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AGENDA REPORT
1 4
DATE: August 27, 2001 1•
TO: Honorable Mayor and City Council
FROM: John B. Bahorski, City Managet�y%
SUBJECT: THE OCEAN OUTFALL FOR WASTEWATER - ISSUES
AND DISCUSSION
SUMMARY OF REOUEST:
At the August 13, 2001 City Council meeting staff was directed to prepare a resolution opposing
the extension of the Section 301(h) waiver by Orange County Sanitation District (OCSD). Staff
has prepared a staff report, invited representatives from OCSD to make a presentation on this
issue and prepared a resolution as requested by City Council
BACKGROUND:
Staff has prepared this background information to aid City Council in their deliberations. This
information was developed from a report prepared by the City of Newport Beach and OCSD will
provide additional information during their presentation. Representatives from OCSD will
provide a brief presentation to City Council on the 301 (h) waiver and other ocean outfall issues.
All of north and central Orange County's wastewater — or sewage — is received and processed by
the Orange County Sanitation District (OCSD), a single - purpose special district formed in 1921
as the Joint Outfall Sewer (JOS) agency. The 1920s saw sewage treatment and disposal start at a
treatment plant in Fountain Valley and end at a 24" cast -iron surfzone outfall at the Santa Ana
'River mouth releasing "screened wastewater" into the ocean.
Both the JOS/District and the Outfall changed in scope over the years. The JOS became an
alliance of sanitation districts (called the County Sanitation Districts of Orange County or
CSDOC) in 1948. The late 40's and 50's saw new treatment facilities in Fountain Valley and
Huntington Beach and a new 7,200' long, 78" diameter ocean outfall off of Huntington Beach
that terminated at an ocean depth of 60'.
Today, the now- consolidated OCSD serves about 2.35 million people across 24 cities and 470
square miles in north and central Orange County, including the residents and businesses of Seal
Beach. OCSD's 650 -mile wastewater collection system takes in about 241 million gallons per
day of wastewater. OCSD produces about 533 wet tons of wastewater biosolids each day and
sends another 236 million gallons per day of effluent out a 5.1 -mile ocean outfall C'Outfall ").
Agenda Item .S
Every POTW applying for an NPDES Permit with a Section 301(h) waiver must meet the criteria
within the Clean Water Act, including:
o Existence of and compliance with water quality standards set by the State.
o Protection and propagation of a balanced indigenous population of fish, shellfish, and
wildlife (that is, a naturally occurring and diverse community of marine animals).
• Allowance of recreational activities.
• Establishment of a monitoring program.
• Satisfactory toxics control programs, including an approved industrial waste pretreatment
program.
• No additional treatment requirements for other sources as a result of the waiver.
• No increase in effluent volume or amount of pollutants discharged above limits in 301(h)
modified permit.
• Protection of public water supplies.
OCSD first received a permit (Order 84-1, Permit #CA0110604) with a Section 301(h) waiver in
1985. US EPA and the California Regional Water Quality Control Board, Santa Ana Region,
issued the Permit. Because NPDES permits typically are in effect for five years, OCSD's first
permit expired in February 1990. OCSD reapplied for — and received after a regulatory delay — a
renewed 5 -year Permit from US EPA and the Regional Board using Section 301(h)'s waiver
provisions. The term of the current (2"d) Permit (Order 98 -5, same permit number) is June 8,
1998 -- June 7, 2003.
The Permit sets limits on pounds of microscopic solids, biological oxygen demand (BOD) and
concentrations of other chemicals and parameters of concern. It also allows OCSD to discharge
a mix of 50% primary treated wastewater and 50% secondary treated wastewater out the ocean
outfall. As noted, about 245 million gallons per day of this 50 -50 mix goes out the 5.1 -mile
Outfall (with diffusers at about 4.5 miles out at about 185 -200' depth). While the permit does
allow for a variance for suspended solids and BOD, OCSD must meet the same standards as all
other California dischargers for industrial toxicants and other pollutants of concern.
