Sullivan brief

ON SITE NITROGEN SEQUESTERING INSTALLED AND FINALED

Questions and answers about the final installation:

What have you done on your property to reduce nitrogen from going into the groundwater?

My name is Steven Paige, I own a home on a 25 by 125 foot lot in the prohibition zone. I submitted plans for to reduce nitrogen emissions by 60 to 80 percent from my septic outfall with the County on May 11, 2006 after receiving approval from Harvey Packard. The project was completed and received final inspection by the County on October 23, 2006 and is now in operation.

How does your system work?

My system is very simple. I have two toilets side by side. One is a bidet used for urine only. The other is a toilet used for solids. The urine only bidet faucet is spring loaded and washes the dry bidet bowl with about 1/3 cup per washout. All the urine goes into a parallel holding tank that is pumped and removed from the water basin once or twice a year. One truck can haul a years supply from twenty to fifty households.

How do you verify how much nitrogen is removed?

A C-42 licensed hauler fills a test container and the container is sent to a testing lab and tested for total nitrogen. That small amount is multiplied by the volume removed from the holding tank. The sequestered nitrogen content is subtracted from the assumed EPA output from a normal two person household giving you the percent reduction in contamination.

What does it cost to operate the system?

The total output with flushing water is about 200 gallons a year for two people and the estimated cost for hauling is about $150.00 per year. The system cost less than $1500.00 to install. I also save on my water bill by about 1/5 because of my reduced flushing volume from the bidet. The small square tank in the picture holds access to the Liquid waste tank.

What if you sell your house?

I have a deed restriction for waste nitrogen sequestering recorded with the County that would show up on the title report. Attached to it is exhibit one, a "Nitrogen Sequestering Homeowner's Manual" that would also show up in the title report.

How well is the system expected to work?

Using accepted EPA data, Standardized Medical data on nitrogen in urine and empirical mathematics it can be determined that sequestering is equal to or better than the Nitrogen reduction assumed and permitted for the TRI-W sewer project of 7 ml/l remaining in the balance of septic waste.

How did you come up with the idea?

It is a well researched idea originating in Sweden. Swedish studies are geared toward using human liquid waste after deodorizing and disinfection as commercial nitrogen fertilizer because making standard Nitrogen fertilizer is very energy intensive. Eighty percent of the cost for Nitrogen fertilizer is related to the cost of Natural Gas used to make it. The Swedish see urine as a desirable future resource much like any other recyclable.

How would you apply your situation to the CDO process?

I would allow Urine sequestering to be used as a carrot to avoid the CDO process. I would use the once or twice a year pumping tickets and Lab results as verification. I myself asked for a waiver when I submitted my plans for review 5 months ago. I will push soon for another option.

Would you expect this to affect the zero discharge enforcement on your property?

Yes I believe it will. If you encourage people like myself that want to meet much higher standards for their on site waste disposal you get immediate positive temporary remediation of the Nitrogen problem. I would encourage this with a proportional discharge order instead of a zero discharge order for small lots compared to one acre parcels that are approved to discharge as per the basin plan.

A Proportional discharge order would mean that a 50 by 100 foot lot would be allowed 16% to 25% of the pollutant discharge for an acre. As a member of LOCAC land use committee I have seen contemporary one acre approvals include houses with many homes approved on one acre. With one acre as the standard, smaller lots should be allowed a proportional discharge.

An additional settlement agreement for proportional discharge and Urine sequestering would encourage water conservation. People not wanting to jeopardize the value of their property would install a system like mine that any plumber could install. To meet the requirements of the settlement they would have to practice careful water conservation and sequester, pump, and haul urine outside the basin. The agreement would have them hook up to the sewer when available but still be allowed to sequester and discharge if problems arose with the time line construction.

The water board would benefit by having the nitrogen removed immediately. They also would optimize air pollution compared to pumping whole tanks. Sequestering would reduce conformance air pollution by 95% thus avoiding "parallel standards" challanges for CEQA exemptions in air quality aginst the RWQCB. Sequestering/conservation would eliminate Prop 218 benefit challenges that on site secondary treatment may raise if allowed. The solution is a front end solution that would go away when the sewer is hooked up to the house.

Intensive water conservation of this order would require:

• Micro flush 1/3 cup urine flushing in the bidet or European dual flush toilets.
• Second generation HE washing machines.
• Zeroscape landscaping.
• Ultra low flow shower heads.
• Ultra efficent dishwashers.
• Removal of garbage disposals for another 15% Nitrogen reductions (85% total).
• Careful use of water.

