The following email exchange took place between myself and Mr. Tom Murphy. I had received an email cc noting that the county had issued Mr. Murphy a “permit” for his Reclamator, which he had installed in his home. Tribune even had a photo and story on the installation.
Mr. Murphy’s e-mail 1
Barry Tolle, County of San Luis Obispo Building Permit Department, contacted my attorney yesterday, Patrick Sparks, to inform him that he had received a call from Harvey Packard, Central Coast Regional Water Quality Control Board Section Manager and Enforcement Coordinator, advising him to issue a permit for the RECLAMATOR.
Best regards,
Tom Murphy
My email reply to Mr. Murphy:
Mr. Murphy, it's not clear from this: Was this a county permit to install a "septic tank" -type device, the same kind of county permit I got, for example, when I put in a new leachfield, signed off by the County since it's not a "new" device, merely a "replacement" device (i.e. I wasn’t adding any bathrooms.)
Or was this an official RWQCB "discharge" permit from the RWQCB allowing you to "discharge" whatever is "discharged" with set nitrate levels and other levels, plus testing requirements and etc, like the "discharge" permit granted to the (recalled) CSD for Tri-W/Broderson "discharge" site?.
It's my understanding that until 2011 people in the PZ are free to replace "septic type devices" and leachfields to their heart's content. (no new ones allowed, just replacements, repairs, etc.). After 2011 (or whenever the whim strikes Mr. Packard), anyone not hooked up to the sewer will be getting CAOs, or whatever Harvey wishes to send them.
In short, there's "permits" and then there's, uh, . . . "permits." and it's not clear to me from this email, which one you're referring to.
Thanks for any further explanation.
Mr. Murphy’s reply:
Good Morning Ann,
Some basic facts you must know first:
Harvey is a liar.
He has no authority to act on what he says.
The Water Board is not long for this world as there is no more “discharge” to permit. (I will forward you an email I sent to Lisa and Steve last night)
The Water Board doesn’t have any authority to “issue” any permit on an individual dwelling, only to a government agency.
The only permit required for the RECLAMATOR is a “building permit”, which is what I have.
The RECLAMATOR is connected to the LOCSD’s publicly owned sewer system.
This establishes the demise of the County sewer project as now one of two precedents are about to be set, both of which stops the funding capability of the County project.
The LOCSD will now be obligated to issue to me an “Exemption from Required Connection”, or
The LOCSD will now be obligated to issue to me “payment for my harvest water” produced by the RECLAMATOR.
Either of these STOPS the County project from happening as now the achilies heel has been cut, their ability to gain financing for the project.
You may ask how? The standard requirement for a public entity to borrow (bond) a sewer project is to provide the lender a “guarantee” of 100% hookup of all DUEs within the to-be-sewered area. They CAN’T do this anymore as anyone will have the right to install the RECLAMATOR. Once the RECLAMATOR is installed on private property there is no revenue to pay for the sewer project (as all money has to come from the people as the government has no money). With a RECLAMATOR:
The government entity will be obligated to “pay” the homeowner upon a “required hookup” to receive the homeowner’s water; the homeowner doesn’t pay the government for sewer service.
Any homeowner currently connected to any government provided sewer service now has the choice to “disconnect” from a sewer service, install the RECLAMATOR and stop paying the government entity anything in regards to a publicly provided sewer service.
Once you understand this, which has been my goal to achieve since I got here knowing what this does, you will understand the Water Board no longer has any power to do anything to anyone who has a RECLAMATOR.
The County sewer project is already “dead” and all they are doing now is burning up the money they currently have access to. They can’t implement the 218 assessment as it is unlawful and we have already pointed it out (thus the reason you have not already recienved the assessment which was suppose to be placed on your property at the end of the year last year, and wasn’t for this reason.
Hope this explains it. I will invite you over to see the RECLAMATOR in action very soon.
It is already over as the first domino tipped and has started falling and there is no stopping it now……
I will have the permit particulars faxed to Mark today for all to see. It actually is a permit for the entire Los Osos project which we submitted 5 months ago to the LOCSD.
Have a GREAT DAY!!
And my reply, again:
Thanks for your reply. A follow up question or two:
1. Didn't the CSD get an ACL & multi-million dollar fine for "discharges" against their communal Bayridge Estates septic "discharges," and as a Bayridge home-owner, won't the share of that fine have to be paid by each homeowner in Bayridge?
2. Was or has the CSD been given a "discharge" permit for the Bayridge collective "discharges" by the RWQCB? Since each homeowner is hooked up to the collective system, you claim that the RWQCB didn't (or can't?) issue an individual CDO against each homeowner since the CSD is, I guess, legally responsible for the collective tank and collective "discharges." But I presume the RWQCB can issue a discharge permit to a government agency, in this case, the CSD. Did they? Have they? Will they?
3. The statement that the Water Board doesn't have authority to issue any permits to individual dwellings is true, but they’re working hand in glove with the County. As for their ability to issue CDOs and CAOs against individuals, (rather than a public entity), that remains remains, for me, unproven in court. I don't know if the PZLDF case will settle that matter or if it will take another case in another court. I also don’t know if the PZLDF case will settle just what a “discharge” is, but I've maintained that SOMEBODY needs to settle that authority,(and those definitions) sooner rather than later. So, until that happens, I'll remain highly skeptical on that claim.
4. Why would you connect your Reclamator to the Bayridge collective system? I thought the whole point was it didn't need to be connected to anything? That whatever is "discharged" out the end of it is usable water that can stay on your property, to be used as you see fit. And if you have connected it to the central system, how can you "test" your "discharges" or do any soil testing or whatever to "prove" whatever you need or want to prove, if whatever you're "discharging" simply goes down a pipe into the collective holding tank and thence into the two collective leachfields? I don't get that. The Tribune gave you a "bouquet" (March 7, "The Reclamator needs a test drive,) but if you're hooked up to the Bayridge system, how can you "test drive" anything?
If your tactic was to put the water into the system, then charge the CSD for the value of that water, why wouldn't the CSD consider that merely a personal option? Since you claim the Reclamator doesn't "discharge" waste it doesn't need any kind of "permit" from the RWQCB and therefore is under no threats whatsoever, you're under no obligation (or threat) to hook up to anything. Since that's a "choice, why wouldn't the CSD simply say, No thanks, we won't allow you to hook up, we're not buying your valuable clean water, and since your Reclamator doesn't "discharge" you don't need to hook up to anything.
Anyway, hope you can clarify some of my further questions. Also, I'd like to post this email exchange on my blog, but will need permission to do so. I've lined up the emails so they make a coherent whole. I'll be out of town for a few days, so will hold all this until I receive your permission.
Thanks.
And Mr. Murphy’s email:
The Water Board doesn’t have any authority to “issue” any permit on an individual dwelling, only to a government agency.
The only permit required for the RECLAMATOR is a “building permit”, which is what I have.