OCSD must reapply for another 5 -year renewal of the Permit in December 2002. Prior to the
December deadline, OCSD staff tells us that the OCSD Board of Directors will evaluate their
options for discharge and determine what level of treatment the district will use in the future.
Workshops and hearings are scheduled during 2002 to receive commentary. The term of this 3`d
Permit would be June 2003 through June 2008.
OCSD believes that a 31d Permit using the waiver is appropriate for the following reasons:
o OCSD's 20 years of monitoring has not shown an adverse public health impact of the
current Outfall use. Ongoing testing (with UCI) off of Huntington Beach will test a
hypothesis that bacteria from the Outfall may reach the shoreline — if so, OCSD has said
(presentation on July 14, 2001):
If testing indicates that (additional pathogen reduction) is necessary, we will apply
additional treatment technology, such as:
o Secondary treatment + disinfection
OCSD, like many sanitation agencies, has facilities to treat wastewater using the following
process:
o Preliminary Treatment & Odor Control. To control odor, OCSD adds sodium hydroxide
within trunklines before wastewater reaches the treatment plant. Once at the plant,
OCSD adds hydrogen peroxide for odors. The wastewater then flows through bar screens
to catch large solids and grit chambers to pull out small gritty things like coffee grounds
and sand.
o Primary Treatment. In this phase, settable solids fall from the wastewater in large
clarifiers. OCSD adds ferric chloride and an anionic polymer here to "clump" small
solids. Finally, the District skims oil and grease from the surface of each clarifier. About
70% of solids settle out here — these solids are later used for fertilizer after additional
treatment.
o Secondary Treatment. Bacteria that consume organic wastes attack wastewater from the
primary treatment phase. The bacteria are assisted by OCSD's "trickling filter" which
sprays the wastewater over rocks and "activated sludge" which exposes the wastewater to
a variety of aerobic microorganisms. Secondary treatment with activated sludge removes
about 95% of viral pathogens.
Some sewering agencies that produce reclaimed water (like the Irvine Ranch Water District) use
a fourth step — Tertiary Treatment — to "polish" the wastewater further. Tertiary treatment may
include sending the wastewater through sand or charcoal filters, reed beds, or grass plots.
Disinfection using ultra- violet light can also be used at this stage of the treatment process.
The federal Clean Water Act (1972) required publicly -owned treatment works (POTWs) to
achieve full secondary treatment capability by July 1977. At the time, some agencies argued that
full secondary treatment might be unnecessary since some POTWs discharge wastewater into
deep waters with large tides and substantial currents. In response, Congress added Section
301(h) to the Act — this section allows for the United States Environmental Protection Agency
(US EPA) to, upon request of a POTW, and with the concurrence of the State Regional Water
Quality Control Board conduct a case -by -case review of treatment requirements and, potentially,
waive the Act's secondary treatment requirement via the issuance of a permit under the National
Pollutant Discharge Elimination System (NPDES). Only biochemical oxygen demand and
suspended solids can receive a variance. All other applicable receiving water standards set by
the State must be met.
Section 301(h) has been amended several times since 1977, but it still allows wastewater treated
at a level less than full secondary to be discharged into deep ocean environments. In 1990, about
60 sanitation agencies (out of about 15,000 agencies) held permits with waivers — today, about
36 such permits remain.
According to US EPA, the majority of Section 301(h) waiver recipients are small POTWs that
discharge less than 5 million gallons per day (MGD), although the flows from these small
POTWs represent only 4% of the 620 MGD of wastewater under the Section 301(h) program.
Recall that OCSD's discharge is approximately 245 MGD of the 620 MGD authorized under the
waiver program nationwide, making OCSD the largest agency in the nation using the Section
301(h) waiver.