With a proportional discharge order from the RWQCB you not only encourage a more usable and efficient sewer system within Prop 218 law but you also jump start smart growth temporary solutions that are married to the future solution of basin groundwater overdraft. Behavior modification is the most efficent method of compliance in the short term.

APPROVED

Liquid human waste sequestering has been approved.

A special thanks to the following people:

APPROVED- Harvey Packard-RWQCB

APPROVED- BarryTolle-County Building and Planning

APPROVED-Laurie Salo-County Public Health

Permit is in hand.

Urine Separation Pumping Alternative- Letter to RWQCB- Design Plan for Property

Lori Okun and Philip G. Wyels
Senior Staff Counsel and Assistant Chief Counsel
State Water Resources Control Board
Office of Chief Counsel

RE: Steven Paige- Comments for April 28, 2006, Central Coast RWQCB Hearing

Dear Honorable Board Members and Council,
I have made a voluntary proposal to cut the Nitrogen emissions on my property by 58%. On March 23 I turned over to your office an alternative measure to septic pumping. The site plan and validation of the design are attached to this letter. It follows the logic of the approved order for segregation and transfer of Nitrogen laden waste from the septic tanks. Septic pumping by your estimation will reduce Total Nitrogen by 22%.
The solution I propose is a copy of a well studied Swedish solution to ‘smart pump’ source separate urine waste by behavior modification. You install a urine only toilet (Bidet) and isolated storage tank, then pump the segregated contents causing the following positive effects:

1) It prevents the unprecedented withdrawal from the water basin of 22 to36 Million Gallons a year caused by septic pumping if required Community wide.

2) It cuts Estuary Airshed NOx to Water Borne Nitrogen emissions from diesel truck effluvium hauling by 90% by reducing the hauled liquid volume.

3) Using EPA data, it reduces Total Nitrogen from the waste stream by 58% compared to 22% described in your pumping order.

4) It cost me 1/10 the amount of money per year for compliance.

5) With the additional removal of my garbage disposal, it would allow immediate improvement of waste discharge for Nitrogen in an order of magnitude that matches your approved waste discharge permit for the Broderson reclamation leachfields. The resultant Nitrogen release from the balance of my septic effluvium is approximately the same for my family as the amount allowed by your previous discharge permit but includes additional water conservation, not basin withdrawal.

My intension is to install the equipment so I can be given a section §13269 PCA Waiver by your office. I would expect a small processing fee to be appropriate based on my ability to pay. I think it would like you to consider an individual ‘Minor Violation Notice’ Section §13399 PCA because it is more fitting to the level of pollution. I’m not a major sewer plant or big industrial polluter. My methodology of Nitrate removal, because its environmental impact is less than yours, is my personal choice of compliance subject to § 13360 PCA:

“Manner of compliance

(a) No waste discharge requirement or other order of a regional board or the state board or decree of a court issued under this division shall specify the design, location, type of construction, or particular manner in which compliance may be had with that requirement, order, or decree, and the person so ordered shall be
permitted to comply with the order in any lawful manner.”

Myself and other residents with limited economic resources have reservations about the boards choice to issue a ‘zero’ discharge order after 2010 because one standard is allowed by the Los Osos Community Service District outlined in their discharge permit and another standard is imposed on homeowner’s to cease individual discharges after 2010.
If the LOCSD wastewater discharge permit meets federal standards that by law they had to, then the individual discharge standards of the People’s CDO’s exceeds federal standards and it’s cost to homeowners should be legally contested. The zero emission requirements are unnecessarily expensive and restrictive for homeowners.

Also, the dual standards clearly are inconsistent with Sec. 304 FEDERAL WATER POLLUTION CONTROL ACT encouraging sustainable, scaled, and economic water treatment. Simply put, the action eliminates altogether the use of sustainable, alternative, energy efficient, small scale waste treatment. Section ‘304’ encourages “promulgating” those systems as required and directed by Federal Law.

Further, With perceptions like the ones expressed in the Administrative Civil Liability Complaint No. R3-2005-0137 Pg. 430 lines 18,19,20 against the LOCSD where Chairman 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.”

It’s hard not to assume that prejudice against small scale compliance led to the two different rulings being imposed. The zero emissions requirement conflicts with federal law directing States to ‘promulgate’ alternative systems and consider them as secondary treatment.

In a broader sense for all Californian’s, the ‘Zero’ emissions order also seems to be in conflict with extensive Federal studies encouraging sustainable on site solutions, small scale cluster systems, or community wide systems that use energy and economics as a critical path.