The RECLAMATOR is connected to the LOCSD’s publicly owned sewer system.
This establishes the demise of the County sewer project as now one of two precedents are about to be set, both of which stops the funding capability of the County project.
The LOCSD will now be obligated to issue to me an “Exemption from Required Connection”, or
The LOCSD will now be obligated to issue to me “payment for my harvest water” produced by the RECLAMATOR.
Either of these STOPS the County project from happening as now the achilies heel has been cut, their ability to gain financing for the project.
You may ask how? The standard requirement for a public entity to borrow (bond) a sewer project is to provide the lender a “guarantee” of 100% hookup of all DUEs within the to-be-sewered area. They CAN’T do this anymore as anyone will have the right to install the RECLAMATOR. Once the RECLAMATOR is installed on private property there is no revenue to pay for the sewer project (as all money has to come from the people as the government has no money). With a RECLAMATOR:
The government entity will be obligated to “pay” the homeowner upon a “required hookup” to receive the homeowner’s water; the homeowner doesn’t pay the government for sewer service.
Any homeowner currently connected to any government provided sewer service now has the choice to “disconnect” from a sewer service, install the RECLAMATOR and stop paying the government entity anything in regards to a publicly provided sewer service.
And Mr. Murphy’s further reply
Hello Ann,
You may run anything you want…thanks for asking, I appreciate it.
I hope you had a good time during your travels. I don’t recall your 3/8 mail but I’ll look for it.
In regards to “permits”, we received a “building permit” to install the RECLAMATOR. The RECLAMATOR doesn’t require a “discharge permit” as the RECLAMATOR doesn’t “discharge” as it is demonstrated to produce “reclaimed water” which contains “nitrates” of less than 7 mg/l (the established “effluent limitation” for the prohibition zone). This means anything over “7” is “effluent” (which is “wastewater”) or a “discharge of waste” and would be subject to “discharge permit” requirements because anything over “7” is considered a “pollutant”. Because my water quality is far less than “7”, there is no “discharge”
I know Gail McPherson has totally confused everyone in LO telling them “discharge” means ANY discharges (most people believing this to also include potable water…, not true). She was wrong, probably because she listened to Briggs or Packard who don’t know what they are talking about and are totally out of bounds of the law with their authoritative actions and statements.
The term “discharge” when used without qualification, means discharge of a pollutant or discharge of pollutants. (USC 33/26 Sec. 1362) When I claim the RECLAMATOR doesn’t discharge and therefore needs NO discharge permit, this means (in the wastewater industry) doesn’t produce pollutants which are of a level which is considered to be “pollutant”. This limit is defined in the US EPA Standard for drinking water. The MCLG states these are non-enforceable public health goals. The RECLAMATOR achieves this goal.
Harvey Packard told the county to permit the installation of the RECLAMATOR (because they had to and didn’t have any choice). Now, we are telling the LOCSD, County and the Water Board “one of them” is going to need to give me an exemption from required connection to the LOCSD’s sewer system or start paying me for my “harvest water” produced and taken from me by the LOCSD.
Have a great day…
Well, there it is, for now.
And so, THWOK! The ball is now in the RWQCB and/or the CSD’s hands. Will they issue an “exemption” from hook up; will they issue a “discharge” permit and if so, what “discharges” will be permitted, ie. So many mgls of this and that, what will it cost per year and require, vis a vis testing & etc.? Will they issue an exemption or discharge permit before or after the sewer’s built, i.e. stall and delay and ignore Mr. Murphy – hey, they’re busy with Morro Bay’s nitrate levels, we’ll get back to you after 2011 or so – and pretend not to notice until after the whole town’s sewered THEN either issue Mr. Murphy a CAO or, heh-heh, decide that, sure, heck, we’ll give him a “discharge” permit, heh-heh, we were just kidding about “discharges” and not permitting any onsites in the PZ?
This is a political football that can stay in the air for years! So, stay tuned.
Sunday, March 16, 2008
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59 comments:
Unless Murphy is willing to do the following:
(1) Agree to indemnify
(2) and defend
(3) every purchaser of his toy
(4) with a bond
you should run him out of town. That means he pays the fines and the lawyers for all of us, with the money up front so he can't run off, or else he needs to get out of town.
He also needs to quit practicing law without a license.
He always seems to refer to FEDERAL regulations which are nice, but not the only game in town. California has its own laws on this topic.
I am a little confused, I thought Muphey wasn't going to sell the gizmos, now the story is that any property owner can install one of their own? And That takes care of permitting issues?
If AES want's to provide a "Service" won't they be under the same rules as any other infrastructure "service"? And thereby under the RWQCB regulation?
My water purveyor, while a private company has to follow all the same laws as the CSD owned water company. (except of course with regards to finances) I think Ann is right, Tom and company are in for a looooong haul here, and my guess is the county and water board are just gonna let him rot on the vine while waiting for some legal opinion.
In the meantime I haven't read any plausible plan by anyone to stop the county project from trundling forward.
What did that Nipomo water lawsuit take? ten years?
Mr. LeGros,
Murphy's Reclamator does not need a discharge permit since it does not discharge -- and he is no longer connected to the community septic system. So what is the point of your comment at all?
Your "better idea," a "pipe" -- as you call it -- from his house to the community system, will cost LO PZ homeowners $75,000 to $100,000 with interest, while Murphy's solution will cost $15,000 plus $600 a year for service. Do the math. It's simple math, if your mind allows you to acknowledge it.
Since there is no discharge and nothing flows from Murphy's property into the community system -- there is nothing to "monitor." End of story.
I know this screws up your agenda, but Murphy is so far ahead of you it isn't even funny.
P.S. The RWQCB and County allowed Murphy to install his "appliance" at his home. Read the above and you will better, if not fully, understand why.
Howie,
As I do not live in the PZ, I have no stake in that situation. I wish the folks in the PZ all the best and a speedy resolution to their goal of a WWTF and/or an on site reclaimator.
If the reclaimator is all that Mr. Murphy says it is, then all the better. As I blogged, I have no stake in what the folks in he PZ do.
I was just offering my personal experience of my attempt to install an on site septic system; that experience says that if you discharge from a device (that receives and processes sewage) into the ground (I take it the reclaimator discharges SOMETHING ...including just pure water) that the RWQCB will require a discharge permit and periodic monitoring to verify the device is working properly.
My questions were asked out of curiosity; and without any agenda attached thereto.
Regards, Richard
Richard LeGros said...
Howie,
As I blogged, I have no stake in what the folks in he PZ do.
Richard, Didn't you sit on the LOCSD Board at some point?
If you are discharging into a septic tank "anywhere", you are "polluting". Think AB885 here.
Mr. LeGros,
The Reclamator does not "discharge" as you describe it. It produces clean water by repurifying it and reusing it, creating new water, which is a "valuable resource."
The RWQCB's sole function in the case of the Reclamator is to monitor it, if it so wishes, and they have asked for data, even though they know it works. They wouldn't have allowed Murphy to install it -- which they and the County did --if it didn't work.
