Sunday, March 26, 2006

Pumping Compliance Attachment to Plan Set

Alternative Compliance Improvement Validation

Author: Steven Paige
Date: 3/21/2006
Property Location:
1554 Ninth Street, Los Osos, California
Owner of Record:
Steven Paige
Alternative System Designer:
Steven Paige
Steven Paige, Owner/Installer Contractors License, Cl 385994

Subject to:

Alternative compliance to Order R3-2006 Central Coast Regional Quality Control Board INTERIM COMPLIANCE REQUIREMENTS set forth in paragraph B-3 "Other Methods" of Compliance.

As per the CRWQCB Staff report dated March 13, 2006 the benchmark reduction of nitrates was investigated by the RWQCB and a standard of 22 percent nitrate reduction was assumed by the six bi-monthly pumpings per year, per household (Pg. 2 Paragraph 2).

Project description:

This project describes an alternative storage, pumping, and disposal plan for a reduction of Water borne Nitrogen loading on the subject's property to reduce the loading by 22% or more on a yearly average.

Urine is proposed to be removed from the waste stream before entering the septic tank by direct source separation of the urine and feces utilizing human behavior as a separation mechanism. The urine is then stored separately and then pumped by a Septic hauling contractor to Santa Maria and disposed of at their sewer plant.

This project is based on the following assumptions:


2) The physical principal that matter cannot either be created or destroyed ad hoc.

3) Normal laws of mathematics i.e. multiplication and percentage calculations are the rule.

4) Data on TN (Total Nitrogen) differences between urine and feces where urine contains 75% TN and feces 25% TN123 in the toilet waste stream.

5) Federal mandate in Section 503 of the Federal Clean Waters Act that Agency's 'promulgate' sustainable and alternative on site sewage disposal systems, that State Agencies are bound to be consistent with Federal Law, and that Federal law supersedes State law in this respect.

Project Design Standards:

1) Bidet installed is approved for disposal of liquid human byproducts and water as per ASME/ANSI Al12.19.2M Bidets have a 1 ½ inch drain and are considered .5 fixture units simplifying installation. Bidets can be plumbed out an exterior wall(See Plan).

2) ABS plumbing to UPC 2000 as adopted by the County of San Luis Obispo.

3) Waste Storage tank is non-corrosive meeting PCO standards for liquid corrosives and liquid fertilizer handling. Storage is in a portable above ground tank.

4) Septic tank improvements described meet NSF Section 46 testing and standards.

5) Charcoal filter, Float Alarm and Remote Alarm are NSF Section 46 compliant and approved.

6) Before final inspection there will be an initial Septic Tank Pumping and monitoring quarterly thereafter with re-pumping required after "sludge level is within eight inches of the outlet device" (as per RWQCB resolution 83-12). This is consistent with previous water board rulings.

7) The owner will verify with receipts the haulage of sequestered urine for verification by the RWQCB if desired. Haulage shall continue quarterly or as the alarm system so warns until the subject property complies with water quality standards equivalent to WASTE DISCHARGE/RECYCLED WATER REQUIREMENTS ORDER NO. R3-2002-0108 onsite or is connected to a community sewer approved by the RWQCB.

7) A deed restriction should contain all requirements and manuals as per this Alternative Plan so as to become part of a home sale title report if home is sold. The transferee will be disclosed in the disclosure report the nature and design of the system and it's operation, including human behavioral inputs. A copy of the restriction and manual should be necessary for final inspection.

Description of household pollutant reduction:

Urine containing 58% of the household nitrate production is separated from all other wastes unilaterally before going into the septic tank. 78% of TN comes from toilet wastes175% TN is held in urine content.123 78% X 75% = 58%. Also 58% > 22% therefore urine separation exceeds the criteria set by the RWQCB mandatory pumping program.

Removal of Garbage disposal will render the pollutant reduction further to 5% more reduction in TN, 28% reduction in BOD(5), and 37% reduction in solids5Hence the total reduction is 63% reduction in TN, 28% reduction in BOD, and 37% reduction in solids entirely by behavioral source separation.

Source separation of trash products is an example of successful behavioral modification to augment sustainability and logic would assume that human waste source separation would have the same results. Persons not desiring to this option could continue with dictated pumping.

Offsite Airshed Pollutant Reduction

The estimated amount of waste haulage per household per year is 9000 gallons. 6 haulings x 5000 households x 120 roundtrip miles to Santa Maria (not including pump out pollution and idle time) = 3.6 Million diesel truck miles per year added to the San Luis Obispo Airshed.

