The following comments are in response to the Los OsosWastewater Draft Environmental Impact Report and were sent to Mark Hutchinson, Environmental Projects Manager, San Luis Obispo County, Calif. via Facsimile 1/14/09 and FedEx overnight to arrive 1/15/09.
A technology which provides a 50%+ reduction in energy usage coupled with a 70% reduction in capital cost is very smart, no matter how you pay fit it.
Comments by Mark Low/ECOfluid
DEIR Los Osos
County of San Luis Obispo
Los Osos Wastewater Project
Attention: Mark Hutchinson and all other interested parties;
ECOfluid’s http://www.ecofluid.com/ Treatment Technology information was provided to
San Luis Obispo County, your consulting engineer “Carollo Engineers” and you
before and/or during the EIR Scoping period yet that information was not included
as part of the county’s evaluation and current EIR Process/Report. As part of my
continuing effort to make known ECOfluid’s USBF (MBR) energy conservation and
capital cost saving wastewater treatment technology, I have attached a series of
exhibits in support of the county’s study that would be of interest to those
responsible for researching solutions for vetting and selection in the Los
Osos/Baywood Park Septic Tank Discharge Elimination Project. I will keep my
comments as sharp and on point as is possible, while extending the invitation to
you and/or your consulting engineer(s) to meet with our engineers to discuss more
fully the facts, features and advantages of employing ECOfluid’s USBF (with or
without ultra filtration membrane) Treatment Technology.
In response to the DEIR, I have the following comments regarding our technology
which seems to have been missed “during the process”:
First:
Electric Power Consumption for ECOfluid’s USBF Treatment Biology only
Is 450,000 kWh/year for a 1.2 MGD Facility.
Electric Power Consumption for all equipment including headworks, biological
treatment, external membrane filtration, UV Disinfection (tertiary treatment)
Is 900,000 kWh/year for a 1.2MGD ECOfluid USBF MBR Facility.
When these figures are added to those on Page 454 of the DEIR in order that a true
“side by side” comparison of technology include ECOfluid’s USBF, there is little
doubt, if any, that energy is conserved in the daily operation of and for the life of
the Facility.
The energy usage information regarding the ECOfluid USBF (MBR)
Treatment Technology is a “significant environmental issue” as
described in CEQA Statues:
http://ceres.ca.gov/topic/env_law/ceqa/guidelines/art7.html
15088. Evaluation of and Response to Comments
(c) The written response shall describe the disposition of significant
environmental issues raised (e.g., revisions to the proposed project to
mitigate anticipated impacts or objections). In particular, the major
environmental issues raised when the Lead Agency's position is at variance
with recommendations and objections raised in the comments must be addressed
in detail giving reasons why specific comments and suggestions were not
accepted. There must be good faith, reasoned analysis in response.
Conclusory statements unsupported by factual information will not suffice.
SECOND:
Capital Cost for an ECOfluid USBF(MBR) equipped facility is significantly less at $6.80
(without a membrane) and $7.40 a gallon capital costs (with membrane) tertiary treatment
compared to the $20.84 a gallon capital cost for the secondary level treatment oxidation
ditch out lined in the San Luis Obispo County’s current RFQ.
ECOfluid’s “pre-engineered” designs conserve energy and resources because all biological processes and secondary clarifications are accomplished in a single tank. It takes less time, money and energy to design, bid, build, operate and maintain this very efficient and effective treatment technology. A significantly less amount of land, time, energy and money are needed to construct and operate an ECOfluid USBF (MBR) equipped facility which
results in a lower environmental and economic footprint, overall.
ECOfluid’s USBF (MBR) technology significantly reduced energy usage, operational and
construction costs as stated here and in the accompanying documentation, will more than
cover any expense of reevaluating the county’s consulting engineer’s current conclusions,
when compared with every other treatment technologies outlined on page 454 in the
current DEIR.
Third:
Certain collection conveyance systems appear to have been overlooked and not
included in the DEIR. Wikipedia has a descent description/discussion that could be
evaluated side by side, the gravity sewerage selection that seems to have risen to
the top of the county’s study process. The DEIR provides little, if any, significant
discussion regarding leak detection and certainly no standards were discussed for
measuring “leakage” of raw sewage from 40+ miles of under street collection and
no discussion at all regarding the approximately same distance of on-site
conveyance to the under street “gravity” conveyance.