Now the CSD and County either have to give him an exemption from the 218 assessment or pay him for his water.
Rick: Just so you won't believe that the LOSDEP RECLAMATOR Solution doesn't take into account California Water Law here are a few cites that address "waste of water". I'm certain that be January 1 2010 the next minting of the Porter-Cologne there will be "lanaguage" that will address "Water Harvesting"...
ARTICLE 2. DECLARATION OF POLICY
§ 13510. Legislative declaration
It is hereby declared that the people of the state have a primary interest in the development of facilities to recycle water containing waste to supplement existing surface and underground water supplies and to assist in meeting the future water requirements of the state.
§ 13511. Legislative findings
The Legislature finds and declares that a substantial portion of the future water requirements of this state may be economically met by beneficial use of recycled water. The Legislature further finds and declares that the utilization of recycled water by local communities for domestic, agricultural, industrial, recreational, and fish and wildlife purposes will contribute to the peace, health, safety and welfare of the people of the state. Use of recycled water constitutes the development of “new basic water supplies” as that term is used in Chapter 5 (commencing with Section 12880) of Part 6 of Division 6.
§ 13512. Legislative intent
It is the intention of the Legislature that the state undertake all possible steps to encourage development of water recycling facilities so that recycled water may be made available to help meet the growing water requirements of the state.
ARTICLE 3. STATE ASSISTANCE
§ 13515. Authorization to provide loans
In order to implement the policy declarations of this chapter, the state board is authorized to provide loans for the development of water reclamation facilities, or for studies and investigations in connection with water reclamation, pursuant to the provisions of Chapter 6 (commencing with Section 13400) of this division.
ARTICLE 4. REGULATION OF RECLAMATION
§ 13520. Definition
As used in this article “recycling criteria” are the levels of constituents of recycled water, and means for assurance of reliability under the design concept which will result in recycled water safe from the standpoint of public health, for the uses to be made.
§ 13521. Statewide criteria
The State Department of Health Services shall establish uniform statewide recycling criteria for each varying type of use of recycled water where the use involves the protection of public health.
§ 13528. Disclaimer
No provision of this chapter shall be construed as affecting the existing powers of the State Department of Health Services.
§ 13529. Legislative findings
The Legislature hereby finds and declares all of the following:
(a) The purpose of Section 13529.2 is to establish notification requirements for unauthorized discharges of recycled water to waters of the state.
(b) It is the intent of the Legislature in enacting this section to promote the efficient and safe use of recycled water.
(c) The people of the state have a primary interest in the development of facilities to recycle water to supplement existing water supplies and to minimize the impacts of growing demand for new water on sensitive natural water bodies.
(d) A substantial portion of the future water requirements of the state may be economically met by the beneficial use of recycled water.
(e) The Legislature has established a statewide goal to recycle 700,000 acre- feet of water per year by the year 2000 and 1,000,000 acre-feet of water per year by the year 2010.
(f) The use of recycled water has proven to be safe and the State Department of Health Services is drafting regulations to provide for expanded uses of recycled water.
§ 13529.2. Unauthorized discharges
(c) For the purposes of this section, “recycled water” means wastewater treated as “disinfected tertiary 2.2 recycled water,” as defined or described by the State Department of Health Services or wastewater receiving advanced treatment beyond disinfected tertiary 2.2 recycled water.
(d) For purposes of this section, “recycled water” means “recycled water,” as defined in subdivision (n) of Section 13050, which is treated at a level less than “disinfected tertiary 2.2 recycled water,” as defined or described by the State Department of Health Services.
§ 13552.2. Legislative findings
(a) The Legislature hereby finds and declares that the use of potable domestic water for the irrigation of residential landscaping is a waste or an unreasonable use of water within the meaning of Section 2 of Article X of the California Constitution if recycled water, for this use, is available to the residents and meets the requirements set forth in Section 13550, as determined by the state board after notice and a hearing.
By the way, Ultra Filtration Permeate Harvest Water produced by the RECLAMATOR is superior to Title 22 Standards.
Why would anyone want to "the that out of town"?
The RECLAMATOR skates to where the "puck" will be.
Howie,
YOU GET IT!
You will really enjoy the information that will be illuminated soon.
Much of this "cite" became law effective January 1, 2008. But not 13553 Regarding toilet flushing(a). That has been in effect since at least January 1, 2006.
So you can see where the "technology" will be a factor as the situtation evolves. Lucky LO/BP...World Visionaries.
I LOVE LO.
WE LOVE IT!
§ 13553. Regarding toilet flushing
(a) The Legislature hereby finds and declares that the use of potable domestic water for toilet and urinal flushing in structures is a waste or an unreasonable use of water within the meaning of Section 2 of Article X of theCalifornia Constitution if recycled water, for these uses, is available to the user and meets the requirements set forth in Section 13550, as determined by the state board after notice and a hearing.
(b) The state board may require a public agency or person subject to this section to furnish whateverany information that may be relevant to making the determination required in subdivision (a).
(c) For the purposes of this section and Section 13554, “structure” or “structures” means commercial, retail, and office buildings, theaters, auditoriums, condominium projects, schools, hotels, apartments, barracks, dormitories, jails, prisons, and reformatories, and other structures as determined by the State Department of Public Health Services.
(d) Recycled water may be used in condominium projects, as defined in Section 1351 of the Civil Code, subject to all of the following conditions:
(1) Prior to the indoor use of recycled water in any condominium project, the agency delivering the recycled water to the condominium project shall file a report with the appropriate regional water quality control board and receive written approval of the report from the State Department of Public Health. The report shall be consistent with the provisions of Title 22 of the California Code of Regulations generally applicable to dual-plumbed structures and shall include all the following: (A) That potable water service to each condominium project will be provided with a backflow protection device approved by the State Department of Public Health to protect the agency's public water system, as defined in
Section 116275 of the Health and Safety Code. The protection device approved by the State Department of Public Health shall be inspected and tested annually by a person certified in the inspection of backflow prevention devices. (B) That any plumbing modifications in the condominium unit or any physical alteration of the structure will be done in compliance with state and local plumbing codes.
(C) That each condominium project will be tested by the recycled water agency or the responsible local agency at least once every four years to ensure that there are no indications of a possible cross connection between the condominium's potable and nonpotable systems.
(D) That recycled water lines will be color coded consistent with current statutes and regulations. (2) The recycled water agency or the responsible local agency shall maintain records of all tests and annual inspections conducted.
(3) The condominium's declaration, as defined in Section 1351 of the Civil Code, shall provide that the laws and regulations governing recycled water apply, shall permit no exceptions to those laws and regulations, shall incorporate the report described in paragraph (1), and shall contain the following statement:
“NOTICE OF USE OF RECYCLED WATER
This property is approved by the State Department of Public Health for the use of recycled water for toilet andurinal flushing. This water is not potable, is not suitable for indoor purposes other than toilet and urinal flushing purposes, and requires dual plumbing. Alterations and modifications to the plumbing system require a permit and are prohibited without first consulting with the appropriate local building code enforcement agency and your property management company or homeowners' association to ensure that the recycled water is not mixed with the drinking water.”
