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CC AG PKT 2001-07-23 Supplemental Information - Surfrider Foundation, OCSD 301(h) Waiver
c r - mil Surfrider Foundation Huntington Beach/Seal Beach Chapter OCSD 301(h) WAIVER Backround Information and Comments July 2001 P.O. Box 878 Huntington Beach, CA. 92648 OCSD 301(h)WAIVER COMMENTS NPDES permit decision states"This decision and the permit implementing this decision are subject to revision on the basis of subsequently acquired information relating to the impacts of le!s•than-secondary discharge on the marine environment " Issued in 1997; Since then the following events have occurred Episodic and periodic beach closures in Huntington Beach. (1999) Frequent beach posted warnings in Huntington Beach A new and more sensitive bacterial indicator mandated by AB 411 and recommended by the EPA (Enterococcus) A new COP FFED and new compliance reporting standards. At least 3 scientific studies have been completed with no firm conclusions regarding the source of the bacteria causing these beach closures. A fourth and fifth are planned A new EPA rule has been approved by the Clinton administration to require new discharge standard for offshore (Federal waters)POTW plants. An expansion of the AES power plant is planned which may have a detrimental impact on the near shore pollution in Huntington Beach. Poseidon Corp. is planning a desalination plant with water from the AES plant which miry be taking water from the discharge plume of the OCSD outflow pipe It is not clear that this event is not in violation of the antidegradation policy of the CW E► Don Schulz Comments made to the CSOD Board of Directors on Nay 23 , 2001 References : NPDES permit issued 1997 1972 Clean Water Act (EPA) AB 411 California Ocean Plan (COP) FFED 2000 Ocean Water Discharge Plan (Federal Waters) (EPA) Huntington Beach Closure Investigations 1 , 11 , an3 111 . CWA Antidegradation Policy—California . r��%��'°" ���, COUNTY SANITATION DISTRICTS JI° o a O V OF ORANGE COUNTY, CALIFORNIA P.O. BOX 8127, FOUNTAIN VALLEY, CALIFORNIA 92728-8127 0 '" "'' t+ 10844 ELLIS, FOUNTAIN VALLEY, CALIFORNIA 92708-7018 glkCE coUN (714) 962-2411 April 13, 1989 To: Interested Individuals, Organizations and Agencies Subject: Future Wastewater Management Programs For the past two years, the County Sanitation Districts of Orange County have been engaged in a long-range wastewater planning study, "Action Plan for Balanced Environmental Management, " to assemble the information necessary to make a policy decision regarding the appropriate level of treatment to apply to the wastewater we discharge to the ocean during our next five-year permit period and to guide the Sanitation Districts' delivery of comprehensive wastewater management services to the year 2020. Because of your direct interest in Orange County's public affairs and environmental issues, we have enclosed a copy of "2020 VISION: An Action Plan for Wastewater Management" for your review and comment. It summarizes the contents and findings of the draft Facilities Master Plan, Environmental Impact Report (EIR) , financial plan and public participation program comprising our Action Plan study. It outlines staff's preliminary selection of a preferred treatment level alternative for the next five years. This document describes long-term programs to effectively control the entry of toxics into the environment, increase the useable water supply through expanded water reclamation activities and maximize the reuse of wastewater treatment by-products such as sludge and digester gas. "2020 VISION" is, in effect, our blueprint for comprehensive wastewater and environmental management designed to ensure that we protect the ocean, as well as the air and the land, while continuing to provide quality services in the face of increasing demands on our system. Thursday, April 13, 1989 marks the beginning of a 45-day public review and comment period on the draft Facilities Master Plan and draft EIR which evaluates "worst case" impacts from the range of studied wastewater treatment and management options. This review and comment period will end on Tuesday, May 30, 1989. If you wish to receive copies of any of the draft Facilities Master Plan, the EIR Executive Summary or the full draft EIR, please contact the Districts' Public Information Office at P.O. Box 8127, Fountain Valley, CA 92728-8127 or call (714) 962-2411. We welcome public comments on these reports. Your comments may be made at the scheduled public hearing or may be submitted in writing as follows: ANEW • COUNTY SANITATION DISTRICTS OF ORANGE COUNTY • FACT: SHEET April 18 , 1989 Volume 2 Revision 2 "2020 VISION" A Wastewater Management Action Plan BACKGROUND, PLANNING PROCESS The Orange County Sanitation Districts are responsible We have been conducting a comprehensive planning for wastewater management for most of Orange County. study to assemble the information necessary to make a We currently operate under the terms of a modified well-informed policy decision in mid-1989. The ocean discharge permit issued by the federal "Action Plan for Balanced Environmental Environmental Protection Agency (EPA) and the Management"is the Districts'program for coordinating California Regional Water Quality Control Board the necessary engineering, environmental and fiscal (CRWQCB). The existing permit is based on a waiver studies and for consulting with the public. When of the federal Clean Water Act's full secondary completed,the Action Plan will result in: treatment requirements. Section 301(h) of the Act permits deep ocean dischargers, like the Districts, to • A 30-year facilities Master Plan with a dispose high quality but less than full secondary treated focused construction and financing plan wastewater to the ocean.Our 301(h)waiver was issued through the turn of the century; in 1985 and requires an extensive ocean monitoring • An Environmental Impact Report (EIR) to program to determine whether the marine environment ensure that all elements of the environment is being protected and whether we are maintaining are adequately protected; compliance with the California Ocean Plan.Our current • permit expires in 1990. We are consistently in A determination of public opinion regarding compliance with all ocean discharge permit conditions the optimal level of treatment and the most oppropriate wastewater management and all federal and state discharge standards and quality limitations. In August 1989, we will be applying for a options; new permit from the EPA and CRWQCB. • An application to the EPA and the CRWQCB for renewal of our discharge