It is significant that un-welded sewer pipes are permitted to leak 499 gallons per
day from a “test section” while being constructed according to the San Luis Obispo
Public Improvement Standard while a vacuum or grinder pump conveyance system
won’t operate properly if either leaks at all. The actual leakage from a gravity sewer
buried up to 25 feet deep may never be detected, after it has been buried, until a
catastrophic failure or sinkhole occurs while a vacuum or grinder pump small
diameter collection system is installed using environmentally sound directional
boring technology at a fraction of the cost in a fraction of the time.
http://en.wikipedia.org/wiki/Grinder_pump
http://en.wikipedia.org/wiki/Sanitary_sewer
4. The allowable leakage in the test section shall not exceed 500 gallons
per mile, per 24 hours, per inch diameter of pipe tested at the five foot test head.
http://www.slocounty.ca.gov/AssetFactory.aspx?did=9362
Respectfully submitted,
Mark Low
Mark@nowastewater.com
(602) 740-7975 Voice
(480) 464-0405 Facsimile
Please contact me if interested in receiving the complete exhibits package.
Saturday, January 17, 2009
Wednesday, January 14, 2009
Smart Choices Protect the Public
The following is an exchange between Mark Hutchinson Environmental Programs Manager, Department of Public Works, San Luis Obispo County and myself.
Mark received information regarding ECOfluid during the EIR Scoping period in Decembber 2007, but none of it was discussed in the DEIR and the County's Consulting Engineer never followed up after their May 5th, 2007 meeting with "us".
We will continue our work to make known the USBF MBR Technology to those responsible for solving wastewater treatment issues, because using USBF MBR conserves energy and capital costs are greatly reduced, which eases the environmental and finacial footprint.
Smart choices are those based upon full and complete research and comparisons.
Fortunately the law appears to protect those choices.
Subject: Title 14 (b)&(c) & 15088.5 (a)
http://ceres.ca.gov/topic/env_law/ceqa/guidelines/art7.html
15088. Evaluation of and Response to Comments
(a) The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response. The Lead Agency shall respond to comments received during the noticed comment period and any extensions and may respond to late comments.
(b) The lead agency shall provide a written proposed response to a public agency on comments made by that public agency at least 10 days prior to certifying an environmental impact report.
(c) The written response shall describe the disposition of significant environmental issues raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections). In particular, the major environmental issues raised when the Lead Agency's position is at variance with recommendations and objections raised in the comments must be addressed in detail giving reasons why specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice.
(d) The response to comments may take the form of a revision to the draft EIR or may be a separate section in the final EIR. Where the response to comments makes important changes in the information contained in the text of the draft EIR, the Lead Agency should either:
(1) Revise the text in the body of the EIR, or
(2) Include marginal notes showing that the information is revised in the response to comments.
Authority cited: Section 21083, Public Resources Code. Reference: Sections 21092.5, 21104, and 21153, Public Resources Code; People v. County of Kern (1974) 39 Cal. App. 3d 830; Cleary v. County of Stanislaus (1981) 118 Cal. App. 3d 348.
15088.5. Recirculation of an EIR Prior to Certification
(a) A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification. As used in this section, the term "information" can include changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not "significant" unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement. "Significant new information" requiring recirculation include, for example, a disclosure showing that:
------------------------------------------------------------------------------------------------------------------
I am particularly interested in how the use of MBR technology might reduce one or more of the project's environmental effects, as described in the DEIR.
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
-----Original Message-----
From: Mark Low [mailto:Mark@NOwastewater.com]
Sent: Friday, December 12, 2008 3:54 PM
To: 'mhutchinson@co.slo.ca.us'
Subject: RE: Not all MBR's are the same
Beautiful!
Thank you for your assistance.
Better water quality for less energy and at less capital cost than Ox-Ditch because USBF is done all in one basin, using gravity instead of electricity to process water through the membrane.
When tertiary membrane treatment is implemented without electricity now it will eliminate any future EIR study/reporting and construction costs and impacts of the planned tertiary "upgrade".
I will work on my comments and questions and would still appreciate a few moments of your time in the weeks ahead to speak with Karel Galland and me.
May we schedule an appointment?
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
-----Original Message-----
From: mhutchinson@co.slo.ca.us [mailto:mhutchinson@co.slo.ca.us]
Sent: Friday, December 12, 2008 3:40 PM
To: Mark Low
Subject: Re: Not all MBR's are the same
Mark,
Most people who provide comments on draft EIRs use regular mail, but I
don't see any reason why you couldn't use certified mail. Please remember
that we should focus EIR comments on environmental impacts, and that we
should explain the basis for our comments using facts, reasonable
assumptions based on facts, and expert opinion based on facts (CEQA
Guidelines section 15200).