(e) The State Department of Public Health may adopt regulations as necessary to assist in the implementation of this section.
(f) This section shall only apply to condominium projects that are created, within the meaning of Section 1352 of the Civil Code, on or after January 1, 2008.
(g) Nothing in this section or Section 13554 applies to a pilot program adopted pursuant to Section 13553.1.
$15,000 plus $600 a year for service. Do the math. It's simple math, if your mind allows you to acknowledge it.
Thanks Howie! I'll assume thats an estimate?
Good, now lets run that through the old Los Osos Sewer calculator and... whrirrrrrr click click.
Gee! almost as cheap as the original county plan!
(10K assessment 40/mo.) but wait!!! It's still calculating!!!! WHIRR,Click....
OOPS! project really is , 50% over!?!?
Show us the contracts with insurance I say!
At least the TAC reports takes in the reality of the real life (IMHO rotten) bids for an approved WWTF.
Murphy is all promises and speculation at this point, some laws only apply if litigated.
litigation can take years, too long!
What is he going to do if competition shows up?
Oh, for those interested, Steve already has a working, permitted system.
http://loviews.blogspot.com/
And his does NOT discharge to a community system.
10:4
Sorry about the multiples, but one thing i wrote needs illuminating
" some laws only apply if litigated."
Why the heck do you think Morro Bay is in such a tizzy?
They are having to SUE to get their nitrate problem addressed AND THEY HAVE A SEWER!
Does it occur to anybody that maybe none of these "solutions" will be a solution?
Maybe endless litigation is the most environmentally friendly path...
Blessedness through Jurisprudence, I think I'll be a monk.
I'm somewhat confused. It's been said that the recent Reclamator installed at the Bay Ridge location does or does not discharge. There was already a common sewage collection system in place connecting each house to a common collection tank which the CSD has responsibility to pump on a regular schedule. The entire community system is ready to connect to a Los Osos sewer when one is completed. There are no septic tanks in Bay ridge Estates.
The sewer pipe from the house and part of the community collection system was then cut and here's the confusion, the Reclamator was either installed on the the now new end of the house sewer line and the pipe going to the community sytem was plugged? If so, where is the outlet of the Reclamator connected? OR was the Reclamator reconnected to the comunity sewer pipe?
If the Reclamator is reconnected to the community sewer, then it would appear to be just another filter or an unnecessary septic tank inserted in the community collection system.
If on the other hand, the outlet of the Reclamator is simply open to the soil, then it would appear to be a septic tank with no dispersal or leach field.
One other curious thought would be that the output fluid of the Reclamator is so pure that it is somehow piped back into the house drinking supply.
No where have I been able to find reference to any sort of instrumentation or an instrumentation diagram that would show just what the output of the Reclamator really is.
Instead of simple salespeak and eventual litigation, I would suggest some engineering dialog.
"SOMETHING comes out of the tail end of the reclaimator. Even if it is water, where is it going?...into a tank for reuse? Into the ground? Where?
If Murphy is putting it into the ground, that is defined as discharge (regardless of the quality of the treated wastewater); and requires a discharge permit from the RWQCB.
"
I am pretty sure he said he hooked it up to the community setic system...
The confusion is that the reclamator supporters do not define what comes out of the reclamator as "discharge" and the opponents do. So when you ask "where does the discharge go?" or "what is the discharge pipe hooked-up to?" then the answer is "no, none, nothing".
From what I have read about this device and its owner, I am assuming he "temporarily" hooked it up to the community system and is apparently feeding clean water into that system.
I am also assuming that at some point he will probably disconnect his device from that system once he figures out what to do with all that clean water on his property.
He has suggested a large fountain, or water feature of some sort, in the front yard.
I recommend a holding tank and purple pipe back to his landscape irrigation system and possibly for flushing the toilet and washing clothes, etc.
I am also assuming no matter how clean the water is, he would not be allowed to feed it directly to a drinking supply... thus the "purple pipe".
A lot of assumptions here... but this is my understanding from what I have read.
A suggestion... until we actually know and agree on the definition of "discharge" maybe we chould use a different term to minimize the confusion in these discussions...
How about "RTCW" for Reclamator Treated Clean Water"... or "Reclamator Output".
Can someone tell me how to get a cheap discharge permit for my garden hose? I need to water the petunias this week.
I also spilled a bucket of water over some dog poo on my lawn by accident - it was my all my fault, and I take full responsibility. The engineering reports on the plastic bucket (Rubbermaid of course) assured me that it was most viable solution for minimizing unwanted discharge. What sort of RWQCB fine am I liable for?
Hi Fbleg,
Oh my, shame on you for the dog poop.....but do not fret....no one will report you to the RWQCB. :-)
Now I understand that your blog was posted in jest....and poking fun at old 'FB'", but REALLY....:-)
Amused, Richard LeGros
How about Ultra Filtration Membrane "permeate" or "Harvest Water"?
Mike Green sez:"Oh, for those interested, Steve already has a working, permitted system.
http://loviews.blogspot.com/
And his does NOT discharge to a community system.
10:4
10:45 PM, March 16, 2008"
If you're refering to Steve Paige and his urine seperator, if I understand correctly, his urine is separated out and held for pick up, but everything else -- poop, water from shower, sink, washer, etc. all goes into the septic tank and then "discharges" to the ground. After 2011 he'll be "guilty" of "discharging." What then? Briggs has repeatedly said there will be no onsite systems allowed in the PZ and having some onsite system now still will not remove your requirement to hook up to a community system. So, what's up with that?
After 2011 he'll be "guilty" of "discharging." Ann, You are correct.
Technoloy which eliminates the diswcharge of pollutants is where we are heading. Briggs knows it. Soon everyone else will too.
For Richard:
The RECLAMATOR “is not” a “septic system” and DOES NOT “DISCHARGE”, therefore NO “DISCHARGE PERMIT” is required, and thus the reason a “building permit” was issued WITHOUT a “DISCHARGE PERMIT”. It is just that simple.
The LOCSD instructed the County to issue the permit. As I have been telling you for the past 7 months, the RECLAMATOR does not require a “DISCHARGE PERMIT”. Now I have just proved it and we still have roadside authorities who continue to suggest it isn’t true…when it is in “red-n-black” ink. Just go to nowastewater.com, it is there for your viewing pleasure.