permit. ISSUE To date, draft versions of the Facilities Plan, EIR and We must decide whether our treatment level beyond Financial Plan have been completed and input from 1990 should be partial secondary or full secondary. interested members of the public regarding the Providing full secondary treatment to all of our flow preliminary wastewater management options has been would cause less solids to be discharged into the ocean solicited and considered. and would result in the least change in the composition of ocean bottom life forms in the immediate vicinity of I.WASTEWATER TREATMENT the outfall. It would require a major expansion of our ALTERNATIVES facilities, which would cost more money to construct, We have been studying and evaluating alternative levels. operate and maintain.The added facilities would require of wastewater treatment prior to the treatment level more equipment and materials, which would increase policy decision by our board of directors and submission total energy use.The additional removal of solids would of our ocean discharge permit renewal application. also increase the amount of sludge requiring land disposal.The issue involves numerous trade-offs. On the following two pages, you will find a summary table presenting information from the Draft EIR and FUNDAMENTAL,QUESTION Facilities Plan relevant to the treatment alternatives being considered.Please note that it is the finding of the The critical question underlying this important public Draft EIR that each of the treatment alternatives would policy decision is: "What is the optimum wastewater protect the environment from significant impairment management program that will protect public health and from the ocean discharge and would comply fully with provide balanced environmental protection?" current regulations and laws. Based on the environmental, financial and engineering information and public feedback to date,Treatment Alternative No. 2 has been designated as the "Preferred Alternative." DESCRIPTIVE SUMMARY OF ALTERNATIVE WASTEWATER TREATMENT OPTIONS 1989 FUTURE WASThWATER TREATMENT ALTERNATIVES* Areas of Primary Current California Ocean (Preliminary �rY Preferred Option) Full Secondary Interest Operations Plan Current Permit Limits , I.T. Portion of Flow Z Receiving eat Secondary 12 1/3 1/2 Full :..t Qt Z Solids Removal 75% 75% 75% 85% L~ Biochemical Oxygen J Demand(HOD)Removal 70% 30 0 60% 85% w wToxics&Heavy Most important objective.Control at source to meet all existing and future standards.No future increases. Cs. I Metals Control Toxic control equivalent to full secondary under all alternatives.Environment and public health protected. Solids to Ocean/tand♦ Ocean/Land Ocean/Land Ocean/Land Ocean/Land (dry tons/day) 49/115 93/150 78/180 46/244 Sludge to Land(daily Wet Tons/Truckload Wet Tons/rruckload � Wet Tons/Truckload Wet Tonsaruckload wet tons/truckloads)) 720/33 930/47 1120/56 1520/76 Toxics&Metals to Ocean/Land Ocean/Land Ocean/Land Ocean/Land Ocean/Land(lbs/day) 600/600 620/580 550/650 370/830 ~ a a Q Dissolved Oxy en (%Depietion� 1.2% 1.5% 13% 1.0% Ocean Bottom 16 Acres 28 Acres 18 Acres S Acres ....1 '• re Life Composition♦ Impacted Impacted Impacted Impacted L'i• U Bacteria Levels 13 1.8 1.3 .2 (Million/100 ml) Z = Virus Levels (Length and depth of outfall results in no identified health risks for all treatment alternatives) O E (Thousand/100 ml) 2.4 3.5 I 24 I 3 nos►"'t Air Impacts Minor differences in air impacts between alternatives.Many volatile substances not measured. >�jj'' No significant adverse impacts on air quality from facilities operation. IL I {..4 Not comparable to future Total Energy requirements which reflect 6,900 Equivalent 9,100 Equivalent 13,400 Equivalent Requirements the efficient reuse of Households Households Households on-site sewage gas. -- C..) = Water Reclamation Up to 15 Million Amount reclaimed is independent of treatment level. ~ Gallons/Day An additional 58 MGD is proposed 0 Sludge Reuse Potential♦ Approximately 50%of Less due to higher Sludge is Reused Equal,pending new federal rcgulalions. �� dg water content. rr.'.r� G:i N.r ~ * Based on a treated wastewater flow of 399 million gallons a day(MGD)projected for the 2020.In theory,the year 2020 is used to illustrate the"worst case"outcomes for each treatment option.In practice,the treatment alternative which is ultimately sanctioned for our next permit period would guide operations from 1990 to 1995 only.The estimated year by which full secondary facilities could be constructed is 2005. The 2005 date is premised on 1990 construction start-up and timely procession by key regulatory agencies such as the U.S. Environmental Protection Agency and the South Coast Air Quality Management District. +Denotes an area reflecting differences among the alternatives. * DESCRIPTIVE SUMMARY OF ALTERNATIVE WASTEWATER TREATMENT OPTIONS 1989 FUTURE WASTEWATER TREATMENT ALTERNATIVES* (Preliminary Areas of Primary Current California Ocean Preferred Option) Full Secondary Interest Operations Plan Current Permit Limits 30-Year Capital Cost of Current Facilities Valued Facilities(a5%Annual at Approximately$625 $2.44 Billion $2.76 Billion $3.16 Billion Inflation)* Mil lion 30-Year Cost of O&M Up (@5%Annual Inflation)♦ N/A $3.78 Billion $4.11 Billion $4.75 Billion F Total Cost of Debt N/A $.82 Billion S.98 Billion $1.34 Billion C, Total 30-Year Cost of E Facilities(@5%Annual Inflation)* N/A $7.04 Billion $7.85 Billion $9.25 Billion Annual Cost to Flouseholds••(1988 9 S) $40_,8105 $90-$170 $105-$175 $130-$195 Cip Annual Cost to e f laar Food Processor(1 $) $709,000 $2,000,000 $2,100,000 $2,500,000 Annual Cost to Medium Sized Food Processor 533,600 $90,000 $96,000 $114,000 (1989$) Annual Cost to Metal Finisher $1,400 $2,900 $3,000 $3,200 (1989$) Calif.Ocean Plan yes Yes Yes Yes • Compliance? C -*1 301(h)Waiver Required? Yes Yes Yes No Qt �—,, The impacts of future air regulations are unknown O Air Quality Compliaa e? Yes and could hinder construction of wastewater and sludge treatment facilities. Sludge Reuse/Disposal Four reuse and disposal Various management options are available for each treatment alternative. • methods in use.75%of Ability to implement will depend upon future regulations,available sites, sludge goes out of county and public acceptance. * Based on a treated wastewater flow of 399 million gallons a day(MGD)projected for the 2020.In theory,the year 2020 is used to illustrate the"worst case"outcomes for each treatment option.In practice,the treatment alternative which is ultimately sanctioned for our next permit period would guide operations from 1990 