I am particularly interested in how the use of MBR technology might reduce
one or more of the project's environmental effects, as described in the
DEIR.
Mark Hutchinson
Environmental Programs Manager
Department of Public Works
"Mark Low"
12/12/2008 02:27 cc
PM,
Subject
Not all MBR's are the same
Hello Mark,
From the DEIR http://www.lowwp-eir.net/lowwpeir/Los_Osos_DEIR.pdf :
"MBR is one of the most commonly implemented treatment process components
for communities the
size of Los Osos seeking high-quality effluent. MBR has a high energy
demand and high capital cost
for implementation. However, MBR has been included as a Level B alternative
in consideration of
the significant benefits offered by the small physical footprint and very
high-quality of the effluent
produced by MBR systems."
The statement from the DEIR is not correct: MBR has a high energy demand
and high capital cost
for implementation.
Will I need a certified return receipt when I submit my comments/questions
for the DEIR?
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
-----Original Message-----
From: mhutchinson@co.slo.ca.us [mailto:mhutchinson@co.slo.ca.us]
Sent: Friday, December 12, 2008 2:44 PM
To: Mark Low
Cc: pogren@co.slo.ca.us
Subject: Re: NWRI MBR Recommendation
Mark,
MBR is included in chapter 7 of the DEIR (Alternatives) as well as in
Appendix P-1 of the DEIR. Additional information is included in the Fine
Screening Report and of course in the 2001 EIR.
Mark Hutchinson
Environmental Programs Manager
Department of Public Works
"Mark Low"
"Mark Hutchinson"
12/12/2008 10:30
AM cc
,
Subject
NWRI MBR Recommendation
http://www.slocounty.ca.gov/AssetFactory.aspx?did=18272
Hi Mark,
I was able to access the report via the link I harvested previously below.
I see that someone is keeping the front page on the archive/news lean and
mean, which is why I didn’t see it and why I called you about it.
Is the county looking at the NWRI recommendation for Membrane Bioreactor?
If not, why not?
If so, how can I help?
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
From: Mark Low [mailto:Mark@NOwastewater.com]
Sent: Wednesday, November 05, 2008 9:35 AM
To: pogren@co.slo.ca.us; John Waddell; Mark Hutchinson;
'LOWWP@co.slo.ca.us'
Cc: BGibson@co.slo.ca.us; Karl Hadler; Lou Carella; Mark Low
Subject: ECOfluid's USBF 1 MGD Generic Plant Proposal-Membrane Bioreactor
all gravity process flow
Importance: High
Greetings Gentlemen,
In response to October 27, 2008: Release of the Final Report from the NWRI
Independent Peer Review Panel:
Treatment Technology
4.3.1 Options:
Biolac
Facultative Pond
Oxidation Ditch
Membrane Bioreactor (added by Panel)
Attached please see a generic proposal for a 1MGD ECOfluid USBF Membrane
Bioreactor Title 22 Water Reclamation Facility.
A close review of our treatment technology will reveal many advantages over
the other treatment technologies your study process included.
These advantages include, but are not limited to, reduced footprint,
reduced energy consumption, no odor, reduced sludge production, reduced
capital and O&M costs.
The cost range is $6,900,000.00 for a Micro Screen option and $7,400,000.00
for the Membrane option which includes 30% design, engineering and
contingency. As Paavo Ogren stated in August 2007- If there is a technology
that is significantly less expensive”, “then that technology becomes the
new standard and all others fall away”. When these words become reality the
citizens are well represented by their government.
The one factor that significantly contributes to operating simplicity and
reduces operating and maintenance needs and costs, is the. Pumped once from
the equalization tank into the bioreactors, the entire flow through the
process (biology, filtration and UV disinfection) is by gravity. Gravity
and hydraulic action are forces of nature and is energy which is free of
charge.
Of course any size (GPD) facility for any strength influent can be designed
upon request.
The attached Nitrogen Reduction Memorandum should be of particular interest
to those interested in solving Nitrogen loading problems.
ECOfluid President, Karel Galland and I are available to discuss in detail
this generic proposal and how a site specific proposal can be developed for
your project.
We expect to see our technology included in your study review process,
including the EIR study.
