33 Chapter 26 Sec. 1317 (a)(b)(c))
As the RECLAMATOR eliminates the discharge of pollutants at the source, the Community of Los Osos will not be subject to any unnecessary economic burden for a publicly owned treatment works (collection laterals with centralized treatment facilities) besides the RECLAMATOR alternative.
AES is initiating its campaign to provide discharge elimination services throughout the Los Osos Prohibition Zone this week. Without the Central Coast Regional Water Quality Control Board’s promulgating the requirement of the RECLAMATOR to comply with the federally mandated pretreatment requirements in the Los Osos Prohibition Zone as per such requirements under the federal water law, AES is sure to incur additional unnecessary hardships in its marketing efforts in providing the federally compliant and county permitted pretreatment alternative RECLAMATOR resulting from the Central Coast Regional Water Quality Control Board’s not performing under their fiduciary duty as is require by state law.
Please promulgate immediately in the interest of the water, the environment and in the best economic interest of the public of Los Osos.
D. Thomas Murphy
The RECLAMATOR, “The Future of Our Water”
Advanced Environmental Systems, Inc.