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• <br />Mr. Steve Worrall <br />January 13, 2012 <br />Page 3 <br />A. Age and Replacement Parts. <br />• <br />According to the attached supplement report from Mr. Bonneau Dickson, P.E. <br />(Exhibit 1), a consulting sanitary engineer with over 30 years experience, the only part of <br />the lift station constructed in the 1960s that is still in service is the wet well — essentially <br />a large manhole. Mr. Dickson's review indicates that not a single piece of mechanical or <br />electrical equipment from the 1960s, is still in use. The 1989 upgrade included all new <br />mechanical and electrical equipment. (Dickson Report, Exhibits A & B.) <br />Moreover, the RDEIR fails to disclose that the two pumps were entirely rebuilt in <br />2007. (Dickson Report at p. 2, Exhibit C.) This renders the RDEIR assertion with <br />respect to design life and difficulty in securing replacement parts even more false and <br />misleading. According to Mr. Dickson, the rebuilding of the pumps in 2007 should <br />extend their effective life to 2025. Moreover, the wet well should have an effective life <br />of at least 100 years. <br />With respect to the cost and availability of replacement parts, Mr. Dickson <br />contacted a representative of Gorman Rupp, the manufacturer of the pumps. According <br />to an email from the representative to Mr. Dickson, attached to his report as Exhibit D: <br />"The T10A3 -B pump that is in use at the existing pump <br />station is still manufactured. Parts for it are readily available. <br />A new pump would cost around $11,000. A new rotating <br />assembly for the pump would cost around $5,000. The pump <br />is extremely rugged and many units are still in service after <br />30 years." <br />This leaves the claims of an end of the lift station's useful life and difficulty in <br />obtaining replacement place false at best, outright fallacious at worst, and eliminates the <br />stated justification for the Project. <br />B. Maintenance Issues. <br />The RDEIR asserts that the exiting lift station is prone to frequent maintenance in <br />order to clear blockage. Mr. Dickson's review of maintenance logs, however, shows the <br />following maintenance calls by year: <br />project description is the sine qua non of an informative and legally sufficient EIR." <br />County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185, 192 -193. <br />55A -136 <br />