• Filtration+ disinfection; or
• Microfiltration
o OCSD's monitoring programs have not shown an adverse environmental impact of the
current Outfall use. OCSD says that "liver pathologies are seen in some fish, but are
decreasing," that "since early 1990s, effects relating to the Outfall have not been seen,"
and that no State consumption advisories associated with the Outfall exist today.
o In order to appropriately reflect OCSD's 1999 Strategic Plan that directs OCSD to meet
changing population and economic conditions, meet regulatory requirements, minimize
operational costs, use existing facilities efficiently, and to distribute costs fairly, OCSD
says that any treatment alternative used for the Outfall must:
• Be technically feasible
• Meet regulatory requirements
• Protect public health and environment
• Meet city and local agency requirements
• Provide reliable service
Treatment Alternatives:
Altemative #1.
OCSD could apply for a 3rd Permit using the Section 301(h) waiver and the same discharge (50-
50 mix) of primary and secondary treated wastewater out the Outfall — but only if the summer
2001 tests off of Huntington Beach disprove the theory that the Outfall contributes to surfzone
and nearshore water quality problems. Alternative #1 is the least expensive of the alternatives
under consideration by OCSD.
Alternative #2.
Filtration of Primary + Disinfection of all Discharge Effluent This alternative treats the
wastewater by putting the Primary effluent through a filter then both the post -filter Primary and
the 50% Secondary are disinfected using UV light. The cost of treatment under alternative #2 is
about $100 MN more expensive than Alternative #1, Alternative #2 is both less expensive than
going to full secondary and may actually be one of the two most effective alternatives for killing
or removing pathogens.
Alternative #3.
rvncrona ng me :)u-/o rnmary netore mixin g it with the 50% Second . This treatment
method processes wastewater by sending the Primary effluent through the pores of a synthetic
membrane small enough to catch most, if not all, bacteria particles and many viruses. This
method may achieve near secondary treatment level. This is the second most costly alternative of
the five currently being considered. This method may achieve near
complete removal of pathogens on the Primary half while costing slightly less than Alternative
#2.
Alternative #4.
Full Secondary Treatment of all effluent. This method would treat all Outfall material to a
secondary treatment level. This is the second most costly alternative of the five currently being
considered.
Alternative #5.
Full Secondary + Disinfection of all effluent. This method would treat all Outfall material to a
secondary treatment level, then would disinfect the post - secondary effluent using W light. Of
the five alternatives, this is the most costly, but it assures near - complete removal of pathogens.
As noted, these alternatives are summarized — with appropriate footnoting that notes estimations
in both cost and effectiveness — on the next page.
Impacts to Other Environmental Media and Energy Impacts
OCSD has said that it looks at air quality, land disposal issues and energy demands as well as
water quality considerations. OCSD is preparing quantitative descriptions of these other non-
water impacts which will be part of the considerations its board of directors will use during its
2002 deliberations.
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RECOMMENDATION:
City Council may wish to consider the following options:
1. Adopt the resolution as proposed. This would oppose the extension of the 301 (h) waiver.
2. Modify the resolution to oppose the waiver unless OCSD agrees to implement Alternative 2
or 3.
3. Do not adopt the resolution opposing the 301 (h) waiver and wait for further information
from OCSD or direct the Council liaison to OCSD to monitor the situation and provide
regular reports to Council before committing to a course of action.
ATTACHMENT:
A. Resolution number _ relating to the discharge of wastewater into the Pacific Ocean
Orange County
Sanitation District
Seal Beach Council
August 27, 20111
ge County Sanitation
ict (OCSD)
• Operates and maintains:
♦ 2 regional treatment plants
♦ 650 miles of trunk sewers
♦ 22 pumping stations
• Treats approx. 240 million gallons per day
of wastewater
+tewater Treatment
eOORCECONMOL + TREATMENT + OWFALL
50i6
Y
Mine ewml
290 mAllmggMwW
perky lMGDi y.tO NGO a pap,,
bpL11° • Dem.