to 1995 only.The estimated year by which full secondary facilities could be constructed is 2005. The 2005 date is premised on 1990 construction start-up and timely procession by key regulatory agencies such as the U.S.Environmental Protection Agency and the South Coast Air Quality Management District a • The range reflects differences among the nine member districts and includes O&M and debt service.The figures presented represent hour hold user fees for the fifteen-year period from 1990-2005. . IP. *Denotes an area reflecting differences among the alternatives. II. WASTEWATER MANAGEMENT PLAN: • Site shape and size OBJECTIVES • • Proximity to environmentally sensit.s.:areas A. Toxics Control D. Sludge Management Current Conditions: Our toxics source control program regulates the discharge of toxic substances and heavy Current Condition: Nearly 50 percent of the sludge metals from industrial dischargers to the sewer system. produced by our treatment process is recycled and used The program is approved by the EPA and the California for agricultural land application and for composting. Regional Water Quality Control Board. Current The remainder is trucked to sanitary landfills. performance is better than all existing standards for removing toxics and heavy metals. Plan Approach: As sewage flows increase,the volume of sludge will also increase. In addition, the more Plan Approach: Toxics control is an important stringent the wastewater treatment level,the greater the objective regardless of treatment alternative. Our quantity of sludge produced. Therefore, we need a • program controls the impact of toxics on air,water and practical, long-term plan for managing more sludge. land (i.e., sludge). This program will result in more The Master Plan approach is to have independent, stringent source control limitations for a greater number multiple sludge management alternatives giving us the of toxics and will commit to holding toxics and heavy flexibility to ensure that sludge disposal options are r metals in the wastewater stream at or below current always available and to continue to stress toxics source levels. control as a way to ensure sludge quality and maximize its reuse potential. The most promising sludge B. Facilities Construction management alternatives which have been identified in the Master Plan are: Current Conditions: Our existing facilities are adequate to meet the hydraulic and treatment needs of our service In-County and out-of-County co-disposal with area and the requirements of state and federal regulatory municipal solid waste agencies. • Sludge-only landfill(monofill) Plan Approach: Based upon land use information from Additional reuse via land application •local and regional planning agencies, sewage flows • within our service area could increase by as much as • Composting at approved sites 55% between 1990 and 2020. Our existing facilities • A detailed long-term sludge study to could not handle this increased demand. Consulting thoroughly evaluate specific options in light engineers have updated our facilities Master Plan to of more restrictive sludge management address the expected increase in flow and service regulations forthcoming from the U.S. demand as well as the various alternative treatment Environmental Protection Agency. levels. III. FURTHER INFORMATION C. Water Reclamation For further information or copies of the draft Facilities Current Conditions: We contract to reclaim up to 15 Master Plan or Environmental Impact Report, please million of our 260 million gallons a day (MGD) of contact the Districts' Public Information Office at Box wastewater in a joint reclamation project with the 8127, Fountain Valley, CA 92728-8127 or call (714) Orange County Water District.Up to 15 MGD will be 962-2411. recovered in 1989, upon completion of the Water District's new landscape irrigation and industrial reuse project. Orange County's semi-arid climate and three consecutive sub-normal rainfall years have made it prudent to explore additional reclamation opportunities as part of the Master Plan process. • Plan Approach: The Master Plan objective is to reclaim as much as is feasible of the approximately 399 MGD wastewater flow anticipated by 2020. Currently, three sites have been identified as the most viable locations for additional reclamation facilities which could reclaim as much as an additional 43 MGD.Some of the criteria being used to determine the viability of these sites include: • Economic feasibility • • Proximity to reclaimable wastewater • Proximity to areas for potential water reuse • L �1� EANI 41T�1.. /• OJ ':Z:{` l 'X90``.°t- ., 5 ,. • ,.�3 . A .: : - to uestions about... s ---, "_ 301 (h) Provision +p�E, ,,►,J: THE E .. of the Clean Water Act '``"' `' �""� • Background The Clean Water Act(CWA) is a 1972 amendment to the Federal i.1 Water Pollution Control Act. The 1972 CWA requires publicly owned treatment ''' ' y� .,, V . - works (POTWs)to use secondary treatment prior to discharge to ocean waters. Mi"-..—,... : !-w r r.,� :.'--- " In 1977, § 301(h)was added to the Clean Water Act. It allowed qualified POTWs =yy" employing rigorous pretreatment and extensive ocean monitoring programs to -z ... .w discharge into deep ocean waters that had large tides and substantial currents `" "-- -"`" : - allowing for greater dilution and dispersion than inland and estuarine waterbodies. In order for a POTW to qualify for a discharge permit under § 301(h) of the Clean fiZtli . Water Act, the discharger must meet stringent criteria including: _ • Compliance with water quality standards of the Clean Water Act• and the State Porter-Cologne Water Quality Act VS;."..":* .; • Protection and reproduction of a balanced native population of fish, k,‘, . r:�f. • 1� ' shellfish and wildlife %J1►� ,.,. +r • Protection of beach and nearshore recreational activities >1 ,' 4br-',• • Establishment of an extensive ocean monitoring program • ; o' 1� i• • A rigorous pretreatment program in order to meet secondary water . � 7'` �?