EPA smart growth policies and objectives of minimizing infrastructure while increasing urban population density cannot be consistent with the zero emissions requirement. If Porter Cologne enforcement is to have positive public participation, flexible ‘smart growth’ enforcement that uses a menu of solutions would give the PCA more ‘contemporary’ environmental creditability and quicker results. It is the only way we are going to get ‘smart growth’ density in Los Osos and still meet CEQA regulations and watershed criteria. Public participation is the key. So assuming the public are a bunch of idiots is THE real tragedy. Like myself, they are the key to the solution.

I think we have all suffered from the ‘cognitive dissonance’ of the Los Osos sewer issue, myself included. Tensions and misconceptions of Board members have made the CDO orders for individual home owners way out of the ordinary. Again, I think Minor Violation Notice’ Section §13399 PCA is a more appropriate to the level of pollution on my property and gives you more flexibility to encourage things like water conservation or integrate on site impervious drainage recharge (roof runoff) as a ‘blending requirement’ for septic tank outfall. Many older homes in Los Osos do not have on site drainage reclamation. Using kinder more flexible enforcement would give you immediate results and raise environmental awareness. Punitive pumping measures that withdraw 36 Million gallons of water from the basin without a CEQA study could be replaced with MVN’s and smarter effluvium management like I have suggested.

My second concern would be that the studies of the water contamination of the Morro Bay Estuary seem faulted. When a major pollution source has been entirely omitted from the Basin Plan and Morro Bay National Monitoring Program there is no possibility of scientific validity. That source is the Morro Bay Power Plant and the interrelationship of Air Shed NOx emissions and TN found in Bay waters.

Federal Studies of similar watersheds found in the sited references below disclose the fact that an average of 25% of the Power Plant NOx emissions return to the waters of Morro Bay. The recent License for the Duke Power NOx emissions allows 260 tons of NOx per year. If Federal studies are correct ,then for the last 50 years 25% of over 260 tons/yr (conservative estimate) or 3250 tons of Nitrogen has been recaptured into the Bay Hydrologic cycle from the Morro Bay Power Plant without having been included in Watershed planning and measurements. Any premise drawn from a plan without this Nitrogen input is without scientific merit.

Here are some simple math calculations that exemplify my concern:

For houeshold Nitrogen production:
If we compute the grams per household per day:
280 gal/Household X 3.78 L/gal X .007 g/L =
7.4 grams per household / day of TN allowed in the Broderson discharge permit.

Looking at the unstudied Power Plant Pollution:
260 tons (conservative) X 2200 lbs X 1/5000 Households X 1/365 per day =
0.31 lbs/day/household
From the referenced air shed studies below 25 % of
Air NOx returns to the Estuary so:
.31 lbs. X 25%( Air NOx to Waterborne N ratio) X 448 grams/lb =
34 Grams Total Nitrogen/day/household for forty years!

The allowed Nitrogen per household per day is 7.4 grams in the TRI-W Permit seems incidental to the allowed unstudied Power plant NOx to waterborne Nitrogen of 34 grams per household per day from the Power Plant Emissions. If these figures are even partly right, how could the Cease and Desist Orders be related to sound science. The Morro Bay Power Plant has been operating for 40 years and easily could be a major contributor to ground water TN in the aquifer. Its contribution has never been included in the Basin Plan. To substantiate my claim at a later time if need be I incorporate by reference all the following documents:

Alliance for the Chesapeake Bay. 1997. Air Pollution and the Chesapeake Bay. WhitePaper of the Alliance for the Chesapeake Bay. 16 pp
Boubel, R.W., D. L. Fox, D.B. Turner, and A.C. Stern. 1994. Fundamentals of Air Pollution.Academic Press: San Diego, CA.
Ecological Society of America. 1999. Acid Deposition: the Ecological Response. Paper presented at "Acid Rain Revisited: a Congressional Briefing Co-Sponsored by the Ecological Society of America and the Hubbard Brook Research Foundation."
Mason, R.P., W.F. Fitzgerald, and F.M.M. Morel. 1994. The Biogeochemical Cycling of Elemental Mercury: anthropogenic Influences. Geochim. et Cosmochim. Acta 58(15): 3191-3198.
Mason, R.P., N.M. Lawson and K.A. Sullivan. 1997a. Atmospheric deposition to the Chesapeake Bay Watershed--Regional and Local Sources. Atmospheric Environment 31(21):3531-3540.
Paerl, H.W. 1993. Emerging Role of Atmospheric Nitrogen Deposition in Coastal Eutrophication: Biogeochemical and Trophic Perspectives. Canadian Journal of Fisheries and Aquatic Sciences, 50:2254-2269.
Perry, J. and E. Vanderklein. 1996. Water Quality: Management of a Natural Resource. Blackwell Science, Inc: Cambridge, MA.
Puckett, L.J. 1994. Nonpoint and point sources of nitrogen i major watersheds of the United States. USGS Water Investigations Report 94-4001. U.S. Geological survey, Reston, Virginia.
Schlesinger, W.H. 1997. Biogeochemistry: An Analysis of Global Change, Academic Press, San Diego, CA.
Seitzinger, S.P. and R.W. Sanders. 1999. Atmospheric inputs of dissolved organic nitrogen stimulate estuarine bacteria and phytoplankton. Limnology and Oceanography 44: 721-730.
Shannon, J.D., and E.C. Voldner. 1995. Modeling Atmospheric Concentrations of Mercury and Deposition to the Great Lakes. Atmospheric Environment 29(14):1649-1661
US Environmental Protection Agency, Office of Air Quality Planning and Standards. 1997. Deposition of air pollutants to the Great Waters: Second Report to Congress. USEPA: Washington, DC.
US Environmental Protection Agency. 1997. Mercury Study Report to Congress. 181 pp.Vitousek, P.M., J. Aber, R.W. Howarth, G.E. Likens, P.A. Matson, D.W. Schindler, W.H. Schlesinger, and G.D. Tillman. 1997. Human Alteration of the Global Nitrogen Cycle: Causes and Consequences. Issues in Ecology, Number 1, Spring 1997. Ecological Society of America, 15 pp.

