Sunday, March 05, 2006

Diesel Exaust PM10 Rule Compliance Letter.

  • Junk Science-Extensive Air Pollution From 1.6 Million Desel Truck Miles Per Year to pump septic tanks ignores new federal guidelines for spot air pollution. RWQCB not in contact with EPA Air about EPA Air Regs!


  • Junk Science-Removing water from septic tanks removes 25 MILLION gallons of water per year from the water basin causing further salt water intrusion and causing increased ground water degradation.(2800 Homes x6 pumpings/year x1500 Gallons/home= 25,000,000 Gallons/yr.) Duh?

Dear Ms. Patuliski
EPA AIR POLLUTION RULES ADMINISTRATION,
It has been brought to our attention that PM10 conformity rules may be in question concerning non-sustainable solutions to the Central Coast RWQCB ruling to truck 2800 septic tank contents six times per year, per parcel, over 100 miles to conform with a cease and desist order subject to the Porter Cologne Act. Under that act the RWQCB is supposed to consider sustainable solutions. Does this burden the Los Osos corridor area spot Air pollution? Is there a compliance issue with your agency? Our estimate is 1.6 million Diesel truck miles per year will be driven to comply with the septic pumping order. (2800 x 6 x 100 Miles on Los Osos Valley road and Hwy.101) LVR is a 12 mile two lane commuting road and the intersection of LVR and highway 101 already congested with rush hour, Home Depot and Cosco traffic.The balance of the trucking will be on 101 to Santa Maria for disposal or possibly Bakersfield as a destination for each load of effluvium.
It is our estimation that these emissions are avoidable and based on limited scientific discovery. There is actually an increase of fixed nitrates and nitrites in the effluvium if solids are eliminated from the septic tanks. Nitrogen reduction from sewage waste is accomplished by high carbon to nitrogen biomass raitos relative to nitrogen content so nitrogen can be digested by bacteria to accomplish denitrification. EPA data suggest a ratio of 5 Carbon atoms in biosolids to 1 Nitrogen atom for denitrification as optimal(See Chapter 3 in link to EPA Septic Systems Manual.).

In essence we are increasing air pollution for nothing and that is why we are suggesting sustainable interim solutions and involving your office in this policy decision. We are concerned that the order wastes energy, pollutes the air, and does nothing for water quality. We are making specific recommendations removing N from the waste stream using EPA conforming sustainable on site solutions and NSF complying products under NSF standards 40 41, and 46 to meet interim N reduction avoiding air quality traffic issues entirely.

We are hoping you can lend us your support in this effort and are like minded about limiting truck miles to reduce ground water nirtogen to federally mandated levels already approved in the RWQCB discharge permit for the on hold sewer project. Butte County already is installing approved systems to meet Nitrogen requirements approved by the Water Board in that county? Our hired engineers can propose valid N reduction with empirical data and monitoring using NSF monitoring guidelines from Stds 40, and 41, greywater recycling, and water conservation. We hope you can convince the RWQCB likewise.

We would appreciate your input.

Steve Paige

4 Comments:

Blogger Mike Green said...

Thaks Steve! You are awsome!

3:30 PM, March 05, 2006  
Anonymous Dogpatch Refugee said...

Second that!

4:38 PM, March 05, 2006  
Blogger Shark Inlet said...

Okay Steve, now you're off the deep end.

Sure, there will be extra air pollution from trucks being used to haul waste. However I don't hear you complaining when trucks are used to haul other stuff around from place to place. It seems like you are grasping at straws here to try to convince us that the RWQCB actions are plain wrong.

Even if the excess exhaust would violate some rule (which it doesn't), the problem is not the RWQCB's but essentially ours.


If lowering nitrates is the goal and our CSD board won't take the actions necessary to do it, I suspect that some sort of onsite solution would pass muster with the RWQCB. They've not formally told us what systems would be acceptable and what would not be, but the CDOs did say "pump or make us an offer". When you get your CDO you should propose an onsite solution and see what they say.

I expect that if an onsite solution would be good enough for the time until the sewer is finished, it wouldn't be any less expensive than pumping would be (well, at least until 2010), but it is a good idea to explore the various possibilities.

I've argued that this is the role the CSD should play in their discussions with the RWQCB and as a designated party. If they can get some argreement, in advance, for the parameters required for onsite, we'll all be better off. Perhaps if the CSD were even willing to, for a price, take care of the install and the paperwork the RWQCB would require it would be of great help to our community.

I don't expect that the CSD will actually do this, but it would be nice.

9:16 PM, March 05, 2006  
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5:00 AM, August 18, 2010  

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