NOx is produced by diesel truck effluvium shipping and is equal to 12.8 grm/mi6 X 3,600,000 miles X 1/2.8 grm/oz X 1/16 oz/lbs X 1/2200 Ibs/ton = 467 Tons of Atmospheric Nitrogen released. With 116 tons of Nitrogen settling out of the air and going back into the watershed!

Correct me if I am wrong here. What this really means is that for every pound of Nitrogen you are hauling you are dumping five pounds back into the Bay because there is only 78 grams of N per truck load and 384 grams are going into the Bay from the diesel exhaust. Contrarily, source separation cuts haulage per household by a factor of 400 gal/9000 gal. or 96% Then- 467 Tons X 4% = 18 Tons of NOx air pollution from hauling urine separate. That’s a big difference not even considering the traffic congestion.

Of the air NOx in the airshed it has been shown by the lengthily and encompassing study of Chesapeake Bay that 22 to 25 percent of the NOx returns to the watershed mechanically when air NOx is released in the adjacent area. My informational source for this claim is in : Atmospheric Deposition, A Handbook for Watershed Managers, Office of Wetlands, Oceans, and Watersheds U.S. Environmental Protection Agency Washington, DC 20460 EPA-453/R-01-009 September 2001 see:
It is a fair assumption that the truck hauling NOx would follow on these percentages.

Salt Water Intrusion Reduction

For tank pumping the quantity of water removed from the hydrologic cycle of Estero Bay and removed from recharge is: 9000 Gallons/yr. X 5000 Households = 45 million gallons per year. The impact of this withdrawal is unknown but it is the equivalent of almost two months usage for the whole community. Source separation could avoid legal complaints by water purveyors for the huge draw against groundwater recharge.

Source separation including .2 liter urine wash down per flush for a family of three would probably not exceed 400 gallons per year. So 400 X 5000 households = 1.1 Million Gallons but the water conservation from saved toilet flushes 6 X 1.6 gal/flush x 365 days x 5000 households = 17.5 Million gallons/yr saved by not being withdrawn. The net gain to basin hydrology in any case would be over 15 Million gallons per year. There would be no net withdrawal.

The motivational feedback to not flush lots of water with urine is that pumping would occur less often costing the homeowner less money.

2% EPA Benchmark Affordability Reached7

The benchmark cost according to the EPA should not exceed 4% of yearly income of a family for both water and sewer cost. For sewer cost alone the amount would be 2%. The income of 33% of the families at Baywood Elementary earn below $28,000 per year with many being one income single parents like myself. $28,000 X 2% X 1/12 = $46.00/ MO. Or $138.00 per quarterly pumping compared to $800.00 for the tank pumping requirement. This would approximate the pumping cost of 100 gallons. Standard portable toilets cost approx $60.00 to service. Hence source separation would meet the low income community needs were Septic pumping does not.

Behavioral Motivation

Behavioral motivation is primarily monetary. The secondary motivation would be environmental awareness. Source separation could be eventually resource oriented where urine is reprocessed onto liquid fertilizer for agricultural users. Swedish studies involving resource source separation and contaminant removal are well documented and available from the author at the request of your department.


It is hoped by this permit application that both yourselves and the RWQCB will consider source separation and pumping as an alternative to septic pumping. It is understood that any approval for an alternative would have to meet the RWQCB needs if applied throughout the community. I think the plan for my property does that. This plan would make Los Osos cutting edge in resource management in line with advanced studies and pilot projects being carried out in Sweden and elsewhere without the risk of the project unknowns of using human urea as a resource. It sets up waste separation behaviors that are the most energy efficient way of processing human groundwater Nitrogen pollution (see enclosed study). Pending your approval, I have five other prohibition zone homeowners waiting for a similar installation.

The main reasons for approving my plan are:

1) 63% Nitrogen removal compared to 22%.

2) Lower cost per household.

3) No groundwater withdrawal, actually conserves groundwater.

4) Uses off the shelf industry standardized equipment.

5) Creates advanced environmental awareness.

6) 1/10 the traffic and air pollution generated.

7) Possible resource management in the future.

8) Much lower energy consumption requirements.

9) Economic advantage for many small local retrofitting contractors.