In considering my idea, I would like to also raise another issue. I am a disabled individual as determined by Court decree. I have an independent doctor’s analysis that states my earning capacity is reduced by 50% due to my disability. It seems that multiple CDO’s with one hearing are discriminatory against me and others in a like situation and violate the Federal Fair Housing Act.

Block or random CDO’s add up to discriminatory zoning actions against people with disabilities by a public agency. The CDO’s are applied to a zoned population of people, the prohibition zone, with no individual hearings. Public accommodation is limited to one hearing for all parties or blocks of parties in the prohibition zone. One size fits all.

The Federal Fair Housing Act makes it unlawful to utilize land use policies or actions that treat groups of persons with disabilities less favorably than groups of non-disabled persons. Blanket hearings and fines are discriminatory to disabled persons in public assisted housing, on assistance, group homes and persons receiving public assisted elder care because they cause economic hardship, traveling expenses and public facility accommodation hardships without consideration by your office. All these hardships are occurring PRIOR to enforcement hearings. It would be horrible to have the order put disabled people out on the street as an unintended consequence. Don’t you agree?

What I feel would constitute a reasonable accommodation for me would be a case-by-case review of myself and all property owners to be able to identify the personal needs of the handicapped or assisted income homeowners . Each disabled person, like me, living in Los Osos, should be entitled to a individual hearing by your RWQCB board if you use economically crippling CDO’s.

In my case of limited earning capacity, I have figured the cost of making the improvements on my property related to my assessed valuation. They exceed 0.5% of my property evaluation and hence I am requesting any information you may have about financial assistance per Section § 13291.5. PCA. My initial expense will be about $1800.00.

I think by me redefining a better ‘smart pumping’ solution and you redefining a more appropriate order (MVN’s) towards myself and others, we could mutually encourage immediate improvements in Los Osos water quality while conserving water, educating the public, and preserving air quality.

Steve Paige, Los Osos Ca.

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
Installer:
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:

1) Federal Data from the EPA ONSITE WASTEWATER TREATMENT SYSTEMS MANUAL EPA/625/ROO/008

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 wastes¹• 75% 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 solids⁵• Hence 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:http://www.epa.gov/airtrends/nitrogen.html)
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.

CONCLUSION

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.
5) Federal Data from the EPA ONSITE WASTEWATER TREATMENT SYSTEMS MANUAL EPA/625/ROO/008
6) http://www.epa.gov/air/airtrends/aqtrnd99/fr_table.html
7) EPA 832-B-97-004 Financial Capability Assessment

Source Separation Beats pumping by 100% for Denitrification at 1/10 the Cost and Energy.

Could one answer be a new toilet that separates urine from wastewater streams? Here's an interm solution that could could become part of the finished design.

Separation reduces Nitrogen 55% from front end loading of your on site septic tank. If going to the bathroom in two different places would save you $2000.00 a year would you do it? It is energy smart to have you sepearate the two from the get go. Pilots studies are going on in Sweden, Mexico, U.K. and we need a solution fast! The water board has some justification in being frustrated. If we temporarily source seprate No. 1 and No. 2 till the sewer gets built then we have really improved the situation. Pumping alone was only going to remove 22%.

I did the bolding in the article so you could skim it if you're in a hurry.

Reprint Thanks To Enviormental Science and Tech. Mag.