The “point of my device” is: Me being “connected” to the LOCSD’s collection system and them NOT issuing me an “Exemption from Required Connection” so I can reuse my own water for such things as indirect potable reuse, subsurface irrigation and even toilet flushing, I have a “money tree” as the RECLAMATOR produces “HARVEST WATER”, a BEYOND “recycled water” resource, the such which is defined as water which is a “valuable resource”, my property and subject to purchase under the United States Constitution’s Fifth Amendment which requires a government agency to fairly and justly compensate a private citizen at fair market value should the private citizen be obligated to give up his personal property to such government entity. The LOCSD is obligated to pay for all RECLAMATOR harvest water they take just like the County will be obligated to pay for all the RECLAMATOR harvest water if they so stupidly chose to continue with a “dead” publicly owned sewer project that cant be paid for, just go figure, again, it is just that simple…it is “WATER”, not “DISCHARGE”.
The “fair market value” of 5Xs (five times) the Golden State water rate coming into same property is based on Lake Havasu’s latest sewer service rates. He, who owns the facility, owns the reclaimed water (state law). He who owns the water is entitled to be paid provided anyone takes it. This month the water bill was $66 dollars with irrigation turned off. That means the LOCSD would have been owing me approximately $300.00 for my reclaimed “harvest water” this month. Just think feeding solar power back into the “power grid” and associate that model to feeding harvest water back into the POTW “sewer grid”.
In regards to “monitoring” the device, it is monitored by a “ultra-filtration” membrane which is a physical filtration and is not subject to allow non-effluent limitation meeting “discharge” through it. The membrane takes out the “unknown failure possibility” out of the equation. If it fails, it asks for service, again, it is just that simple…it is “fool and foul proof” in regards to permeate quality. When the biological process is functioning, the RECLAMATOR is denitrifying. When the biological process equipment fails, the process is affected and the membrane won’t allow passage thus causing a service signal to go out. No thousands of gallons of untreated sewage and pollutants flow into the bay…ever!
Obviously, Mr. LeGros doesn’t know a RECLAMATOR is required to be installed at each home prior to discharging into a POTW to comply with the “pretreatment requirements” of USC 33/26. Maybe he should read “Facts” then he will have a few of his own as he is running real short on them at present…….Again, with either an “Exemption” or “Payment”, which one or the other must apply, the sewer can’t be funded, thus will NEVER happen. If Mr. LeGros doesn’t get it, then maybe he just needs to ask Mr. Ogren to explain it to him.
The BESTEP 10 was tested by NSF International in 1994 and demonstrated to provide consistent denitrification. No other technology has been successfully able to accomplish this to this day. I am going to provide a computer to the regulatory authorities so they can monitor them all right from their office along with NSF International as NSF is the entity who has agreed to provide daily monitoring of all the systems via wireless technology and internet. Just to show what a really nice guy I am, I’m not even going to charge them for the computers…J
Thanks again,
Tom Murphy
Los Osos, CA.
For Everyone:
Ann, I just want to clear up one thing. I don’t want a “discharge permit”. I have refused to be issued a “discharge permit”. I am not ever going to accept a “discharge permit”. Furthermore, soon, I will soon be filing a federal injunction against any “discharge permit” being issued in the State of California with all other states to follow…..
The law required best available technology which will eliminate the discharge of pollutants. The RECLAMATOR does this and therefore is the technology which achieves this requirements and as such shall be implemented nationally. They already owe me damages for not specifying it since 1994 (NSF Report showing nitrate reduction) nationally. Now, it is “knowingly” violating the federal law to not require and assist in the application of the RECLAMATOR nationally.
Now, there is no need for the Water Board as they only rule over “discharges” and there will be no more “discharges” allowed…“Disband the Water Board”!!! It is the solution for the State’s deficit.
Well, there it is, for now. -Tom
............And so, THWOK! The ball is now in the RWQCB and/or the CSD’s hands. Will they issue an “exemption” from hook up; will they issue a “discharge” permit and if so, what “discharges” will be permitted, ie. So many mgls of this and that, what will it cost per year and require, vis a vis testing & etc.? Will they issue an exemption or discharge permit before or after the sewer’s built, i.e. stall and delay and ignore Mr. Murphy – hey, they’re busy with Morro Bay’s nitrate levels, we’ll get back to you after 2011 or so – and pretend not to notice until after the whole town’s sewered THEN either issue Mr. Murphy a CAO or, heh-heh, decide that, sure, heck, we’ll give him a “discharge” permit, heh-heh, we were just kidding about “discharges” and not permitting any onsites in the PZ?
This is a political football that can stay in the air for years! So, stay tuned.
OK! mark, when are you going to provide the missing pages from the 1994 test you refer to a couple of posts up the page here? We are still waiting. Are you ignoring us? (Pages 2-51 in case you forgot.)
Oh, and Richard LeGros is right. I think your insulting the very people you are trying to sell this thing to is very poor marketing.
Toons,
You are not being ignored, we have "teased out" the NSF Report issue, completely. We are beyond that. We are offering discharge elimination services that will utilize the invention of the founder. We are not "selling" units. NSF cerification is not required for sale of units in California. Please see the RECLAMATOR Engineering Report posted on our website, please.
If you are unhappy or offened you'll just have to stick with the "Polite as an Eglish Butler" county study process.
We'll be happy to provide service to everyone who wants or needs it.
Smiles everyone, smiles.
“ADVANCED INNOVATIVE ALTERNATIVE TECHNOLOGY”
Required by
US Code, Title 33, Chapter 26, Section 1251 et. seq.
1.0 INTRODUCTION
AES, as a private organization, has private funding necessary to facilitate the Los Osos, California areawide waste management plan, meeting all requirements in USC 33§1288 developed pursuant to USC 33§1313 (e), and providing the advanced innovative alternative technology as required per USC 33§1281 and meeting all cost effectiveness requirements of the selected alternative as required by USC 33§1297 and 33§1298. The advanced innovative alternative technology of AES achieves the performance criteria pertaining to required alternatives as defined in USC 33§1316, producing a reclaimed water quality representing “the greatest degree of effluent reduction which the Administrator determines to be achievable through application of the best available demonstrated control technology (BADCT), processes, operating methods, or other alternatives, including, where practicable, a standard permitting no discharge of pollutants”. This required alternative presents a method of reducing the total flow of sewage, including, but not limited to, unnecessary water consumption in order to reduce the requirements for, and the costs of, sewage and waste treatment services as defined in USC 33§1254 (o), and as meeting the further defined requirements in 33§1254 (q), qualifies for federal grant assistance as defined in USC 33§1255 (e)(2), (f)(g). Community is under a State order to cease and desist discharge of waste into subsurface excavations as defined in USC 33§1288 (b)(2)(K).
2.0 INNOVATIVE TECHNOLOGY
This advanced “innovative technology” as defined in USC 33§1311 (k) has the potential for industrywide application as it can be applied to serve any source ranging from a single residential dwelling to a publicly owned municipal plant. This innovative system can be provided at a significantly lower cost than any other system which has been determined by the Administrator to be economically achievable. Its “innovative control techniques” associated with its “innovative control process” which will result in an effluent reduction significantly greater than that required by the limitation otherwise applicable to such facility and moves toward the national goal of eliminating the discharge of all pollutants.
