From: Tom Opishinski [mailto:iocean@cox.net] Sent: Monday, May 22, 2006 12:33 PM Subject: Placencia EIA Here is some information that I located regarding the BESST system that might be helpful. I only have time to skim the EIA so somebody may have already commented on this and I may have overlooked something by having read only portions of the EIA (aramacoeiafinal.pdf) however there appear to be some inconsistencies in the amount of generated waste water. From the Executive Summary under the Water and Wastewater section: Stated daily generation of wastewater is 290000 gallons (or 1097769 liters). From Chapter 6, section 6.1-Waste Water: It is stated that "Waste water is normally calculated as between 70-80% of the water demand. For the purpose of the proposed project the upper limit of 70% will be used." Comment - The upper limit is 80% so they are actually using the lower limit! This lowers the daily wastewater estimate to 859273 liters. At 80% the total wastewater is 945200 liters, still less than that listed in the executive summary. Some other comments on wastewater loading. From the manufacture's web site (see http://www.purestreaminc.com/purestreames.asp) they provide the following specifications. The Purestream ES, LLC BESST® (Biologically Engineered Single Sludge Treatment) process offers "State of the Art" Advanced Wastewater Treatment with effluents well below 10 mg/l BOD, 10 mg/l TSS, less than 1 mg/l ammonia, and less than 10 mg/l TKN. Phosphorous reduction below 3 mg/l is easily achieved through "Luxury Uptake". Higher Phosphorous removal rates can be achieved with the use of metal salts such as Ferric Sulfate. Package Plant sizes from 4,000 gpd up to 0.100 MGD can be run in parallel for flows up to 0.500 MGD. Also, from Table 6.5 in the EIA it shows that the system removes 97% of TSS, BOD and Ammonia however it only removes 80% of phosphates and 67% of organic nitrogen. Comment: Phosphates and nitrogen are the two major chemicals that cause degradation of coastal ecosystem by causing chemical imbalances and quite often algae blooms. The 80% and 67% removal rates for phosphates and nitrogen, respectively, are not very good and although the 97% removal rates appear impressive the total loading depends on the volume of wastewater. Using the "Lower" estimate of waste water volume calculated at 70% or 859273 liters per day and the concentration levels given in Table 6.5, the total daily loading for nitrogen and phosphates is: Nitrogen (5 mg/l concentration): 5mg/l x 859273 liters = 4296365 mg of nitrogen (4.296kg nitrogen) or almost 10 pounds per day. Phosphates (2mg/l concentration): 2mg/l x 859273 liters = 1718546 mg of phosphate (1.718kg phosphate ) or almost 4pounds per day. I don't believe the EIA waste water analysis accounts for the nitrogen and phosphates and other chemicals that will enter the lagoon and coastal waters as a result of fertilizers used on the golf courses and in the rest of the resort although the report may cover this elsewhere. Comment: Concentration levels or even the total mass of chemicals in the waste water are not very significant unless a study is conducted to determine the total loading and flushing rate (how long it takes for water in the lagoon to be exchanged with offshore ocean water) of the receiving waters (i.e., Plancencia Lagoon and coastal waters around the proposed resort) through an extensive hydrodynamic monitoring and modeling study. Such a study would also need to account for other sources of existing nutrient loading on the receiving waters such as shrimp and citrus farms. Although some of the wastewater will be used for watering the golf course and flushing toilets eventually a majority of the material makes it way through the ecosystem. Tom Opishinski Interactive Oceanographics 81 Shippee Road East Greenwich, RI 02818-1028 Tom Opishinksi is the consultant for the Smithsonian Institute who installed and manages the Smithsonian's environmental monitoring systems on Carrie Bow Cay. He also has trained MBRS staff in environmental monitoring equipment.