Re-engineering the toilet for sustainable wastewater management.
May 1, 2001 / Volume 35 , Issue 9 / pp 192 A – 197 A.
TOVE A. LARSEN,
IRENE PETERS,
ALFREDO ALDER,
RIK EGGEN,
MAX MAURER,
AND JANE MUNCKE

"Municipal wastewater treatment needs rethinking. It is burdened with a pollutant load that it was never intended to manage."

Problems with the existing management system are manifold. The current system—waterborne transport and centralized treatment—consumes large amounts of fresh water. It discharges nutrients to water bodies, where they cause pollution and are lost for further use at a time when scarce raw materials are being depleted to produce synthetic mineral fertilizers. Concern is also growing about human excretion of micropollutants such as pharmaceuticals, synthetic and natural hormones, and their metabolites. Many of these substances (suspected to be largely excreted in urine) are not removed by biological wastewater treatment (1–3) and often are very potent, especially hormonally active agents, which have caused changes in the morphology and behavior of some species (4). Moreover, the spread of antibiotics to the environment could lead to increased resistance of microorganisms to these substances. Fortunately, a promising alternative to centralized wastewater management may soon be available that addresses many of these problems. It involves separation of urine from feces in a special “NoMix” toilet with in-house storage of the collected liquid followed by its subsequent transport and treatment (Figure 1). Such urine source separation is technologically easy to accomplish, and at pilot scale, the technology is already in place in several countries. At the Swiss Federal Institute for Environmental Science and Technology (EAWAG) in Dübendorf, the NOVAQUATIS project (www.novaquatis.eawag.ch) is exploring the engineering, microbiological, exotoxicological, economic, and social science aspects of this novel approach.

Source-separating urine provides a range of benefits. A urine-separating NoMix toilet saves 80% of the water used for toilet flushing, accounting for 30% of the average Western European’s direct daily water use and 10% of the total freshwater use in Switzerland. Because urine accounts for a large fraction of the wastewater nutrient load, this approach can also reduce emissions from fertilizer production and halt the contamination of agricultural soils by the heavy metals found in the raw materials used to produce synthetic fertilizers. It also reduces micropollutant discharges to water bodies.

Using existing collection and treatment infrastructure, urine source separation is well suited to aid the transition to decentralized wastewater management. For the approach to succeed, however, many stakeholders—consumers, public agencies, industry, and agriculture—must aid in the dissemination of NoMix technology.

Problem synthesis

Thousands of xenobiotic substances that have been brought into use in the past few decades are finding their way into municipal wastewater. Centralized treatment technology cannot deal with this new pollutant load and offers no incentive to polluters to seek better alternatives. Current urban water management practice contains strong elements of what economists call a natural monopoly, in which a single supplier can service the market at lower cost than two or more suppliers. This situation stifles innovation and locks in a technology that is inferior in many respects.

Therefore, municipal wastewater treatment systems should be moving toward source separation schemes, but it is not clear how to make this happen. What are the right technologies? How can they be implemented? Addressing the latter question may be the more challenging issue because of the current system’s built-in inertia—it is well established, long-lived, seems to adequately serve public needs, and has large amounts of capital invested in the present infrastructure, in which several complementary technologies work together to make the system function.

It may be feasible to unbundle wastewater management and introduce competition in treatment, for example, but it is hard to see how this can be done for transport. The sewer system is too extensive to sustain several independent providers. In fact, for most deregulated public utilities—power, rail transport, and water supply—network operation has remained a monopoly, and establishing competition in unbundled services has proven harder to accomplish than anticipated. Ultimately, household on-site technology would make today’s centralized wastewater collection and treatment infrastructure redundant. Important issues to be addressed include how the transition to a decentralized technology regime can be accomplished, what it would cost, and who is going to pay for it.

Why urine source separation?

Human excrements are the greatest source of nutrients in wastewater, and the major fraction of excreted nutrients is found in urine (Figure 2). Although the numbers can vary, urine typically contributes around 80% of the nitrogen, 50% of the phosphorus, and 90% of the potassium in the total nutrient load arriving at a treatment plant. This input can have a pronounced effect on the maximum daily load of ammonia with which the plant has to cope, and the urine peak early in the morning when most people get up is an important factor for planning plant capacity.

Absent urine, plant influent carbon and nitrogen levels would be almost balanced; that is, the plant’s bacteria feeding on the organic matter in the wastewater could absorb all the nitrogen content. Excess phosphorus remaining after biological treatment can easily be reduced. Production of inert sludge is thereby reduced, enabling savings in sludge handling and especially in ash disposal from sludge incineration, which is on the way to becoming the primary sludge disposal option, at least in Europe.