•; —s quality equivalency for the removal of toxics `" ` ' • Protection of public water supplies '� : '` Since the adoption of the Clean Water Act, the Orange County Sanitation District Orange County (OCSD) has consistently complied with this and all other federal, state and local 9 ty regulations. Sanitation District • Who issues OCSD's Ocean Discharge Permit? When was the Vision- last permit issued? The Orange County Sanitation District's (OCSD)ocean :To maintain world-class discharge permit is jointly issued by the federal Environmental Protection Agency leadership in wastewater (EPA)and the State of California by the local Regional Water Quality Control Board and water resource (RWQCB). The ocean discharge permit requires review by the United States Fish management and Wildlife Service and the National Marine Fisheries Service to assure that the issuance of a permit will not impact endangered or threatened species. Also, the California Coastal Commission performs a review of the permit for consistency N with the Coastal Act. The permitting process requires a series of public hearings that assure an oppor- tunity for all interested parties to comment on the draft permit. The 5-year permit that OCSD is currently operating under was issued in June 1998 and expires in June 2003. The renewal application must be submitted to the regulators by December 2002. 10844 Ellis Avenue • How does OCSD treat wastewater? What is advanced Fountain Valley, CA primary treatment? OCSD treats wastewater using three processes: _, 92708-7018 preliminary treatment, advanced primary treatment, and secondary treatment. for more information In preliminary treatment, wastewater passes through screens that remove large call (714) 962-2411 and nonorganic materials. It then flows into grit chambers where the heaviest or visit our web site materials such as egg shells, coffee grounds, and sand settle out. The materials www.ocsd.com removed here are then sent to a landfill. OCSD/042001/3011H1.cdr naae 1 mouto 1 i+KT:v. at..�-:.,�..' After preliminary treatment, the wastewater is pumped to large settling basins. w_ Chemicals are added to reduce hydrogen, control odors, and combine small ':.:- r particles into larger particles. Here liquids and solids are separated. The heavier • , , solids settle and are scraped off the bottom, and the lighter material is skimmed • i— off the top of the basins. The thickeners that are added to improve settling of the mss-. heavier solids result in advanced primary treated wastewater. All of OCSD's wastewater receives advanced primary treatment.Advanced primary treatment removes 70 percent of the solids in the wastewater. Secondary treatment is primarily a biological system that uses microorganisms • �} - to feed on the organic material that is left in the water after primary treatment.• • . ;:.j• .. ---1 OCSD treats approximately half of its wastewater using secondary treatment. "'�`..,_:" Combined primary and secondary treatment remove 85 percent of the solids - — in the wastewater. _ OCSD uses two different processes for secondary treatment: trickling filters and activated sludge. Trickling filters use revolving arms that spray wastewater over baseball sized rocks covered in zoogleal slime(microorganisms)to clarify the • wastewater. Activated sludge is a brownish mixture containing a variety of aerobic • t i, microorganisms. The activated sludge is mixed with the wastewater in large tanks. Air or oxygen is bubbled through the mixture creating an ideal environment . for the bacteria to feed, grow and reproduce. The bacteria eat most of the 1�: dissolved organic material in the wastewater. �.w` • What is the difference between the standards required in a - full secondary treatment permit and a permit issued under the § 310(h) section? The § 301(h) provision of the federal Clean Water • :.A, - • Act allows for a slight increase in the amount of total suspended solids(TSS) 4 and biological oxygen demand (BOD)over set standards imposed on other ocean discharge permit holders. These slight increases are in the concentration, but there is still a limit in the overall mass that can be discharged. However,the , C; § 301(h) permit requires increased ocean monitoring by OCSD and increased - environmental examination by regulatory agencies. s3�:= • Where does the water go after treatment? After treatment, OCSD discharges the treated effluent between four and five miles out to sea from an ocean outfall pipe 200 feet underwater. The outfall runs perpendicular to the beach heading out to sea just north of the Santa Ana River in Huntington Beach. ,��(1 1,/ 1 �F! •��:.._:. . `i { .: . ;-: • Does OCSD test to make sure fish and other sea life are not =}:,(Urr��r� i :v =4,::;:.,.;7-;: - affected by the outfall's treated effluent discharge? OCSD : conducts an annual multi million dollar ocean monitoring program. The extensive x � monitoring program tracks and evaluates water quality, sediment quality and sea � ' �' life from Seal Beach to Corona Del Mar. 1� . itrr-lt- r.. .r The program is designed to measure impacts to the coastal ocean environment ` `. from the discharge of treated wastewater so that OCSD can take appropriate measures to ensure the continued protection of human health and marine organisms. Thousands of samples are taken each year from the coastal waters and bottom . . �;s'. ;y sediments using rig fishing, trawling, sediment grabs, water column testing and •.;::,y�•: -, —• in plant wastewater samples to ensure the safety and health of the public and 40/ marine life. OCSD is required to perform more sampling than other agencies, 4 . • . { r`' but annually the agency does considerably more that the minimum requirements•d" I ` ' " due to its interest in overall watershed and environmental protection. OCSD/042001/301(H).cdr page 2 • • Why does OCSD choose to be regulated under the § 301(h) provision rather than implement full secondary treatment. --i�- ( OCSD believes that the § 301(h) provision allows the agency to strike a balance - t-- f":r. k between the impacts upon the air, land and water environments due to the i o „9,•r•, ,r• wastewater treatment process. As a result, OCSD believes that the § 301(h) f'A 1 `1L04}t • provision allows for greater overall environmental protection of the land, air and t .�;:s�/,! ' assures future flexibility for the a en to implement the newest and �r � � ,, ..�1-t�. .•._ sea and assu es utu a agency t p st most efficient treatment systems. What would happen if OCSD was required to change wastewater treatment levels to full secondary? OCSD would consume much more energy(electricity and natural gas necessary to run the co- generation facilities), be required to manage two times the amount of biosolids currently generated, and increase air emissions into the environment. • �.,,rt4W�;. ;,• The ratepayers in Orange County would pay an additional $200-400 million dollars 'T4, i� r for construction of secondary facilities and approximately$10 million dollars more 3 .'r.�.4.,I� a year in operations and maintenance. The bulk of the amount is the cost of �' ..�_�*_`3s , =� , handling and disposing of biosolids. �r,� w,� ;�, ., . How is the § 301(h) provision linked to ocean water x - ='` ,.e : - • closures? The § 301(h) provision is not related to the ocean water closures. . 