Thank you for your consideration. It is my intention to avoid a CDO on my property by making improvements immediately. Your prompt attention is necessary to prevent devaluation of my property and potential legal encumbrances caused by your inaction. Lets act now to save our Bay!

Steve Paige

1)Nutrients in urine: energetic aspects of removal and recovery M. Maurer*, P. Schwegler and T.A. Larsen EA WAG, Environmental Engineering, Uberlandstrasse 133, CH-8600 Dubendorf, Switzerland
2) Siegrist et al. et aI, 1976 2Beckerus et aI, 1998 3Jonsson et aI, 1997, Medcalf and Eddy, 2003
3) Department of Nutritional Sciences NS 160University of California, Berkeley Unit III: HUMAN PROTEIN NEEDS
4) 3 & 2 page 2.
7) EPA 832-B-97-004 Financial Capability Assessment


Blogger Shark Inlet said...

Perhaps I am reading this wrong, but it seems that you're essentially pitching an experimental system to the RWQCB. (Many aspects of this idea seem to make sense, but the package, as a whole, on a 5000 home scale hasn't ever been tried.)

If they sign on, let us know.

4:09 PM, March 27, 2006  
Blogger Steve Paige said...

Here's how it works in a nut shell, Shark Inlet...... There is absolutely nothing experimental with source separation. There is no increased discharge at all. The nitrates are removed from the front end of the process before they are mixed with all the other water uses in your home- bioreactor (SEPTIC TANK) Urine contains 58% of all household nitrates. Urine is going into a holding tank, collected and shipped to the Santa Maria sewer plant for processing under THEIR wastewater discharge permit.

If you go on vacation and don't use your septic tank do you need a waste discharge permit for reducing it's use? We are sending the urine on a vacation for a while until the sewer or sewers are redesigned and built. The balance of nitrates now leaving your septic tank is 58% lower than it was before you sequestered your pee pee. This is of course if you believe in physics i.e.- Matter cannot either be created or destroyed. No N in means no N out.

Storing and shipping urine is no more experimental than storing and shipping your septic tank contents. Now in the future if someone wants to buy the urine and process it into chemical fertilizer that could happen. But it's not our concern. Market forces will drive the the price of energy so high that making urea fertilizer will become very expensive. It may be cheaper even now to 'clean up' urine of pathogens and use it as commerical fertilizer.

10:24 PM, March 27, 2006  
Anonymous PublicWorks said...

This could give a whole new connotation to a 'lemonade' stand.

This is great in theory. Treat the poop on-site, and collect the urine in small diameter pipes to 1-2 treatment/processing facilities.

10:20 AM, March 28, 2006  
Blogger Mike Green said...

Steve, I read that you already have five property owners lined up, if I'm not one of those, count me as #6

6:06 PM, March 29, 2006  
Blogger Sewertoons said...

OK, I'm still asking, how does this thing work? You have to pitch out your old toilet, right? Can you pee and poop in the same new pot or do you need two different pots? (My bathrooms are wa-y-y-y too small for that!) How do you monitor compliance if people get lazy and it all goes in one pot?

So how much does this cost per household? In 2010 we have can have NO discharge, nitrate laden or otherwise. This won't work then!

6:24 PM, March 29, 2006  
Anonymous PublicWorks said...

Hopefully Steve is successful in getting a waiver with this.

The only problem I see with it is when you're plastered or hung over at 2 am, it'll be hard to aim for the right section.

6:50 PM, March 29, 2006  
Blogger Mike Green said...

A good argument could be made in 2010 that the discharge from the onsite system is better than the (supposedly) on line WWTF, correct me if I'm wrong, but doesn't prop 218 specificaly allow useage of alternate systems if it can be proved that its cheaper?

7:51 PM, March 29, 2006  
Blogger Mike Green said...

publickworks, you need to quit drinkin so much!

7:53 PM, March 29, 2006  
Blogger Mike Green said...

As far as compliance goes, Why is water pollution held to such different standards than air pollution? The EPA uses air quality samples to gauge the effectiveness of the smog laws, why can't the "water gods" use the same thing? I'm talking test wells here, something with test equipment that will measure the amount of N in the aquifer. If reduction is achieved we all call victory and go home from this war.

8:02 PM, March 29, 2006  
Blogger Steve Paige said...

