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Saturday, March 29, 2008

Reclamator’s Up And Running!

The following email exchange between Tom Murphy of AES and Barry Tolle of the county. For those following the Reclamator story, here’s further info as to its operation.

As with all things Sewerish, this little Danse Macabre de Merde will have to be resolved either in the courts or by an official sit-down/pronouncements by RWQCB, the County and Mr. Murphy before anything gets clarified in a meaningful manner. The question I raised in another posting regarding “selling” reclaimed water at 6 x the cost, remains. (i.e. The CSD can say to Mr. Murphy, No thanks, we don’t want your nice water. If it’s not a “discharge” then you don’t need to hook up to a sewer, so keep your nice water out of our sewer pipes, thank you, and go talk to Roger Briggs, thank you.) So, stay tuned.

And, posted last, an email from Harvey Packard to the CSD that raises as interesting question. Note his use of the word “may.” As in, We don’t know, we’re just guessing here. Who’s job is it to stop guessing and actually find out? Clearly, not Mr. Packard’s or the RWQCB’s.

Mr. Murphy’s reply to Mr. Tolle’s email (qwhich follows below, Mr. Packard's email after that)


Hi Barry,
. . . . Now, I am in Hawai'i closing a large commercial project, taking effluent from a> municipal plant and purifying it for irrigation to serve a very large health> care facility on Oahu utilizing the RECLAMATOR. Additionally, we are> discussing a Private Public Partnership arrangement with the Hawaii> Department of Health, providing the RECLAMATOR to retrofit over 180,000 residential cesspools and over 3,000 commercial cesspools statewide.

In regards to the RECLAMATOR being up and running, I somewhat puzzled by your suggestion that the RECLAMATOR shouldn't be running. Why not? Barry, I have been in contact with you and made several offers for you to arrange to meet me at the RECLAMATOR. Ed Ochs told me you came by the house last week, however, I didn't know you were coming by and wasn't available to show it to you. As of now, there won't be an opportunity to inspect it until I return from Hawai'i next week. So am I to understand a "water heater" or a "garbage disposal" isn't allowed to be put into operation until someone actually inspects it first?

I will contact you as soon as I return, until then, the RECLAMATOR is connected to the house sewer pipe, reclamates (reclaims and repurifies) the water, decants the reclamated water through a wireless water meter into a permeate reservoir from which it overflows back into the sewer line which delivers the metered reclamated water to the LOCSD's sewer lateral for purchase at the gong market value. The water meter and box with plumbing was exposed when you stopped by last week. I assume you saw it. Keep in mind, the RECLAMATOR does not produce any "effluent". It provides for the maximum degree of effluent reduction as is the criteria set fourth in USC 33/26 Sec. 1316. I brought by a jar of permeate which was drawn directly from the reservoir tank of the RECLAMATOR for your viewing pleasure or testing if you wish. As the LOCSD has not provided me with an "exemption from required connection", they currently are paying me for the water based upon my water meter reading. You may want to refer to the RECLAMATOR as a "money tree" when I connect it up to a publicly owned sewer lateral within the CCRWQCB jurisdiction as they are requiring a "hookup" to the publicly owned sewer laterals. Good for me as the reclamated water cost is 6 times (6Xs) the cost of the public drinking water supplied to my property. Also keep in mind that there is NO disposal as there is NO waste associated with the RECLAMATOR. I know this is very different from the onsite wastewater treatment systems you are familiar with which treat wastewater for disposal, however, the RECLAMATOR reclamates (not treats) water (not> wastewater) for beneficial reuse (not disposal). The RECLAMATOR does not require a "disposal field". When there is no publicly owned treatment works> collection lateral available to connect to and charge for the water, nor an existing disposal field which served a previous onsite wastewater treatment system, the reclamate simply flows into a 1 1/4" well point installed only 6-10 feed into the soil, I will install one soon to show how this is done.
As the system has only been operating for one week last Friday, the nitrates are not yet where they will soon be as it takes the de-nitrifiers a little longer to develop than the nitrifiers. NSF waited 6 weeks prior to starting their testing for the Nitrogen Series Analysis. However, I believe we are already less than 10 ppm since 5 days after startup. The electrical is very simple as I use 4 conductor cord run inside of 1" electrical conduit hard wired into a circuit box at the house which is off of a 15 amp breaker. All control is within the RECLAMATOR itself, not on the wall of the house as is others. As is explained in the RECLAMATOR Engineering Report you have a copy of, the maximum amp draw of any one piece of equipment is only 2.9 amps and there is a maximum draw of less than 6> amps for only one minute during the post decant back flush of the ultra filtration membrane upon the startup of the aeration phase of operation which happens a maximum of only 6 times per day. I understand this RECLAMATOR is very different in nature than anything the County has previously been exposed to as it complies with the MCLG USEPA standard for drinking water quality which is a non-enforceable public health goal standard. However, as we move to start installing 1000s within your jurisdiction, we will be glad to work with your department to fine tune a program to track all installs as they occur. I will discuss some ideas as to how this can happen next week upon my return, until then...ALOHA!