1 . o; v.,., The closures are due to the presence of bacteria in the water, which is not believed to be associated with OCSD's discharge. OCSD has repeatedly per- formed wastewater analyses to demonstrate that the effluent plume is not reaching nearshore waters; however, more analyses are planned to further assure protection of public health. Full secondary treatment would not provide any significant further protection of public health, as secondary treatment is NOT a form of disinfection to rid the effluent of further bacteria. What differences might occur in the ocean environment _ � without the district's § 301(h) provision? We would not see any• difference in the ocean's sediment, however we might be able to detect a p decrease in the abundance of the fish around the discharge zone. There has been -'� �, an ecos stem established that uses some of the dischar ed nutrients for food. -- ri, r�. By removing additional solids, we would be removing nutrients currently being �"� - released to the ecosystem. �.,,_:r -� -�y_ ystem. There is the potential to slightly increase the clarity in the water near the dis- charge due to decreased solids. While the increase would be calculable, it is likely not measurable. The 20-year Strategic Plan, dated 1991, shows that you are • preparing or full secondary treatment. When will that be done? Why not sooner? The 1999 Strategic Plan process, which was a ,_ . public process, indicated that OCSD should pursue water reclamation and , `, ' ' maintain the use of the § 301(h) provision of the Clean Water Act. OCSD believes .-r, Vii)::"': i .. ' - that § 301(h) permit allows for a beneficial balance overall between the land, air 441 and ocean environments. OCSD is not progressing towards full secondary at this time If the decision were made today proceed to full seconds y to p secondary, it would take 5-10 years for OCSD to begin operation. OCSD/042001/301(H).cdr page 3 .it: ":"4 '''gii December 1997 Vol.6 No. 2 P ..�{.7' ♦ 1.: L #1 )� $\V t`. ri ( / rx Ii ' 440`ti 'f� iff 4.-.! ‘ .4vi "„,$ti. ,..71 ‘t1. A r ,;ii fi =r -4 y`ttt 4;_. A o .t a ..,..f/ .,; ..i.. 1,,,�`• +LAW' A newsletter of St{rfrtder Foundation's Huntington/Long Beach Chapter Is the Ocean a Dump? r:' ;�'''i'' ' Y : t t�; i pji; .'1 lY� O.C. Sanitation Says:Yes! tO i 1 1 t I lin t...1;'1 t s II 1 I I ;. Here is your chance to hear the reasons why the December 4th Orange County Sanitation District thinks that they Thursday at 7 pm should expand ocean s,:wage disposal. They are 10844 Ellis Fountain ountain Valley proposing an increase ii the amount of treated 405 Frwy. at Ave.,., od/Ellis exit urine and feces that are dumped into the deep (tell guard you are going to the Administration Building) ocean off shore of the Santa Ana River. Not only Speaker. Nancy Wheatley, do they want to increase. their dumping, but they Director of Technical Services want to continue their e; emotion from the , ` Orange County Sanitation Federal Clean Water Act. . • They are asking for an l ul - extension of their sectio,l � • �4 1 ' Radioactive Waste r 301h waiver. The 301h v _ ', Spill �Near the T waiver is a loophole in' the Clean Water Act the. .4,-.., ; Santa Ana River says that if a polluter i�, .w... Recently the 405 Freeway was closed for can prove that their N%, -. .1\` ""ifive hours while workers cleaned dumping does not 44 7..,r, '' ' degrade the ` up an overturned truck full of environment, they can '"` *"r. .;t, radioactive medical waste. None continue to dump without obeying the law that was discharged into the Santa says that all sewage treatment plants should treat River—this time. their sewage to"full secondary”standards. Soon they will be using old nuclear power plant Sewage treated to "full si:condary standards" if fuel to irradiate meat. Isn't it time we rethink our s swallowed in even small amounts YrCi�il4' cause society's dependence on dangerous chemicals? grave illness and perhap i death within a few Do we want toxic trucks running all over our local days if untreated. Seconi Lary treatment removes streets and freeways? most of the solids from th. sewage. Orange County Sanitation says tt is is too expensive. Please Support Your Chapter . Supporters this Holiday Season Let's Hear Their side of the Story/ . River's End Cafe - First st, sea Beach More Pipes in the Ocean? Harbour Surfboards -seal Beach ' Recycled Water or Ocean Dumping? Bruce Jones Surfboards -sunset Beach Juice for You - warner&pcH . ... . _ .1 To: N.Wheatley, INTERNET:73222.1532 @compuserve.com Date: 2/9/98, 11:23 AM Re: CSDOC NPDES permit application 301(h)waiver. Nancy, In the message Dtd. 215198 you stated: "There WILL BE lower volumes of effluent discharge with GWR than without." "The mass emissions with GWR will be lower than without." The NPDES Draft Permit (Pg.5, Par.8.) states; "The discharger is currently planning a major regional water reclamation project, the Ground Water Replenishment System (formally known as the Orange County Regional Water Reclamation Project), that may reduce the dischargers projected suspended solids mass emission rate to below 19,788 MT/yr by the end-of-permit term " The EPA Tentative Decision of theRegional Administrator(Pg.7 Par.3), states; "Mass emissions: In terms of mass, suspended solids loadings have ranged from 14,000 to 17,500 MTtyr since 1985." Once again,this appears to be a clear contradiction in information received from CSDOC Instead of the decrease that you stated, the permit is predicting a 25% increase,with an option to go even higher at the request of the discharger(see Permit Re-opening, revision, Revocation, and Re-issuance condition J.3). Based on the previous technical information that I have received from OCWD and CSDOC, there should be a corresponding, and proportional reduction mass emission as a result of the GWR project, that would place a maximum end-of-term value of 14,500 MT/yr. for this effluent limit parameter. Please help me restore some of your lost credibility as spokesperson for CSDOC. I suggest that you get togeather with Tom Dawes at OCWD, and find out exactly how much secondary treated effluent is needed for the GWR project.I would then be glad to assist your engineering staff in calculating the approximate volume of additional secondary treatment process capacity is needed in order to meet previously stated commitments,consistent with your current regulatory requirements. Your friend,Don Schulz 1 To: Donald P. Schulz, Surf Daddy From: Nancy Wheatley, NWheatley Date: 2/9/98, 12:46 PM Re: CSDOC NPDES permit application. 