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stewater Treatment
12a "OiameterOWall
5 Mlles Long m.pon
200 Feet Deep par
a1 Mlle Long
laff- rxim Me pinta
are Regulated through
"VWmits Issued by:
• U.S. Environmental Protection Agency,
Region 9 (San Francisco)
• Regional Water Quality Control Board
(Santa Ana Region)
• South Coast Air Quality Management
District
Our Current Ocean
charge Permit?
♦ Our facilities impact water, air, land and
energy resources
♦ CWA Section 301(h) allows OCSD to:
• operate more ess rfly
• txlanceenvimnmentxlimpaals
♦ 15 years of ocean monitoring shows
continued protection of the ocean
environment and recreation
Ocean Discharge Permit
• Relaxes our limit for Biochemical
Oxygen Demand (BOD)
• Relaxes our limit for suspended solids
♦ Requires a strict industrial source
control program
♦ Sets strict toxicant limits on our
discharge
O yr Ocean Discharge Permit o
• Requires all ocean water quality
standards are met
• Requires a naturally occurring aquatic
community
♦ Requires we protect public health
at We Check for:
♦ More than 100 chemicals monitored and
thousands of samples taken annually
♦ Beach stations for bacteria
♦ Ocean sediment for chemicals
♦ Ocean water quality for chemicals
♦ Fish tissue for chemicals
♦ Characteristics of animal communities
*an Environmental Concerns
• Is it safe to swim?
• Is it safe to eat the fish?
• Are the fish healthy?
• Is the ecosystem being protected?
About Huntington Beach?
♦ 3,000 feet of shoreline frequently
experiences elevated bacterial levels
♦ 1999 urban runoff diversions cut bacteria
in half
• Testing UCI hypothesis this summer
• Preliminary results are in
• Checking land -based sources
an Discharge Permit
ewalSchedule
♦ 1984 - First Clean Water Act permit
♦ 1998 - Second Clean Water Act permit
♦ Dec 2002 - Permit application due
♦ June 2003 - Current permit expires
*l6 Months: Studies,
lic Workshops, Hearing
• Public input at workshops and hearing
• Formal public commentary period
• Ocean research reports
• Treatment technology reports
• Costs and financing reports
• 28- member OCSD Board November,
2002 decision
re Do We Go From Here?
• July '01 — Introductory 1" Public Workshop
— Begin additional research
• Oct'01 — Complete Huntington Beach
field wor,
• Nov'01 — 2- Public Workshop
IF
re Do We Go From Here?
• March'02 — Draft Huntington Beach report
— Draft treatment studies report
— 3- Public Workshop
• May '02 — Final reports to Board
• June'02 — 4- Public Workshop
— Adopt an'A" & "B' budget
re Do We Go From Here?
• Aug'02
— Draft permit application
— 45-day public comment
• Sept '02
— Board receives public comments
• Oct'02
— Board responds to comments
• Nov'02
— Board approves
permit
application
• Dec '02
— Submit permit application
t We Need from You
• Remain engaged in this dialogue
• Review and comment on the marine
science as it is completed
• Invite us back to study sessions during
2002 as our work is completed
• Wait for now
C
August 29, 2001
Mr. Blake Anderson,
General Manager
Orange County Sanitation District
P. O. Box 8127
Fountain Valley, California 92708
Dear Mr. Anderson,
Forwarded for your information is a certified copy of
Resolution Number 4926 entitled "A RESOLUTION OF THE CITY
COUNCIL OF THE CITY OF SEAL BEACH RELATING TO THE DISCHARGE
OF WASTEWATER INTO THE PACIFIC OCEAN." As you are aware,
the Seal Beach City Council adopted Resolution Number 4926
at their regular meeting of August 27`", 2001.
Very truly yours,
Joanne M. Yeo, City Clerk
City of Seal Beach
Encl.
cc: Santa Ana Regional Water Quality Board
Environmental Protection Agency,
San Francisco