Urine is also the main culprit for the acute toxicity effect that occurs when there are combined sewer overflows. Most industrialized countries transport municipal wastewater and rainwater in the same (combined) sewers. During heavy rains, the total amount of sewage arriving at a treatment plant can exceed its capacity, and raw sewage, diluted by rainwater, is released directly into rivers and lakes. The discharge contains ammonia, a byproduct of urine decomposition, which is acutely toxic to fish.

Although a problem when released unintentionally to the environment, under other circumstances, urine provides definite benefits. Nitrogen, phosphorus, potassium, and sulfur are basic constituents of synthetic mineral fertilizers used in agriculture. Substituting urine components for these fertilizers eliminates environmental impacts associated with production and use of the latter and slows resource depletion (see box, "Advantages of nutrient recycling" (5)).

Other resource demand problems can also be avoided. For example, nitrogen is in plentiful supply in the atmosphere, but its industrial fixation is energy-intensive. As an alternative, urine provides a ready source of fixed nitrogen.

In summary, the economic and environmental advantages of adopting urine source separation are manifold: smaller, simpler treatment plants; lower nutrient emissions to rivers, lakes, and oceans; reduced sludge production; reduced use of flocculation chemicals, which saves money and reduces environmental impacts; natural resource conservation; lower fertilizer impacts; and greatly reduced toxic impacts of combined sewer overflows.

System mechanics

The NoMix toilet has one compartment for feces and one for urine. The urine flows through separate pipes to a storage tank that is emptied periodically. An alternative currently being explored is storing a day’s worth of urine within the toilet for later controlled release through the existing pipes in the building.

NoMix toilets already exist in Scandinavia, notably Sweden. There, a low-tech approach has been chosen for urine transport and treatment. Storage is decentralized and uses large tanks that are periodically emptied by local farmers who spread the urine directly on their fields (6).

The technology variant being researched at EAWAG is adapted to a municipal setting and relies on smaller, on-site storage tanks and use of the existing sewer network for transport to a treatment facility. Depending on the intended use, urine transport could occur at different times of the day. If urine is to be entirely removed from the wastewater stream for nutrient recycling, it could be released at night when the sewers are empty (Figure 2). This would require using storage tanks large enough to bridge a series of rainy nights. The Swiss urine-to-fertilizer strategy emphasizes processing of the urine solution. Sterilization, pH stabilization, removal of potentially harmful micropollutants, and the elimination of the characteristic odor are important treatment steps.

An alternative, low-cost approach for reducing the early-morning urine peak, involves temporarily separating urine using small storage tanks that are fully integrated into the toilet. The stored urine is released later during the day to ensure that a smooth, even load arrives at the treatment plant. Release could also be controlled to withhold urine when combined sewer overflows are likely to occur, thus reducing the adverse effects of raw sewage emissions to rivers and lakes. Modeling of this option shows that it could successfully compete with the more traditional approach of enlarging treatment plants and rainwater storage capacity (7). This strategy enables technological learning, especially in the area of real-time control, beginning with simple strategies like peak-shaving, followed by more advanced strategies for better response to rain events.

Stakeholders

Implementation of NoMix technology is not cost-free, even though it can use existing infrastructure. Investment is necessary at the household level, in particular, when the nutrient recycling option is pursued. NoMix toilets could be installed in the course of natural appliance turnover, but piping and storage are bigger items to consider, and additional treatment facilities would have to be built. To accomplish all this, multiple parties have to realize a stake in the new technology.

Although its marketability has not yet been tested, producers of sanitary appliances and equipment are already investing in NoMix technology (8, 9). The first generation of NoMix toilets was produced by small Scandinavian companies; the type shown in the photo at the top of this page and Figure 3 was produced by Roediger Vakuum + Haustechnik (www.roevac.de), a German manufacturer. Several Swiss firms have shown interest in a toilet with integrated storage.

Consumers who participate in pilot projects have responded favorably to the NoMix technology, despite some minor technical difficulties (10, 11). The technology saves them money by conserving water—flushing urine in the NoMix toilet requires 0.0–0.2 L, whereas a modern water-saving toilet uses 2–3 L for a small flush. On a daily basis, a family of four could save around 80 L of water. Given typical Swiss water prices, annual savings of $100 (USD) can be realized—double that amount, if the toilet to be replaced is not of the modern, water-saving kind. Household investment in NoMix technology could be amortized over 5–10 years.

Public authorities will have to act if urine separation technology is to grow more rapidly. Consumers can install NoMix toilets but still need the involvement of regulatory agencies and wastewater service providers. If existing sewers are used for transport, storage tank opening should be coordinated with treatment plant operations. Moreover, urine storage and treatment require new infrastructure, particularly if the nutrient-recycling option is pursued.