Time and money are precious, so we won’t waste any and know that you will
want to give us your best consideration so we look forward to hearing from
you soon.
Your prompt attention in this matter will be appreciated.
Kind regards,
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
(See attached file: ECOfluid 1MGD Generic Proposal.zip)(See attached
file: Custom Designs Municipal.zip)
Mark received information regarding ECOfluid during the EIR Scoping period in Decembber 2007, but none of it was discussed in the DEIR and the County's Consulting Engineer never followed up after their May 5th, 2007 meeting with "us".
We will continue our work to make known the USBF MBR Technology to those responsible for solving wastewater treatment issues, because using USBF MBR conserves energy and capital costs are greatly reduced, which eases the environmental and finacial footprint.
Smart choices are those based upon full and complete research and comparisons.
Fortunately the law appears to protect those choices.
Subject: Title 14 (b)&(c) & 15088.5 (a)
http://ceres.ca.gov/topic/env_law/ceqa/guidelines/art7.html
15088. Evaluation of and Response to Comments
(a) The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response. The Lead Agency shall respond to comments received during the noticed comment period and any extensions and may respond to late comments.
(b) The lead agency shall provide a written proposed response to a public agency on comments made by that public agency at least 10 days prior to certifying an environmental impact report.
(c) The written response shall describe the disposition of significant environmental issues raised (e.g., revisions to the proposed project to mitigate anticipated impacts or objections). In particular, the major environmental issues raised when the Lead Agency's position is at variance with recommendations and objections raised in the comments must be addressed in detail giving reasons why specific comments and suggestions were not accepted. There must be good faith, reasoned analysis in response. Conclusory statements unsupported by factual information will not suffice.
(d) The response to comments may take the form of a revision to the draft EIR or may be a separate section in the final EIR. Where the response to comments makes important changes in the information contained in the text of the draft EIR, the Lead Agency should either:
(1) Revise the text in the body of the EIR, or
(2) Include marginal notes showing that the information is revised in the response to comments.
Authority cited: Section 21083, Public Resources Code. Reference: Sections 21092.5, 21104, and 21153, Public Resources Code; People v. County of Kern (1974) 39 Cal. App. 3d 830; Cleary v. County of Stanislaus (1981) 118 Cal. App. 3d 348.
15088.5. Recirculation of an EIR Prior to Certification
(a) A lead agency is required to recirculate an EIR when significant new information is added to the EIR after public notice is given of the availability of the draft EIR for public review under Section 15087 but before certification. As used in this section, the term "information" can include changes in the project or environmental setting as well as additional data or other information. New information added to an EIR is not "significant" unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project's proponents have declined to implement. "Significant new information" requiring recirculation include, for example, a disclosure showing that:
------------------------------------------------------------------------------------------------------------------
I am particularly interested in how the use of MBR technology might reduce one or more of the project's environmental effects, as described in the DEIR.
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
-----Original Message-----
From: Mark Low [mailto:Mark@NOwastewater.com]
Sent: Friday, December 12, 2008 3:54 PM
To: 'mhutchinson@co.slo.ca.us'
Subject: RE: Not all MBR's are the same
Beautiful!
Thank you for your assistance.
Better water quality for less energy and at less capital cost than Ox-Ditch because USBF is done all in one basin, using gravity instead of electricity to process water through the membrane.
When tertiary membrane treatment is implemented without electricity now it will eliminate any future EIR study/reporting and construction costs and impacts of the planned tertiary "upgrade".
I will work on my comments and questions and would still appreciate a few moments of your time in the weeks ahead to speak with Karel Galland and me.
May we schedule an appointment?
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
-----Original Message-----
From: mhutchinson@co.slo.ca.us [mailto:mhutchinson@co.slo.ca.us]
Sent: Friday, December 12, 2008 3:40 PM
To: Mark Low
Subject: Re: Not all MBR's are the same
Mark,
Most people who provide comments on draft EIRs use regular mail, but I
don't see any reason why you couldn't use certified mail. Please remember
that we should focus EIR comments on environmental impacts, and that we
should explain the basis for our comments using facts, reasonable
assumptions based on facts, and expert opinion based on facts (CEQA
Guidelines section 15200).
I am particularly interested in how the use of MBR technology might reduce
one or more of the project's environmental effects, as described in the
DEIR.