Tom Murphy,



Hi Tom: . . . . . Sorry I missed you last week . . .I just received a call that Mr. Low appeared at the Board of Supervisors meeting yesterday and claimed that the Reclamator was up and running.> Please be advised, until I make a final inspection of the Reclamator unit,> this unit should not be operating. Please contact me as soon as possible> to schedule a final inspection. I will be looking at connections between> house sewer and the reclamator unit, how effluent is handled, the disposal> field, and all electrical connections. Please contact me ASAP: Thanks: Barry Tolle 781-5628


And From Harvey Packard, RWQCB

As noted, above, at this late date, what’s that word “may” doing in there? As in “. . . may even be of higher quality.” Doesn’t anybody KNOW? Who’s job is it to actually KNOW something here? And To Mr. Packard’s Knowledge means. . . what, exactly? That he’s presuming? Guessing? Also note Mr. Packard’s statement that the basin plan prohibits all discharges of waste from sewer disposal systems. If that’s the case, how was it possible for the RWQCB to issue a discharge permit for the TRI-W plant to discharge waste onto the Broderson site, which is within the Basin? If that discharge was allowed because it met certain criteria that the RWQCB set, then does whatever the Reclamator is “discharging” also meet that same criteria? If Mr. Packard doesn’t know, i.e. the Reclamator “may” be doing something or other, then who does know?

email to CSD

Thu Feb 28 15:36:28 2008

Subject: Re: FW: Los Osos Community Services District

Ms. Biggs, I stated in my Feb 19 email (shown below), that we would have a further response to the CSD's inquiry within a couple of weeks. However, upon further review and reflection, we have only the following to add at this time.To our knowledge, the effluent quality from a Reclamator would not be any worse than that from the CSD's existing facilities, and may even be of higher quality. The Central Coast Water Board supports measures to minimize ongoing adverse impacts from septic systems. However, even if it works as well as its promotors claim it will, the Reclamator will still discharge waste. The Reclamator therefore does not comply with the Basin Plan, which prohibits all discharges of waste from sewage disposal systems, including engineered alternative systems.

The Central Coast Water Board has indicated that it does not intend to take additional enforcement action for violations of the Basin Plan prohibition as long as the County’s process stays on track. Once a community sewer system is available, or sooner if the County discontinues its efforts to build one, the CSD will be required to eliminate all onsite discharges of sewage waste. The CSD can do this by connecting to the sewer system, or by proposing and obtaining approval of another legal alternative to eliminate all onsite discharges. The requirement to eliminate onsite discharges does not violate Water Code Section 13360, even if the only feasible compliance alternative is connecting to a public system.

Harvey Packard, Section Manager and Enforcement CoordinatorCentral Coast Regional Water Quality Control Board895 Aerovista Place, Suite 101San Luis Obispo, CA 93401Phone: (805) 542-4639Fax: (805) 788-3558

12 comments:

Rick said...

However, even if it works as well as its promotors claim it will, the Reclamator will still discharge waste.

I know this defies the common sense use of the word, but this is exactly true in the parlance of water law.

And once again, I will remind folks that our federal system allows for dual jurisdiction over most environmental matters. The reclamators inventors may have passed muster with the federal EPA someplace, but that doesn't mean a damn thing.

Don't get me wrong--I'd love to see this succeed. I even want one. I just want to see the permit first--from the RWQCB. (Which won't happen.)

Watershed Mark said...

The discharge permit is Federal Form 200 http://www.waterboards.ca.gov/centralcoast/Applications/index.htm posted on the Quality Control Board website http://www.waterboards.ca.gov/

INTRODUCTION

This application package constitutes a Report of Waste Discharge (ROWD) pursuant to California Water Code

Section 13260. Section 13260 states that persons discharging or proposing to discharge waste that could affect

the quality of the waters of the State, other than into a community sewer system, shall file a ROWD containing

information which may be required by the appropriate Regional Water Quality Control Board (RWQCB).

Sorry Rick,

The RECLAMATOR does not discharge or discharge waste so it poses a "significate challenge" to the current nature of "things", which is a good thing all around!

The LOSTDEP RECLAMATOR Solution continues on step.

I Love L.O.

Watershed Mark said...

into a community sewer system, ...they left out the word "leaky"...

Sewers cause affect the quality of the waters of the State.
You'd think that would be "understood" by those seeking to protect the waters.

Watershed Mark said...

California Water Code http://www.waterboards.ca.gov/water_laws/docs/portercologne.pdf

I suggest you take a look at 13260 don't forget to look at 13360 while you are there.