Public authorities should have an interest in pursuing NoMix technology, because it can significantly improve treatment plant effluent quality. Using NoMix technology to level the ammonia peaks produces the same effect as expanding treatment capacity, either reducing the ammonia and nitrite content of the effluent, or allowing for additional nitrogen elimination (12). In some countries, denitrification to reduce nitrogen in plant effluent has been mandated to prevent further ocean eutrophication. This expensive end-of-pipe measure would be redundant, and its effect easily surpassed, if urine were removed at the source.

The attraction of urine-based fertilizer for farmers is more tenuous, since they are not yet affected by shortcomings of the present system. Containment of heavy metals might be the most relevant issue for them. Organic farmers could find the urine-based fertilizer a welcome source of nutrients, since the organic certification requirements they have to meet often prohibit using synthetic mineral fertilizers (13). Any use of urine-based fertilizer on the farm should be preceded by an assessment of associated ecotoxicological risks; for example, microresidues in urine (pharmaceuticals and hormones) may have to be removed from the fertilizer product. Such a risk assessment is being carried out by the EAWAG NOVAQUATIS project.

For several years, the phosphate industry has been exploring alternative sources for raw phosphate, for example, phosphate reclamation from wastewater and chicken manure. Although the industry has not yet shown an interest in phosphates reclaimed from source-separated urine, it might soon begin to do so. The industry’s interest in alternative raw material sources is driven by increasing difficulties with disposing of hazardous wastes generated during phosphate rock refining.

Although EAWAG scientists and associated institutions do not have a direct commercial interest in the NoMix technology, they are stakeholders nevertheless, exploring alternatives to current materials policy. In the NOVAQUATIS project, engineers are developing treatment methods for separated urine solutions to make its constituent nutrients available for agriculture. Microbiologists and agricultural ecologists are studying the ecotoxicological risks that a urine-derived fertilizer could bring to soils and plants. Environmental scientists are assessing material flows associated with conventional and nutrient-separated waste management regimes. Economists and social scientists are exploring the acceptance of the technology, taking into account cost and consumer attitudes.

Next steps

Urine source separation is but one step toward a more comprehensive source separation strategy that makes it easier to treat and recycle wastewater stream components. Because individually they are more homogeneous, wastewater components can be better controlled if they have not been mixed.

Ecological engineering approaches that use ecosystems for engineering tasks and exploit their self-organizing capacity (14, 15) likewise benefit from, and increasingly rely on, source separation. For example, separation of urine and feces leaves “gray water” that can be more easily treated in constructed wetlands.

In the future, source separation may permit the use of completely decentralized wastewater treatment systems that avoid transport altogether. Already, the relative ease of accomplishing urine source separation in an existing, inert system permits implementation to occur, though gradually, and positive effects are being realized from the start.

To move toward really intelligent wastewater management, however, change has to be more radical. The principle of source separation could be extended to other household wastewater sources. The major water-using appliances in the household—toilet, washing machine, and dishwasher—are responsible for at least 85% of the organic pollutant load in residential wastewater. Equipping these appliances with a device for internal waste reclamation would be a logical way of reducing pollutant emissions from wastewater. Recent developments in membrane technology and other physical–chemical treatment methods hint that such solutions may be realistic in the not-too-distant future (16). Use of technologically sophisticated appliances such as these would leave households with small remaining amounts of wastewater that could be treated on-site to a quality comparable with rainwater. In this scenario, public responsibility for wastewater transport and treatment would be largely delegated to households, opening up a mass market for in-house water treatment technology that could provide greater rewards for innovation than the large-scale infrastructure of today. Such radical source separation could also alleviate the burden of dealing with contaminated biosolids, because with separated waste streams, the resulting separate fractions of biosolids would be of higher quality and could be directed toward their most suitable destination.

Taking source separation seriously, handling all wastewater components individually, and reducing the associated water use pose a real challenge. At some point, we may want to downsize the entire urban water infrastructure or do away with it altogether. This cannot happen overnight, but if we don’t start the journey now, we will never get there.

Advantages of nutrient recycling

Current fertilizer production and use consume limited resources and harm the environment. At current extraction rates, reserves of phosphate rock that are economically recoverable with today’s technology will last less than 100 years, and the reserve base will last less than 300 years (http://minerals.usgs.gov/minerals/pubs/commodity).

In addition to resource limits, phosphate rock has a high heavy metal content, giving rise to hazardous wastes when processed. The cadmium content of phosphate rock, for example, ranges from 0.1 to 850 mg cadmium per kilogram phosphorus. Because these impurities are not entirely removed from the final product, phosphate fertilizer application introduces heavy metals, such as cadmium, which is very toxic, into the soil. This problem will worsen if rock of lesser quality is used in the future as the resource is expended. There are also impacts associated with hauling raw materials long distances to where they are needed, as well as after their consumption, when nutrients are discharged into lakes, rivers, and oceans, where they cause pollution and are largely unavailable for use in agriculture.