301(h) waiver. Don —While this dialogue is good overall, I am concerned that all information provided reeds to be understood and used. There is no contradiction between my saying that there will be lower volumes of effluent discharge and mass emissions with the GWR system than without and the language in the permit about increases in discharges and emissions. There will be growth in the system because there will be growth in Orange County's population. That must be factored into calculations on future discharges. Also, please note that the permit reoaeners are conditioned on moving forward with the GWR system. Tom Dawes, and the consulting engineers both at OCWD and CSDOC, are working on the development of treatment requirements as part of the Strategic Plan and GWR system work. While those reports are not finalized, some numbers are, and have been available. Those numbers do not include an additional 84 mgd of secondary treatment. As with many complex projects, there are details that make the issue somewhat more complicated that it appears on its face, but everyone has been trying to get you the best information possible. One reason that I have avoided putting numbers in my responses to you is that I do not want to get incorrect numbers into the debate. I have been trying to deal with principles. I will reiterate that I do not believe it is responsible to invest resources to provide wastewater treatment that has little or no environmental (or public health) benefit. To the extent that your position on additional secondary treatment is premised on a belief that this treatment will provide environmental benefit, I would encourage you to look at our manna monitoring information over many years. It is almost impossible to find impacts from our discharge once you move away from the immediate area of the difuser. (It is true that you can find bacteria offshore, which is an impact, but there is no evidence of harm to human health or the marine life. I do consider this an important issue that must be looked at over the long term.) If you disagree with the findings of our monitoring, I would encourage you to state why and provide the basis for your opinion. Nancy 1 sURFRIDER FOUNDATION .,„4Huntington / Long Beach Chapter February 13, 1998 U. S. Environmental Protection Agency Region IX, WTR-5 75 Hawthorne Street San Francisco, CA 94105-390 Attn: Robyn Stuber California Regional Water Quality Control Board - Santa Ana Region 3737 Main Street, Suite 500 Riverside, CA 92501-3339 Attn: Gary Stewart RE: (1) Draft National Pollutant Discharge Elimination System (NPDES) Permit. (2) FACT SHEET -Draft, Waste Discharge Requirements and Authorization. (3) Tentative Decision of the Regional Administrator. Gentlemen: A review of the above referenced documents has raised some issues and questions within our local Surfrider Foundation Chapter membership that w e would greatly appreciate your assistance in clarifying for us: (1) Reference (3); Description of the Treatment System (pg.6) states: "The Huntington Beach facility(plant#2) located near the mouth of the Santa Ana River has the capacity for 186 MGD in primary treatment " s/b "168 MGD of primary treatment" per reference (1), pg. 3, par. 5.? (2) Reference (3), pg. 58 states: "California Ocean Plan. 1990"...s/b "California Ocean Plan 1997." ? (3) Reference (2), pg.3, item 4. states: "The discharge meets State water quality standards." But, reference (3), (pg.14), lists seven compounds (aldren, heptachlor, hexachlorobenzine, chlordane, toxaphene, DDT, and PAH's), for which the detection limits are greater than the maximum California Ocean Plan standards. Therefore, with regard to these compounds, the discharge must be, at best, indeterminant with respect to meeting State water quality ocean plan standards. (4) Is it the assumption in the EPA's calculation of dilution factor (as predicted by EPA's UPLUM model), that all compounds should have the same dilution factor in sea water? (5) Are the listed Mass Emission Rates "benchmarks", as indicated in reference (2), pg.13 and reference (3), pg.14, or are they regulatory requirements,as stated in reference (1), pg. 11? (6) If, as the discharger has stated many times, "The Groundwater Replenishment System project will result in a reduction in polluted effluent discharge into the ocean.", then why is it necessary for the EPA to permit them a 25%increase in Mass Emission Rates P.O. Box 3087 Long Beach , California 90803 (310) 438- 6994 Page 2 U. S. Environmental Protection Agency California Regional Water Quality Control Board - S. A. Region (7) Is it a policy of the EPA to grant dischargers an increase in Mass Emission Rate limits as an incentive,in order to encourage them to participate in water reclamation projects? (8) Reference (3),pg.46, D."Impact of Discharge on Recreational Activities." erroneously quotes the California Ocean Plan coliform bacteria requirements in terms of most probable number (MPN). Reference (1), pg. 25, states it correctly (as an absolute number). These two values are not numerically equivalent. (9) Reference (1), pg. 35, states "For the offshore zone, compliance with receiving water limitations shall be determined by sampling and analyzing for Escherichia Coli. using the Colilert Method." Is this an EPA approved test method, and does this preclude the use of any other commercially available test method? (10) Is it the contention of the EPA that a discharge of 20,000MT/yr. of polluted effluent in the migratory corridor of the Pacific Grey Whale poses no threat to this endangered species? Your timely response to these issues will greatly assist us in preparation of the comments to the NPDES Draft permit 301(h) waiver request. Thank you for your attention to this matter. Very truly yours, D. P. Schulz, P.E. Surfrider Foundation Huntington Beach/Long Beach Chapter (562) 430-2260 SurfDaddy @compuserve.com cc: EIT, Surfrider Foundation 4c-121-046 0 ORANGE COUNTY GRAND JURY 700 CIVIC CENTER DRIVE WEST•SANTA ANA, CALIFORNIA 92701.714/8343320 August 17, 1998 Don Schultz Surfrider Foundation P. O.Box 3087 Long Beach,CA 90803 Dear Mr. Schultz: On behalf of the 1998-99 Orange County Grand Jury,I want to thank you for your interview with the Environment-Transportation Committee on Wednesday,August 12. We share a common interest with your Foundation—that of addressing the issues of pollution in our oceans and beaches—and wish you well in your work. Very truly yours, 1998-99 GRAN 'OUNTY GRAND JURY Sheldon S. Singer Foreman SSS:cj SURFRIDER FOUNDATION Huntington / Long Beach Chapter SURFRIDER FOUNDATION