3.0 GREATEST DEGREE OF EFFLUENT REDUCTION
The advanced innovative alternative technology for onsite application is available in two basic versions, version “1” is referred to as the BESTEP 10, and version “2” is referred to as the BESTEP UF-900. The BESTEP 10 has been demonstrated by NSF/ANSI (NSF International) to eliminate the discharge of pollutants, i.e. nitrates 1.6 mg/l average and total nitrogen 4.9 mg/l average. Nitrates are the primary toxic pollutant which will remain soluble to migrate and cause water pollution if not removed biologically prior to being introduced into a soil environment. All other pollutants will be contained. This quality of water is suited for any under ground beneficial reuse application such as “indirect potable reuse” as per EPA definition, where the water aquifer is replenished with “potable quality” water. In this application, the BESTEP 10 meets all requirements for grant assistance as defined in USC 33, Chapter 26, and Subchapter II as a pilot program when selected for application in an alternative water source project (USC 33§ 1300). This will maximize the grant assistance to the benefit of the citizens in conformance with the allowed maximum as provided for under USC §1282 (a) available for eligible treatment works or significant portion thereof utilizing innovative or alternative wastewater treatment processes and techniques referred to in USC §1281(g)(5).
For requirements under USC 33§ 1288 (b)(2)(K) which require advanced waste treatment and water purification methods as provided for in USC 33§1255(a), the BESTEP UF-900 achieves the greatest degree of effluent reduction. It produces a quality of water consistent with 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), removal of large molecular weight organic compounds (above 100,000 Daltons), establishing a standard, that can be applied onsite to serve any domestic source of pollutants any where, “permitting no discharge of pollutants” as required by USC 33§1316. This effluent standard meets the US Environmental Protection Agency’s “Maximum Contaminant Level Goals” (MCLG), the established measure defining “treated drinking water quality” standards.
4.0 MOST COST EFFECTIVE AND ECONOMICAL ALTERNATIVE
This BADCT will serve the Los Osos Community under the requirements of USC 33§1281(h)(1,2,&3). The AES technology is the most cost effective alternative (USC 33§1297 & 1298) which has the most advanced processes and techniques meeting guidelines promulgated in USC 33§1314 (b)(c), and (d)(3) providing the most cost effective alternative having the lowest life cycle cost of any other alternative by in excess of 15 per centum.
Per the requirements set fourth in this US Code, it is unlawful for any person to discharge any pollutant (USC 33§1311(a)). Every source is required to be served by the best available technology economically achievable as required in USC 33§1311(b)(2)(A) which is the AES technology. The regulatory community is required to specify it by “brand name or equal”, and there is no equal. To not select and apply this technology upon it being available is a violation of this Federal Law known as “The Clean Water Act".
Richard LeGros said...
Mark,
Thank you for clarifying that your home remains connected to the Baywood Estates sewage collection, treatment and disposal system. In essence, the reclaimator is acting as a pretreatment device augmenting (but not replacing) the existing Community system.
As I am curious by nature, could you please clarify:
1. How you are harvesting the reclaimed water from the reclaimator before it enters the community system. -There will be oppourtuinty to "tour" the operations as we roll out. I will keep eveyne updated as to when we can begin scheduling tours for citizens. I think you will be pleasantly surprised to "kroak" about it.
2. What is the quality of the reclaimed water before entering the community system.- see discussion above, Membrane + I.D.E.A. Biological process = Best Available Technology
3. What happens in a situation where a community collection, treatment and disposal system does not exist (to which to connect the reclaimator)? -The RECLAMATOR will produce harvest water to be reused or sold. The owner of the Baywood Estates collection system will issue a exemption for hook up or will pay for the water.
It would appear that for you to reclaim the water, you must be connected to a larger community collection system with sewage processing and disposal elsewhere. I now grok that the permit was issued as (in this case) you are using the reclaimator solely as intermediate pretreatment device before it enters the Baywood Estates sewage system. - The RECLAMATOR is the ultimate pretreatment that repurifies water at the source eliminating the need for any further treatment. What comes out of a RECLAMATOR is "ready to go" for many beneficial reuses.
We are working on the ultimate reuse appliction at this time. Think "self sufficient" here... As the cites of water law above indicate even the legislators are thinking about what will be necessary. Fortunately, advanced water reclamation technology is already in operation in Los Osos. But all the smart, sensitive and polite folks already know that.
I will disagree with your take on the legal issues and appreciate your advice regarding the "marketing" aspect of the LOSTDEP RECLAMATOR Solution. It will begin immidiately following the current phase of the Solution. It will be interesting to see how many choose the "county/state study process" over the much more econmical RECLAMATOR Solution, no matter how "insulted" they may have been made to feel.
BTW, you never did answer the questions: Richard, Didn't you sit on the LOCSD Board at some point?
If you are discharging into a septic tank "anywhere", you are "polluting". Think AB885 here.
But if you believe I am being too rude in the asking, feel free to ignore my questionsand statement, it's a free country.
Regards, Richard LeGros
PS:
Ask yourself if it is prudent to insult the folks asking questions about your product and service. Do not get me wrong...I'm just a salty old cuss who is used to (even immune to) uncivil language. However, there are many smart and inquisitive folks reading this blog who may be more sensitive than I. As you are a business man, your reputation is being scrutinized; so why not be pleasant and informative about the reclaimator itself.
We all grok what you are blogging regarding your interpretation of the law; however you will have to test your interpretation in the courts. I estimate that if you file lawsuit(s) on this matter, you will need at least 2 years and about $400,000 to process your claim. After you have litigated what you deem proper, I will look forward to your report on the results.
Just a few friendly suggestions; and good luck
4:10 PM, March 18, 2008
Mark,
What comes out of a Reclamator (TM)? Stuff of various sorts goes in and approximately the same volume should come out. The stuff that comes out is discharge by my definition, that of the RWQCB and by most everyone but you it seems.
Doesn't matter to me if you want to redefine terms, but consider yourself warned that the RWQCB may very well disagree with you and, because of that, you might have an uphill battle with them.
All the best to you ...
What did you or Richard just say...???? That is a most confused posting of whatever it is/was!!!
The term "discharge" in the "industry" is associated with "waste".
We are well aware of what is required under law regarding "discharge" and the CCRWQCB does too.
So you think that we have been fighting on level ground thus far and will have to modify our "strategery" to prevail?....;-)
I appreciate your sentiment in wishing us the "best", because "luck" has little if anything to do with the process. While, intention, commitment and integrity have everything to do with what has been achieved thus far.
Like I told Harvey Packard while shaking his hand good-bye at an person meeting last week:
"Harvey, there isn't going to be a sewer in Los Osos, because it ain't right".
mark says:
"…we have "teased out" the NSF Report issue, completely. We are beyond that."