Clearly, a closed nutrient cycle is desirable (7), and some nutrient recycling is already happening. For instance, in many places, sewage sludge is being spread on agricultural fields. The sludge acts as a fertilizer, but the practice primarily serves as a cheap disposal option. Given the increasing contamination of sewage sludge with pollutants from municipal wastewater, its application to fields is increasingly less viable (Environ. Sci. Technol. 2000, 34 (19), 430A–435A). Source separating urine could reopen this pathway for agricultural application of nutrients recovered from municipal wastewater treatment and avoid the current problem of effluents from treatment plants contributing significantly to nutrient pollution of water bodies.

References

1. Ternes, T. A. Water Res. 1998, 32 (11), 3245–3260.
2. Stumpf, M.; Ternes, T. A. Vom Wasser. 1996, 87, 251–261.
3. Pharmaceuticals and Personal Care Products in the Environment: Scientific and Regulatory Issues. Daughton, C. G., Jones-Lepp, T., Eds.; American Chemical Society: Washington, DC, 2001.
4. Ashfield, L. A.; Pottinger, T. G.; Sumpter, J. P. Environ. Toxicol. Chem. 1998, 17 (3), 679–685.
5. Beck, M. B.; Cummings, R. G. Habitat Intl. 1996, 20 (3), 405–420.
6. Höglund, C.; Stenström, T. A.; Jönsson, H.; Sundin, A. Water Sci. Technol. 1998, 38 (6), 17–25.
7. Larsen, T. A.; Rauch, W.; Gujer, W. Waste design paves the way for sustainable urban wastewater management, submitted to the UNESCO Symposium Frontiers in Urban Water Management: Deadlock or Hope?, Marseille, France, June 18–20, 2001.
8. Fussler, C. Driving Eco-Innovation; Pitman Publishing: London, 1996.
9. Moore, C.; Miller, A. Green Gold: Japan, Germany, the United States, and the Race for Environmental Technology; Beacon Press: Boston, 1995.
10. Burström, A.; Jönsson, H. Double Flushed Urine Separating Toilets—User Experiences and a Follow-Up of Problems; Report 229, ISSN 00283-0086; Swedish University of Agricultural Sciences, Department of Agricultural Engineering: Uppsala, Sweden, 1998.
11. Hanäus, J.; Hellström, D.; Johansson, E. Water Sci. Technol. 1997, 35 (9), 153–160.
12. Larsen, T. A.; Gujer, W. Water Sci. Technol. 1996, 34 (3–4), 87–94.
13. Haller, M. Düngeverhalten von Bio- und IP-Landwirten (Fertilizer Use by Farmers in Switzerland); Department of Environmental Sciences, Swiss Federal Institute of Technology: Zürich, 2000.
14. Ecological Engineering: An Introduction to Ecotechnology; Mitsch, W. J., Jorgensen, S. E., Eds.; Wiley and Sons: New York, 1989.
15. Ecological Engineering for Wastewater Treatment; Etnier, C., Guterstam, B., Eds.; Lewis Publishers: Boca Raton, FL, 1997.
16. Larsen, T. A.; Gujer, W. In Water Resources and Waste Management. Conference Preprint of the 1st World Congress of the International Water Association, July 3–7, 2000, Paris; 2000, 5, 293–300.

All authors are at the Swiss Federal Institute for Environmental Science and Technology (EAWAG), Dübendorf, Switzerland, and are part of the NOVAQUATIS management team. Tove A. Larsen (tove.larsen@eawag.ch) is an environmental engineer in the Urban Hydrology Division of EAWAG and leader of the entire NOVAQUATIS project; Irene Peters is an economist in the Systems Analysis, Integrated Assess ment, and Modelling Division and heads a project conducting a comprehensive evaluation of all aspects of the NoMix technology, Alfredo Alder is an analytical chemist in the Chemical Pollutants Division and coordinates a project analyzing the fate of various pharmaceuticals in urine; Rik Eggen is a molecular biologist heading the Environmental Microbiology and Molecular Ecotoxicology Division and coordinates the projects on the potential ecotoxicological effects of substances in urine; Max Maurer is a process engineer in the Environmental Engineering Division and coordinates the projects exploring methods to process the urine solution; and Jane Muncke, an environmental scientist, is working on the effects of conventional versus urine-based fertilizers and is also assistant to the project leader.

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