Environmentally Significant Technology

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.