C&D Effluent Guidelines Rulemaking Telephone Documentation Record

TELEPHONE RECORD

 Outgoing Call	Project No.:

68-C-07-029, Work Assignment 0-02

Charge No.: 5000100.07012.002.06.100	Project Name: 

C&D Effluent Guidelines Rulemaking 

– Estimated Regulatory Costs

Contact Name: 

Joe Gannon (President)	Phone No.: 877-324-9634 cell:  661-979-2525
Organization Name: 

Clear Creek Systems, Inc.

4101 Union Ave

Bakersfield, CA 93305

Website:    HYPERLINK "http://www.clearcreeksystems.com/" 
http://www.clearcreeksystems.com/  

Date:

2/13/08

(includes a 5/8/08 update)	Time:

3:00 PM	Name: 

Samantha Lewis

U.S. EPA

Subject: Request for Information on Technologies to Meet Numeric
Standards



Introduction:  “Clear Creek Systems, Inc (CCS) provides water
treatment equipment rental, polymer treatment systems for storm water,
and oil/water separator rentals.  CCS designs, installs and monitors
treatment systems for storm water, groundwater and construction
dewatering needs.”  U.S. EPA contacted Mr. Joe Gannon with CCS and
asked the following questions:

Q1:  What information do you have on costs for applications treating
construction site runoff?  

A1:  Costs go down per unit as you get to bigger sites (e.g. ½ percent
of costs usually).  CCS has used the technology from 2 acres to 1,500
acres.  For the 1,500 acres projects, CCS utilized two treatment
sites--with water being pumped around from various collection locations.
 Additional information to be provided.

Q2:  What information do you have on performance of applications
treating construction site runoff?

A2:  Average effluent from treatment is usually less than 10 NTU.  Mr.
Gannon stated that “it's hard to meet a specific higher number (like
70 NTU).”  However, consistently meeting under 5 NTU all the time
would cost a little more due to extra treatment steps.  Additional
information to be provided.

Q3:  Do you have any toxicity data for the treatment chemicals you are
using?

A3:  Yes, for the toxicity of the material itself, and impact on the
receiving water.  CCS uses Chitosan (a natural derivative from crab and
clam shells)--but it can still be toxic.  Polyacrylamide (PAM) is not
non-toxic--everything is toxic at some level.  Mr. Gannon is looking for
a chemical he can use at non-toxic levels “just-in-case” of user
error.  He does not think the MSDS (not provided) will tell the whole
story on toxicity--performance data he is sending will show that there
is no carryover into the environment.

Q4:  How many systems/projects have you done nationwide?  

A4:  Mostly in CA, some in WA, and some in other places -- approximately
100 (1 acre to 1,500 acres).  

5/8/08 update: Joe Gannon left me a message on 5/8/08 (in response to a
message requesting additional details on the States that he has worked
in).  Mr. Gannon stated California ,Oregon, and Washington--and he
provided equipment to Florida, but wasn't running the actual project. 
He recommended talking to Jim Nye (spelling?) at Clear Water Compliance
to get a bigger list of States. A call by PG Environmental LLC to Clear
Water could not identify the above referenced Clear Water contact.

Miscellaneous Discussion: 

How a treatment system generally works:  Water from site is collected,
polymer is added as water is sent to a "seasonal tank (i.e. only on site
during the rainy season)", goes to a sand filter as more polymer is
added.  CCS also has a mobile system that works for smaller systems that
store their water (sand filter on back of a truck).

Clear Creek Systems, Inc. had previously pulled together costs on
treatment of construction wastewater for the Building Industry
Association (BIA)--from an historical perspective (which will probably
be the highest it will ever be, since he thinks costs will go down in
the future as people get better at this).  Independent BIA cost
estimates were much higher than Clear Creek estimates.   Joe will send
the cost estimates that he sent to the BIA.

Mr. Joe Gannon believes that it's really important to use the treatment
chemicals in a safe manner!  The State of CA asked
Halosource/StormKlear™, Clearwater Compliance Services, ProTech GCS,
and Clear Creek Systems (Active Treatment Systems (ATS) Working Group)
to come up with ways of ensuring safe and effective operation that
doesn't limit it to certain materials or ways of doing things.  This was
submitted to CA and was well-received.  Mr. Gannon will send us this
document.

The state of Florida can use Alum for construction wastewater treatment,
with only a 60 second retention time—Mr. Joe Gannon stated that “he
thinks this is not a safe way for treatment.”