The RWQCB is applying two different standards to the same sewage. One standard to the Los Osos Community Service District outlined in the above discharge order and another standard to the peoples individual discharges requiring no discharges at all after 2010. My complaint is partially based on City of Burbank v. State Water Resources Control Bd. (2005) 35 Cal.4th 613 , -- Cal.Rptr.3d --; -- P.3d -- [No. S119248. Apr. 4, 2005.].

If the LOCSD wastewater discharge permit meets federal standards that by law they have to, then the individual discharge standards of the People’s CDO’s exceeds federal standards and is in conflict with the promulgation clause of the Federal Clean Waters Act encouraging sustainable on site waste water treatment. Simply put, you are attempting to restrict sustainable, energy efficient, on site waste treatment instead of “promulgating” those systems as required and directed by federal law.

To level the playing field for on site sustainable systems the discharge requirements would in the least be adjudicated as identical to meet the wording federal law. The homeowner’s standards are more punitive than substantive. They are not relational to facts, measurement and federal requirements. Zero discharge is a punitive, undemocratic order, based on discriminatory perceptions like the ones expressed in the Administrative Civil Liability Complaint No. R3-2005-0137 CLOSING ARGUMENTS – DECISION THURSDAY, JANUARY 5, 2006, Pg. 430 lines 18,19,20 where Mr. Young Stated: “It's quite clear to me that the folks of Los Osos, in my opinion, are really not capable of addressing these issues with their wastewater disposal in a rational way.”

This assumption led to the two different standards being imposed. There is no factual basis behind the two different standards and having a more punitive standard for individual homeowners violates homeowner’s rights to freedom of economic choice towards sustainability and use of personal property. Such is my first reserved complaint.

They make waste separating toilets.

10:00 PM, March 29, 2006  
Blogger Steve Paige said...

Here's the PDF of the waste discharge order the individual on site treatment should be equivlent to:

10:14 PM, March 29, 2006  
Blogger Steve Paige said...

This comment has been removed by a blog administrator.

10:48 PM, March 29, 2006  
Blogger Spectator said...

Steve Paige:

I know that I can put in a $55,000 unit that would clean all nitrites and then resulting nitrates from the wastewater of a fimily of 6, and would produce potable water that could be reused over and over again. I can make that water like mountain spring water. There would be brine produced, the water content solar evaporated and returned to the system, leaving me with salts. Some are regarded by the government as explosives, although they are only oxidants.

Now I ask: How will this save my fanny from the Water Board who wants a regional solution? I will use no water from any water district, so If they attach sewer fees to water bills, I will turn my water off, and turn landscaping into rock and cactus. Will I be contributing to the "greater good"?

They do not look kindly to this:

I should be exempt from any assessment, and my actions will make any centralized solution more expensive for others. It will also be more expensive for me. At the same time I can replace my roof with thin film solar roofing pannels, load the garage with lead acid bombs, being very careful with venting of hydrogen, and even use an electrical vehicle, charged by my solar power, since PG&E declines to pay me for over production beyond my own use (failure of the law).

What would happen to your business, if PG&E was required to pay for excess solar electrical power returned to the grid at 1/2 the difference between retail and wholesale? And we could get rid of the lead acid bombs. I have 8000 sq. feet of roof (multiple locations).

Government is the problem, education is the answer.

It has nothing to do with a university degree. I have a MBA. I also have a CRS (Can't Remember Shit). My most valuable degree is the CRS. Facts (previously beliefs) and technology change so rapidly, that it is best to forget what you remember, what you were taught, and relearn constantly.

2:56 PM, March 31, 2006  
Blogger Mike Green said...

Spectator said:" Now I ask: How will this save my fanny from the Water Board who wants a regional solution?"

If the Water Gods wanted a regional solution why are they sending the individual CDO's?

I'm failing to see the logic here, if it's (as they say) to improve the water quality in the upper aquifer immediatly, then the onsite system is clearly better than pumping every two months.

For that matter, a working septic management district also is better.

If the overriding concern here is to build a WWTF in the shortest amount of time, then why fine and fight the people that have stated that that's exactly what they are trying to do?

you also said: "They do not look kindly to this"

Now that, I believe, says a lot,
We have affronted their EGOS.
Don't believe me? go ask Sam Blakeslee

No, they are demanding TriW.
and they are going to use every thing they think they can legaly do to insure their wishes.

After all, they are Gods aren't they?

5:11 PM, March 31, 2006  
Blogger Spectator said...