HUNTINGTON/LONG BEACH CHAPTER ORANGE COUNTY GRAND JURY INPUTS Prepared By:Executive Committee Surfrider Foundation HB/LB Chapter Blue Water Task Force Environmental Issues Team September 17 , 1998 P.O. Box 3087 Long Beach , California 90803 (310) 438 - 6994 SUMMARY OF ISSUES SUMMARY OF ENVIRONMENTAL ISSUES FOR THE ORANGE COUNTY GRAND JURY PANEL CONSIDERATION: I. COUNTY SANITATION DISTRICT OF ORANGE COUNTY(CSDOC)301(h)WAIVER. Q. LIABILITY OF BEACH AND OCEAN POLLUTION AT SANTA ANA AND SAN GABRIEL RIVER OUTLETS. III. NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM(NPDES)POLLUTION FINE. IV. CSDOC FREQUENCY OF DISCHARGE OF SEWAGE AT NEWPORT BEACH. V. CURRENT FEE INCREASE AT CSDOC. SURFRIDER HB/LB CHAPTER PAGE 2 I. CSDOC 301(h) WAIVER CSDOC RECENTLY RECEIVED EPA APPROVAL FOR AN EXTENSION,AND MODIFICATION OF THEIR NPDES DISCHARGE PERMIT WHICH WILL ALLOW A 25%INCREASE IN THE AMOUNT OF SUSPENDED SOLIDS(UP TO 20,000 TONNES)DISCHARGED INTO THE OCEAN OUTFALL. THIS IS A VIOLATION(APPARENTLY UNENFORCEABLE)OF THE CLEAN WATER ACT (CWA). IT IS ASSERTED THAT THE PERMIT WAS GRANTED ON THE EPA PREMISE THAT THIS INCREASE"DOES NO HARM TO THE MARINE ENVIRONMENT',AND THAT CSDOC PARTICIPATE IN THE GROUND WATER REPLENISHMENT SYSTEM(GWRS)PROJECT. IT IS ASSERTED THAT THE PRIMARY BENEFICIARIES OF THIS APPROVAL ARE THE PROPERTY DEVELOPERS IN NORTH ORANGE COUNTY,SINCE THE COST SAVINGS IN CSDOC TREATMENT WOULD CONTINUE TO BE PASSED OFF TO SUBSIDIZE REDUCED CSDOC CONNECTION FEES TO DEVELOPERS. (CONTINUED ON NEXT SLIDE) SURFRIDER HB/LB CHAPTER J \ \ PAGE 3 I. CSDOC 301(h) WAIVER (continued) OUESTIONS: (I) In the opinion of the OC Grand Jury, is the decision by the EPA to allow a 25%increase in effluent discharge consistent with the anti-degradation policy of the Clean Water Act(CWA). (2) Did the EPA exceed its authority by allowing a reopener provision to permit CSDOC even greater levels of effluent discharge on condition that they participate in the Ground Water Replenishment System(GWRS)project. (3) Does the NPDES Permit re-opener provision constitute a thinly veiled bribe by CSDOC to promise to financilly participate in the GWRS on condition that they are allowed to increase the levels of pollution discharged into the ocean? (4) Does the EPA need more stringent guidelines with respect to CWA? (5) Is the use of CSDOC user fees for the GWRS project legal and proper? (6) Did CSDOC officials knowingly attempt to deceive the public by telling them that the GWRS would result in a reduction in efluent discharge while at the same time planning a 25%(or more)increase in discharge levels? SURFRIDER HB/LB CHAPTER J �� \ • PAGE 4 II. LIABILITY AT RIVER MOUTHS \ ' TWO MOST FREQUENTLY POLLUTED BEACHES IN ORANGE CO ARE AT THE MOUTH OF THE SAN GABRIEL AND SANTA ANA RIVERS. SANTA ANA RIVER COLIFORM LEVELS 85%OF YEAR ABOVE BODY CONTACT STANDARDS. SAN GABRIEL RIVER COLIFORM LEVELS: 25%OF YEAR ABOVE BODY CONTACT STANDARDS. QUESTION: (1) Should the Counties of Los Angeles, San Bernadino and Riverside be held financially liable for the health and water quality of Orange County beaches? SURFRIDER HB/LB CHAPTER PAGE 5 III. NPDES POLLUTION FINE CSDOC WAS RECENTLY GRANTED A 301(h)TREATMENT WAIVER WHICH REQUIRES THEM TO MONITOR THE WATER AND SEDIMENT QUALITY OF THE OUTFALL REGION MORE EXTENSIVELY. THE 301(h)WAIVER ALLOWS CSDOC TO CONTINUE DISCHARGING ADVANCED PRIMARY TREATED WASTEWATER TO THE OCEAN INSTEAD OF THE SECONDARILY TREATED WASTEWATER THAT THE CLEAN WATER ACT REQUIRES. THE"EXTENSIVE MONITORING"WILL COST THE ORANGE CO TAX PAYER MORE MONEY. A MORE EQUITABLE SOLUTION WOULD BE TO ASK THE O.C.DISTRICT ATTORNEY TO INCREASE THE FINES TO POLLUTERS TO PAY FOR THIS ADDITIONAL EXPENSE WITH A FINE INCREASE. QUESTION: (1) Should the O.C. Grand Jury request the O.C. District Attorney.reassess the NPDES fine structure to cover the increase in sediment testing at CSDOC required as a condition of the 301(h)waiver? SURFRIDER HB/LB CHAPTER PAGE 6 W. SEWAGE DISCHARGE AT NEWPORT BEACH RATHER THAN INCREASE SANITATION DISTRICT USER(CONNECTION)FEE'S,CSDOC'S PLANNING ADVISORY COMMITTEE FAVORS A POLICY WHICH WOULD HAVE A FREQUENCYOF EMERGENCY DISCARGE OF TREATED FINAL EFFLUENT THROUGH THE • 78-INCH OUTFALL LOCATED 1 MILE SOUTH OF THE SANTA ANA RIVER OUTLET ONCE EVERY THREE YEARS IN THE YEAR 2020. THE DEFINITION OF EMERGENCY CONDITIONS BY THE REGIONAL WATER QUALITY CONTROL BOARD IS AN"EXTREMELY RARE AND INFREQUENT EVENT". THE DEFINITION OF EMERGENCY CONDITIONS BY THE FLOOD CONTROL DISTRICT IS ONCE EVERY 190 YEARS. THIS POLICY WOULD BENEFIT BUILDERS AND DEVELOPERS SINCE CSDOC WOULD NOT HAVE TO BUILD NEW FACILITIES WHICH BY CURRENT POLICY ARE SUPPOSED TO BE PAID FOR BY DEVELOPERS CONNECTION FEES. QUESTIONS: (CONTINUED ON NEXT SLIDE) SURFRIDER \I HB/LB CHAPTER PAGE 7 • IV. SEWAGE AT NEWPORT BEACH (con't) _ I QUESTIONS: (1) Is increasing beach pollution in order to reduce the fees paid by a clear minority of district residents fair and lawful? - (2) Should the Regional Water Quality Control Board be required to numerically define"an extremely rare occurrence"? (3) Should district fees be used as subsidies to builders and developers in order to promote county growth? SURFRIDER HB/LB C HAPTER PAGE 8 V. CURRENT FEE INCREASES AT CSDOC SURFRIDER ASSERTSTHAT CSDOC'S RATE-PAYER HAS BEEN ASKED TO PAY A HIGHER RATE AND TOLERATE AN INCREASE IN BEACH POLLUTION FOR THE ECONOMIC BENEFIT OF PROPERTY AND BUSINESS DEVELOPERS. CSDOC ASSERTS THAT THE NEW USER FEE STRUCTURE WAS DEVELOPED IN ACCORDANCE WITH THE POLICY THAT VARIOUS USER CLASSIFICATIONS SHOULD PAY THEIR FAIR SHARE,AND THAT USER FEES SHOULD BE SET IN PROPORTION TO A USER'S IMPACT ON THE DISTRICT'S OPERATIONS. QUESTIONS: (1) Is the current fee structure at CSDOC fair and equitable? (2) Is the current fee structure at CSDOC being administered according to policy? (3) Is the current income to CSDOC(from Ad Valorum taxes, rate-fees and connection fees)being used for unauthorized purposes such as the GWRS project to subsidize developers to promote County growth and to conduct political opinion surveys? (CONTINUED ON NEXT SLIDE) SURFRIDER HB/LB CHAPTER 1 PAGE 9 • V. INCREASES AT CSDOC (continued) QUESTIONS: (con't) (4) Is the current income from connection fees sufficient to pay for the expansion of treatment facilities to accomidate projected district population growth at the same level of effluent treatment? If not, why not? (5) Should an independent outside audit of CSDOC income and expenditures be conducted? (6) Should additional financial controls be put in place at CSDOC in order to insure that rate policies are strictly adhered to? SURFRIDER HB/LB