So you won't be bringing up anything off that report again? How it proved that the Wrecklamator removed contaminants such as nitrates from wastewater? If that report, as you have claimed, justifies the use of the Wrecklamator for Los Osos, how can you just ignore it? How can you be "beyond" that?" What "proof" are you using now that the thing works if not that report?
Gee, I don't know mark, to ignore that report after putting so much time (and so many million words) touting it seems a little odd to me.
mark said:
"While, intention, commitment and integrity have everything to do with what has been achieved thus far"
What exactly has been achieved - so far?
Come'on "...toons", Mark said "...there isn't going to be a sewer in Los Osos, because it ain't right"
He promulgated his Reclamator at least a zillion times so he must be right. I'm just surprised the CSD hasn't elected him King of Los Osos yet!
That's correct, MIKE- "it ain't right"... Since the 1970's it never was and now never will be.
Toons,
The Nitrogen Series performed by NSF in 1994 and promugated in 1995 sets today's national standard. This aspect of the solution will make more sense to "citizen's" as we roll.
The NSF Nitrogen series are a part of the engineer's report and will always be apart of the LOSTDEP RECLAMATOR Solution. It is a part of History.
If you do not see the progress yet, then you'll just have to continue to wait and see.
Some things just cannot be explained. Change may be one of them...
Richard,
Just how much experience do you have racked up in the water industry? How much face time do you have with the "Quality Control Board".What "technology" were you working with at that time?
Answers to these questions will assist me in evaluating your "opinion" regarding everything USC 33/26 which underpins everything Quality Control Board and the LOSTDEP.
If your experience is limited to the time you may have served on the LOCSD or if you are or were a government employee, you can understand my wanting to continue the process we have set for bringing the RECLAMATOR Technology forward.
Do you know how much raw sewage was released into environment during the heavy rains recently?
The Men's Colony spill was a drop in the bucket, by comparison, yet no newspaper coverage.
Remember the spills and leakage from a system being studied that won't be in operation for at least 5 more years. While a RECLAMATOR niether leaks or spills and would begin mitigation immediately and be complete in 2 years.
If you are using a septic tank you are polluting. Septic tanks are in the zone.
FYI, for the most part I will always respond to questions or commentsdirected at me or mine.
So if you like it quiet, think unchained bear looking for bulls, here. shhh...
Quotation of the law, is not:interpretation of the law....
There are several government employees who have come to this "understanding".
The Law is written to protect citizens and their environment.
"Policy" is another story...
Mark,
There is a time-tested way to evaluate the performance of the reclaimator; set up a test situation where the reclaimator is fully loaded over a set period of time, test the outgoing waste water produced using industry standard tests, collect the data, evaluate the data, and present the results in a form that is understandable. If you need assistance, there many testing laboratories that can perform these tests. If money to pay for the tests is a problem, I am sure that many folks in Los Osos would donate the capital you require.
The ongoing legal legerdemain may simply be resolved by working with the RWQCB; or if that fails, you may press your case in Superior Court.
Meanwhile, if you want to call local citizens 'to arms' to fight 'da man', go ahead. No one will stop you; but there is no need to attack those folks who do not rally to your banner. Besides, such attacks just dilute your battle. Focus on what you need to achieve.
Regards, Richard LeGros
Just show us the report mark. Why is that so difficult for you? Why are you avoiding doing so?
Here's another one for you. Just how many Wrecklamators do you have stockpiled and ready to go so you can instantly "fix" the nitrate problem here? How long does it take to make one? Who manufactures them?
Mark,
Are you telling me that if I were to divert the water out of my washing machine onto my lawn (and if I were to use the right sort of soap) the RWQCB cannot legally prosecute me and that they will not try to prosecute me even if I send them an explanation of photos of what I am doing, a schematic chart and even dates and amounts of "discharge" from the machine. (Please know that I am using the general definition and not the one you've been using ... I apologize but couldn't think of a better, clearer word for what comes out of the washer.)
Once you've won your case and demonstrated that the RWQCB will be happy with a completely Reclamator solution, we'll sign up in droves. Until then, please don't tell us that we have no reason to fear because your legal interpretation (are you a lawyer with a specialty in the sorts of issues the RWQCB deals with, by the way?) differs from what the newspaper, the County and the RWQCB tell us.
Everyone's advice is greatly appreciated although nothing offered is anything new or is not addressed by the LOSTDEP RECLAMATOR Solution. Thank you all for your interest.
Shark: "Household" greywater contains pollutants and would need treatment in order to avoid "discharge of waste", something the "quality control board" is required by law to prevent, abate, mitigate, clean up...
Washing machines and showers contain the same bacteria and viruses that are contained in black water. These "pollutants" are not present in the "Ultra Filtration Membrane Permeate" produced by the RECLAMATOR.
I would think that when there are no more discharges the "Quality Control Board" would be happy, so that is what I am working towards.
Toons, Hang in there...the county study of leaky sewerage continues on step...
How is that "county/state data on exfiltration and treatment results", especially during peak flows, coming along?
Richard, I see you do not comprehend the meaning/significance of the NSF Nitrogen Series test results...
Perhaps you can get withtoons and assist us all in learning just how well the current sewerage is "operating"?
Perhaps when more information is illuminated my discussion on the negative aspects of sewerage will be better understood by all.
Unless and until the pollution caused by energy intensive, expensive and leaky sewerage is better known, there will continue to be unrest with what is actually going on with the LOSTDEP RECLAMATOR Solution.
Perhaps if you had had a chance to read the "business plan" you would see the logic i the process as executed.
In rereading the blog I will challenge you to cut and paste the parts of the dialogue you attribute to my being rude. If you "feel" like it, of course. Toons, same goes for you.
Where is the "leaky sewerage" blogspot?
Mark,
Oh, I completely understand the NFS report tests results. I also read and grok your business plan.
However, I (and many others) cannot make a determination from only a single data point sampled during 1994-1995. In fact, to persuade you will need many (say, 100 or so)data point test results taken over many years, perferably from a single reclaimator. Data needed would be on both the quality of the treated waste water leaving the reclaimator AND regarding the overall performance (maintenance) data. As you have beem selling/promoting the reclaimator since atleast 1994, I asssume you have more data you can provide. Would you please send me the data you have to my email address (KPGRBL@aol.com)...thanks in advance.
Good luck and Regards,
Richard LeGros
to persuade? ...whom? got law?
Would you please cite the "law" in support of your "Grok"- "In fact, you will need many (say, 100 or so)data point test results taken over many years, preferably from a single 'RECLAMATOR'(sp.)."
There is no "i" in RECLAMATOR, Richard...;-)Got Grok(pronounced-GRAHK)?
I'm curious about the cites of law as I have read Porter-Cologne and C26 and know there is no such statute.
Did you read all 156 pages of the business plan? Did you sign a non-disclosure agreement? I do not have your name on file?
Mark,
There are no 'laws' that says how many 'data points' you need; simply because the 'law' is not the issue here.