Mark Hutchinson
Environmental Programs Manager
Department of Public Works
"Mark Low"
12/12/2008 02:27 cc
PM
Subject
Not all MBR's are the same
Hello Mark,
From the DEIR http://www.lowwp-eir.net/lowwpeir/Los_Osos_DEIR.pdf :
"MBR is one of the most commonly implemented treatment process components
for communities the
size of Los Osos seeking high-quality effluent. MBR has a high energy
demand and high capital cost
for implementation. However, MBR has been included as a Level B alternative
in consideration of
the significant benefits offered by the small physical footprint and very
high-quality of the effluent
produced by MBR systems."
The statement from the DEIR is not correct: MBR has a high energy demand
and high capital cost
for implementation.
Will I need a certified return receipt when I submit my comments/questions
for the DEIR?
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
-----Original Message-----
From: mhutchinson@co.slo.ca.us [mailto:mhutchinson@co.slo.ca.us]
Sent: Friday, December 12, 2008 2:44 PM
To: Mark Low
Cc: pogren@co.slo.ca.us
Subject: Re: NWRI MBR Recommendation
Mark,
MBR is included in chapter 7 of the DEIR (Alternatives) as well as in
Appendix P-1 of the DEIR. Additional information is included in the Fine
Screening Report and of course in the 2001 EIR.
Mark Hutchinson
Environmental Programs Manager
Department of Public Works
"Mark Low"
"Mark Hutchinson"
12/12/2008 10:30
AM cc
Subject
NWRI MBR Recommendation
http://www.slocounty.ca.gov/AssetFactory.aspx?did=18272
Hi Mark,
I was able to access the report via the link I harvested previously below.
I see that someone is keeping the front page on the archive/news lean and
mean, which is why I didn’t see it and why I called you about it.
Is the county looking at the NWRI recommendation for Membrane Bioreactor?
If not, why not?
If so, how can I help?
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
From: Mark Low [mailto:Mark@NOwastewater.com]
Sent: Wednesday, November 05, 2008 9:35 AM
To: pogren@co.slo.ca.us; John Waddell; Mark Hutchinson;
'LOWWP@co.slo.ca.us'
Cc: BGibson@co.slo.ca.us; Karl Hadler; Lou Carella; Mark Low
Subject: ECOfluid's USBF 1 MGD Generic Plant Proposal-Membrane Bioreactor
all gravity process flow
Importance: High
Greetings Gentlemen,
In response to October 27, 2008: Release of the Final Report from the NWRI
Independent Peer Review Panel:
Treatment Technology
4.3.1 Options:
Biolac
Facultative Pond
Oxidation Ditch
Membrane Bioreactor (added by Panel)
Attached please see a generic proposal for a 1MGD ECOfluid USBF Membrane
Bioreactor Title 22 Water Reclamation Facility.
A close review of our treatment technology will reveal many advantages over
the other treatment technologies your study process included.
These advantages include, but are not limited to, reduced footprint,
reduced energy consumption, no odor, reduced sludge production, reduced
capital and O&M costs.
The cost range is $6,900,000.00 for a Micro Screen option and $7,400,000.00
for the Membrane option which includes 30% design, engineering and
contingency. As Paavo Ogren stated in August 2007- If there is a technology
that is significantly less expensive”, “then that technology becomes the
new standard and all others fall away”. When these words become reality the
citizens are well represented by their government.
The one factor that significantly contributes to operating simplicity and
reduces operating and maintenance needs and costs, is the. Pumped once from
the equalization tank into the bioreactors, the entire flow through the
process (biology, filtration and UV disinfection) is by gravity. Gravity
and hydraulic action are forces of nature and is energy which is free of
charge.
Of course any size (GPD) facility for any strength influent can be designed
upon request.
The attached Nitrogen Reduction Memorandum should be of particular interest
to those interested in solving Nitrogen loading problems.
ECOfluid President, Karel Galland and I are available to discuss in detail
this generic proposal and how a site specific proposal can be developed for
your project.
We expect to see our technology included in your study review process,
including the EIR study.
Time and money are precious, so we won’t waste any and know that you will
want to give us your best consideration so we look forward to hearing from
you soon.
Your prompt attention in this matter will be appreciated.
Kind regards,
Mark Low
602.740.7975 voice
480.464.0405 facsimile
Mark@NOwastewater.com
P.O. Box 1355 Mesa, Arizona 85211
Spero Meliora "I aspire to greater things"
(See attached file: ECOfluid 1MGD Generic Proposal.zip)(See attached
file: Custom Designs Municipal.zip)
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