The only logic I can see from the CCRWQCB is that they warned us many times of consequences. Our elected officials (Fab5) said they had no teeth, and spat in the board's faces by stopping a permitted system cold, beyond all logic. The results of LOCSD logic is now apparent: suits, suits, and more suits, fines and possible pumping. (nobody has been pumped yet)

I agree with you completely, except that I do not see the CCRWQCB as "gods". I see them as judges trying to enforce polution laws on a bunch of very unreasonable people. I do not agree with their methods, but ain't it amazing how the property owners have awakend. There are better than 3000 petitions to dissolve the LOCSD.

If the people in charge of our LOCSD wanted a WWTF in the shortest amount of time, they would dissolve themselves and let the county build at TRI-W. All the plans exist, the permits are in place, environmental impact reports, coastal commission approval, etc.

However, "pie in the sky goes on". Sure the Fab5 "say" they wanna build a WWTF, but don't know where, don't know what, don't have a time span, don't have cost analysis, and don't have money.

They (CCRWQCB) do not look kindly to this "pie in the sky".

In the meantime, I look to judicial decisions. To me, county control and TRI-W is far better than hanging. By the way, has the committee of the doomed found a lawyer yet and been able to raise significant funds? I have heard nothing.

As for Sam Blakeslee, poor Sam, I do not need to ask him, he can speak for himself, and has not spoken publicly at all since his last letter to the Bay News. He will soon come to me, asking for a significant campaign contribution, and will be told that my political budget is spent defending my property in the "Sewer Wars".

Did you sign the petition to dissolve? I did! I still see no other way out of this mess. However, my mind is completely open, and yearning desparately, that one way or another we can get this behind us. But be assured, it will not come from "pie in the sky".

7:50 AM, April 01, 2006  
Blogger Shark Inlet said...

I'll agree with Spectacular Tater...

If the cop pulls you over for littering (ho-hos wrapper comes flying out the window) and gives you a warning then pulls you over again five miles down the road and gives you another warning (triscuit box), what should she do when, after another two miles you toss a big gulp cup out of the window?

If she were to do anything other than write you a citation, she would not be doing her job. She provided information about the consequences of breaking the law two times and grace two times. If you foolishly believed that she would not follow through because of her past grace *you* are the fool.

Similarly, those on the current board and those who voted for them ... if they thought that there would be no CDOs and no fines and if they thought that they would be able to move the location of the WWTF and still keep the SRF ... they were mistaken and basing their decisions on something other than what the RWQCB and SWRCB had told them.

11:25 AM, April 02, 2006  
Anonymous PublicWorks said...


Jail is what Los Osos is in, because it and it's residents are in violation of legal ruling.

Jail is what the RWQCB is in, because in spite of any possible inkling to cut Los Osos any slack, they fear, as does the next level up in Sac., something even worse in legal circles called 'precedent'.

Ironically, while many in LO point to Morro Bay as an example of why they should get more time, the water board probably fears giving LO more time so as not to give Morro Bay and others a bad example of what happens when enforcement is delayed.

Jail is what the County hopes to avoid, because no one wants to even speak about Los Osos for fear of litigation and somehow they are secretly hoping the CSD continues so that they don't receive another turn with enforcement directed at them.

Unfortunately, there are no get out of jail free cards for anyone in Los Osos.

6:16 PM, April 02, 2006  
Blogger Shark Inlet said...

So, getting back to the original topic, urine would need to be separated from other things.

How would this be done?


9:43 PM, April 03, 2006  
Blogger Mike Green said...

Spectator, No I did not sign the petiton to dissolve, I have laid out my reasons before, just like Sam Blakeslee has stated publicly why the negotiations failed, either directly to me on public radio (The Dave Congalton Show), or through his representative at the meeting of the doomed, which I reported on
It is my opinion that a lot of their decisions may have more to do with personal beliefs than evidence, and possibly an institutional, shall we say, fossilization?

10:48 PM, April 04, 2006  
Blogger Spectator said...


Fossilization? You betcha! Our legal system is a system of common law where previous rulings and precidents rule! If our system was based upon civil law (Napolionic Code) perhaps we would not have to deal with "fossilization" because the clear intent of the origional law would be interpreted.

Personal beliefs? You betcha: The "greater good" will be forced upon you and your individual rights don't matter when compared to the "greater good".

I am anxious to see if they accept any part of your plan for individual responsibility. Good luck!

Thanks for your excellent work.

12:59 PM, April 08, 2006  

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