Sewertoons AKA Lynette Tornatzky said...

rick,
I don't think they have passed anything anyplace but the one lone test by the NSF back in '95, the parameters of which the Wrecklamator dudes will not release.

I want to see both permits from the RWQCB -- AND the equivalent of what Consumer Reports does for dishwashers or toasters.

What we are given is a bunch of words by the promotes with no hard facts. I want to see years of test results from a variety of actual and different households. I don't believe this sort of data is available. They are attempting to prove their point by NSF testing on the house they have Wrecklamatored. One house, one set of residents, one kind of water usage. Big deal. I wager there would be different results of of a house with 5 students, no environmental thoughts and lots of partying. But we'll never know. Lots of words but no direct answers.

Sewertoons AKA Lynette Tornatzky said...

tom says,
"As the LOCSD has not provided me with an "exemption from required connection", they currently are paying me for the water based upon my water meter reading."

Funny, the LOCSD's lawyer said nothing of the kind at the last meeting - the Board is to "do nothing," she said, and there have been no meetings since then so that it should come before the Board. Are you SURE the LOCSD is paying you?

Ann says:
"As noted, above, at this late date, what’s that word “may” doing in there? As in “. . . may even be of higher quality.” Doesn’t anybody KNOW? Who’s job is it to actually KNOW something here?"

Ann, wouldn't the burden of proof be on the salesman? If not, every crackpot with an "invention" would be here asking the Water Board to test their device.

tom says:
"…gong market value."

Well, that says it all, doesn't it?

Churadogs said...

Toons sez:"Ann, wouldn't the burden of proof be on the salesman? If not, every crackpot with an "invention" would be here asking the Water Board to test their device."

How's about the waterboard saying, In order not to be deemed Polluting The Waters Of The State of California,(interesting caveat there, what happens if you're NOT pollluting the waters of the state of California? How do you prove or disprove that?? To date, we've had the weird Mad Hatter Teaparty testimony that the Board doesn'thave emperical evidence of Mr X, & or Z polluting the waters of the state of California yet they've been slapped with CDOs. What's up with that?), petitioner must meet the following "discharge" numbers under the following conditions for the following length of time: If you can meet those numbers, then we'll talk. If not, go away.

Watershed Mark said...

Sewerage discharges waste into and pollutes the Waters of the State.
A RECLAMATOR RECLAMATES and produces harvest water. Think Resource of Value here.

Cal. Water Code 13050 (l)(1) “Pollution” means an alteration of the quality of the
waters of the state by waste to a degree which
unreasonably affects either of the following:
(A) The waters for beneficial uses.
(B) Facilities which serve these beneficial uses.
(2) “Pollution” may include “contamination.”
(m) “Nuisance” means anything which meets all of the
following requirements:
(1) Is injurious to health, or is indecent or offensive to the
senses, or an obstruction to the free use of property, so as
to interfere with the comfortable enjoyment of life or
property.
(2) Affects at the same time an entire community or
neighborhood, or any considerable number of persons,
although the extent of the annoyance or damage inflicted
upon individuals may be unequal.
(3) Occurs during, or as a result of, the treatment or
disposal of wastes.
(n) “Recycled water” means water which, as a result of
treatment of waste, is suitable for a direct beneficial use
or a controlled use that would not otherwise occur and is
therefor considered a valuable resource.

Watershed Mark said...

A valuable resource is not a discharge or a discharge of waste.

Sewertoons AKA Lynette Tornatzky said...

Ann would it make you happy to pay for 45 lycimeters to go under the houses of the CDOers? Go for it! Head up the group that wants to make that purchase and installation.

Sorry, 8 house per acre is enough to convince me.

Watershed Mark said...

RECLAMATOR resolves the discharge/discharge of waste and produces harvest water and nuetralizes the CDO's and NOV's as a side effect it cleans up ansd abates with every "decant".

Such is being demonstrated in the PZ at RECLAMATOR House. $15,000.00 commences the $45.75/month service.

I'll be setting up "demonstration" tours shortly...I'll be in touch.

Every septic tank discharges waste bt design, so there is no need to measure it, toons.

Watershed Mark said...

Hey Rick:
Here is one of those environmental(health) issues you were refering to:
A key element of these disputes is the argument over health effects.

The federal Telecommunications Act of 1996 forbids local governments from using health claims to ban cell towers or regulate their locations as long as the sites comply with Federal Communications Commission regulations.

Local governments can regulate what the towers look like, what they are made of and how they fit in with neighboring buildings and scenery.

Like I have been saying Federal Law if more stringent takes supremacy....A discharge must still contain "waste" to be considered a discharge.

Here's my favorite line in the story: Lenthall said he has heard from people who want cell phone coverage expanded, and he asked, “How does democracy serve them” if the board listened only to one side? Go LENTHALL!!