What is at issue is showing, through application of the scientific method, that the reclamator will perform as you claim; and that ongoing operation of actual reclamators will consistantly perform as you claim over time too.
This is not a difficult task; and would be expected of any product in order to detail that the device performs as you claim.
Do not get me wrong...I would just love it if the reclamator worked as you say. But wishing something to be so is different from reality. Give me reality.
You can easily make me... and anyone (including the RWQCB)...a believer if you supply actual undeniable data supporting the reclaimator as a viable solution. With such data, you would not have to perform legal gymnastics to force the issue.
Regards, Richard LeGros
PS : 'GROK' means to understand and grasp fact easily. It is a term originally used in the computer industry; and that has worked its way into modern slang amongst the technically literate.
PPS: I understand your business plan.
Hey Richard, you are showing your youth! - I am an old timer - I used "grok" back in the 60's - it became popular from the 1961 book, "Stranger in a Strange Land" by Robert A. Heinlein.
mark, I can get better research on my next toaster purchase than you are willing - or is it able - to provide us about your device.
Excellent and new point Richard about the legal gymnastics mark seems eager to go through - gymnastics which are a substitute for a lack of performance data.
The RECLAMATOR works as engineered and stamped.
Soon everyone will know it, including citizens.
At this point, I think the Quality Control Board understands the nature of spiral wound ultra filtration membrane permeate post I.D.E.A. Biology/RECLAMATOR Technology.
Who will stand against reclaiming 100% of household water conserving it for some direct and or indirect uses, while conserving energy, carbon and capital costs?
I look forward to seeing just whom that will be, if anyone...
There are no 'laws' that says how many 'data points' you need; simply because the 'law' is not the issue here.
THe law is the "issue here"...
Mark,
The 'law' only applies IF the reclamator undeniably works and performs as you claim.
To repeat mysel (from a prior post):
'What is at issue is showing, through application of the scientific method, that the reclamator will perform as you claim; and that ongoing operation of actual reclamators will consistantly perform as you claim over time too.'
Again, thank you in advance for sending me the reclamator documentation I have requested (previously).
Regards, Richard LeGros
----- Original Message -----
From: Mark Low
To: kpgrbl@aol.com
Cc: Mark Low
Sent: Thursday, March 20, 2008 9:42 AM
Subject: Interesting that the county nor state has been asking for more test results.
Richard,
I will be posting data on the website when appropriate and will not be sending it to you personally. If you are not satisfied with what is in the engineering report you do not understand how the "process" works. The QCB is under the gun to eliminate discharges by law. We have technology that is supported by law. This isn't a popularity contest.
The QCB nor you don't get to place artificial barriers designed to prevent best available technology from being implemented. The law says "demonstrated" and that requirement has been "satisfied". Please understand the RECLAMATOR Solution has the same requirements as a big pipe solution. So we are not jumping through hoops that a "permitted" leaky sewerage and treatment system does not jump through. It's known as equal protection.
The provider of the service invented the RECLAMATOR Technology and he is already "sold" on it. Everyone else is free to stick with the county's study of leaky sewerage process or go with some other method of eliminating your discharge if you can find one. It is a free country. So as rude as it may seem "You can't please all of the people all of the time", I guess this will be one of those times, or not.
We are a nation of laws so the "law" most certainly does apply.
The first LOSTDEP RECLAMATOR is in operation and the first labs are being performed. Using nitrogen testing strips yesterday, the system is producing well under the 7.0 mg/l limit. WELL UNDER.
As I have written before the "I.D.E.A." biological process would be the best choice at the end of a pipe. Engineers don't like or want to specify it because it is "pre-engineered" and that cuts into the consulting engineer's business model. Besides, that pesky pretreatment statute that will be followed from here on in...A RECLAMATOR treats so well a sewer pipe is made "obsolete".
I hope this helps.
Best,
Mark
Interesting that the county nor state has "NOT" been asking for more test results.
I guess the test results that will matter will be those from the first installation. The State has found it's "new source" offuture water.
Harvest Water from a RECLAMATOR. Technology is a beautiful thing.
I love L.O.
So then Mark,
Who gets to determine what is and what is not a discharge. You tell us that your sewage treating device doesn't produce a discharge but that the water I use to rinse out my dirty clothes (mud from the bay, sand and the like) is a discharge.
Don't you think that it depends on the content of the stuff that comes out of the other end? If there is a certain level of nitrates or sediment (for example), it would be a discharge but if less, not.
Sounds to me like exactly what the RWQCB does control. The LOCSD had a discharge permit for their TriW effluent. They were allowed a certain nitrate level but no higher. The Monarch Grove plant similarly is regulated by the RWQCB. Presumably the RWQCB would then get to determine the allowable content of any outflow you have from your many many Reclamators and they could require testing and even mandate an allowable testing scheme.
Please don't tell us that you've got a magic box that will never fail and that we should all trust your box to work perfectly ... systems fail and I want to know why you think the RWQCB doesn't have the authority to require monitoring and the ability to fine if the system has been determined to fail.
Give us a bloody break!
Clothing has more on it than mud and sand, ask your significant other.
The Ultra Filtration Membrane removes pathogens and viruses not eliminated during the biological process. Only when Maximum Contaminant Level "Goals" MCLG's have been reached or exceeded can the word "discharge" be "neutralized" or eliminated from the discussion.
No contaminants, no discharge...a rare win/win.
I am amused and disgusted that the QCB issues "pollution permits" every five years when technology is available to eliminate pollution at the source.
The biggest non point "permitted" part of sewerage, "the pipe" is never "examined" after it is buried. That is criminal.
Membranes monitor, it is a continuous test. Electronic monitoring will provide instantaneous feed back to the Quality Control Board's and our computer stations. I understand your interest and desire to learn more and there will be plenty of time for that. Relax, enjoy the Easter Season, the county study of leaky sewerage continues on step.
Funny you do not appear as concerned with all the leaky sewerage and treatment plant failures that the countyis studying. I will suggest that you give yourself a "bloody" break today.
The sewerage the State and County are studying fail constantly.
Where are the flows and loads and final testing result websites for the "permitted" systems? I know it is being collected...
Where is the leakage/infiltration data on the ~P~I~P~E~?
Mark,
Thankyou for your time. You have provided all the information I require to make a determination as to the viability and performance of your device.
Regards, Richard LeGros
Mark,
Sounds like you are telling us that you are sure your device removes 100% of everything that could be considered "bad".
If so, good.
I am troubled that you've not yet addressed the question of what happens if or when the system fails and how your group will be monitoring the output for contaminants and reporting the results to the RWQCB ... because surely one will fail every so often and surely the RWQCB is charged with monitoring possible water polluters and surely your company are one of those ... even if 99% of 5000 of your devices have no problems in any given year, there will be some 50 problems each year ... about one per week.
They have regulatory authority here no matter how you slice things ... unless your technology is perfect and will never fail ... and even then, they have the regulatory authority to ask you all to demonstrate that.
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