CHAPTER PAGE 10 CONCLUSIONS & RECOMMENDATIONS IT IS RESPECTFULLY RECOMMENDED THAT ACCOUNTABILITY TO THE RATE-PAYERS, AND THE FOLLOWING OPERATIONAL_AND FINANCIAL CONTROL POLICIES AT CSDOC BE PUT IN PLACE THAT WILL ASSURE THAT THE FOLLOWING POLICIES WILL BE STRICTLY ADHERED TO: (1) ALL FEES COLLECTED FROM RATE-PAYERSARE USEDONLY FOR THE OPERATION AND MAINTAINENCE OF THE EXISTING SYSTEM PLUS NECESSARY RESERVES. (2) CAPITAL NECESSARY FOR THE EXPANSION OF CSDOC'S CAPACITY TO SERVICE THE PROJECTED COUNTY POPULATION GROWTH WITHOUT FURTHER DEGRADATION IN THE LEVEL OF TREATMENT, SHOULD COME FROM CONNECTION FEES AND NOT FROM USER FEES. (3) FINANCIAL"INCENTIVES"FOR WORTHWHILE CSDOC PROJECTS(SUCH AS THE GROUND WATER REPLENISHMENT PROJECT)SHOULD COME FROM ALL BENEFICIAL COUNTY RESIDENTS(AD VALORUM TAXES),AND NOT FROM RATE-PAYERS. (4) CSDOC SHOULD STRIVE FOR FULL COMPLIANCE TO THE REQUIREMENTS OF THE CLEAN WATER ACT WITHOUT CONTINUED RELIANCE ON WAIVERS,EXEMPTIONS, AND EXCLUSIONS WITH REGARD TO OCEAN WATER DISCHARGE PERMITS. (5) CSDOC SHOULD STRIVE FOR THE GOAL OF 100%RECYCLE CAPACITY BY THE END OF LIFE OF THE' 12 0" .OUTFLOW PIPE. SURFRIDER HB/LB CHAPTER PAGE 11 • Who is Responsible for the • • Water Quality of Our Beaches ? By Gordon LaBedz There are two answers that are correct; answer pollute, also. Except for run-off from industrial one - YOU ARE! and answer two NOBODY!! sites, there are very few factories left that have I There is a third answer, but you won't find it very pipes in the rivers or ocean. Power plants are a satisfying, our government agencies. First, there big exception. That's why the water in Seal Beach 1 , is the Regional Water Quality Control Board. They is so warm. The power plants take Alamitos Bay are funded by our federal income taxes through water to cool their turbines and then they dump the the E.P.A.. There is one for the San Gabriel River hot water in the San Gabriel River. and another one for the Santa Ana River. They don't communicate very much. They don't The Local Cities 'measure water quality anywhere, unless asked. Cities are responsible for the sewer pipes that lead They have a policy that we call "correct your own to the sewage plants. Some of these pipes are homework." • fifty years old, rusted and bent • by earthquakes and subsidence Pollution Permits (ground • sinking from oil The Regional Water Quality . . extraction). During heavy rain, Boards give polluters a permit these pipes can leak sewage to to pollute (NPDES permits). : ,, .y- " • g �:>J:; :.', ; . - the storm drains and beach. It Then they ask them to monitor ' ` �' ::. .••• • •' is a case of out-of-sight, out-of the water to be sure that their "`' - ° . permit is being obeyed. The •./ ,'�1 •r: -mind. Regional Boards are way toor �'"‘ ` p . Public Health Agencies understaffed to look at any of > : :• •�� >�t + • >, Some monitoring is done by this monitoring and sometimes - . ;;`.-,, f' - County Health Agencies. They polluters _ these called •• ( �`�-___ '�;`��y� .• .<.';Y,'=�'j'�. will usually put a sign on the "dischargers") get away:with - -. " beach, if they` hear about a murder. If we catch them, we - sewage spill. They monitor can sue them under the Clean ; some beaches once a week:-.:It Water Act.. takes them three days to get the results:. Sometimes they ,make Sewage Plants . reassuring comments to the media. : , Most of the surf zone water quality monitoring is ; ' • done by sewage agencies. The Regional Board It is up to Us am- gives them a permit to dump partially treated. There are a great many other bureaucracies : . sewage in the deep offshore waters. If this that have some control of water. Most don't .r: sewage doesn't reach the beach, they are off the talk to each other and often they don't even hook. If the beach is polluted by urban run-off, it is like each other. We organized the Surfrider: A not their problem. When the bacteria counts are Foundation to empower local activists' to high after a rain, they say that it is not from their clean up this nightmare and clean up our ' : sewage plants and of no concern to them. beaches. We hope you will get involved If • . not you, then who? ' 'I, Factory Pollution a ;N. The Regional Water Boards give them permits to . '' Eby 'd;------_ .� j' ' %.,,.--'4 -4_--., r yf'. '' n'`_ I 1•' II .4M^ t1�•)�\\ 7— '' 4>. y I . . ll•MlI. . o 'iov22=, =4 CD v 1110 . tiro co , 0 �o'� m 15 on� m0C7cF :F' � z S V Z CIIII eD m a... .. 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O BE ""' 5peDfDH eo t+ 0 e al xib - � g�+ a , aII �," � c1c °' ro� �D�n O 0, cA a° m`' .< •-• .e a et .m C/ N nm n .ep 5.O p,0.ti 51='1 ^2 O eo � doo �v°, �'aa'� ow ° n R. � etfla 7 00 t a—E$ oc m co • o y -- � gvV �^ at .-.IP co '3F ° m Os N :1.tato n O + O G ^+ eo R `.^ O CD I A �O Q. fy v' 7 0 C "3 1 Y l• • to .-.CO e9 . ft N N c so O e?' S O CD �'3 d p a eL i e9 < d M Gl p 4 G a s co m $�< I ... M o?= En , C 7 eD S3 O y r.O-.. S D y 41 b' oh sal • F-; nj co ''' * ,< = maina IN • st $u ° o,u 5, moo 5' . g ceDY < 7Aeic,., A 7 .Gn 8 N -I . N .c•. erse r 1 4. • WASTE: 17% I►READER POLL:Metro 3 'uui increase is a,u f ,,/,.... sac ••<:. 'tea , /•�_ expected ,ti 11•• )r tr Pipeline e,:na - _ FROM 1 tou _` smiles' cent secondary. to s Ism : - Only the amount of microscop- ! is particles in the water would - increase; the amount of water MORE SEWAGE `�` :-discharged would remain about --Z� The amount of microscopic waste ;q:• the same. ann particles suspended in water al: The increase in the concentra- discharged into the ocean could o tion of particles in the water is increase 17 percent under a •A . needed because of the district's as proposal by the Orange County ul • plans for a new groundwater-re- m; Sanitation District. . • At plenishment system. That sys- • at tem involves pumping highly si The Orange County Register gu. treated wastewater by pipeline s1 aq to- settling ponds in Anaheim, GETTING INVOLVED where it would gradually perco- a The Orange County Sanitation Dis- to late into groundwater aquifers. no tricts must collect public comment sa But it also means diverting up aq and gain approval from their board to 100 million gallons of water per si of directors before increasing the day away from the outfall pipe iq; amount of waste discharged into the DL -and into the new groundwater In ocean. Here's what's next: As system.And that,in turn, means Saturday:A workshop geared to- •'there will be a higher concentra- sc ward board members,districts head- .tion of solid particles in the water sE quarters, 10844 Ellis Ave., Fountain Si %that is discharged. I , Valley,9 to 11:30 a.m. It is open to t The sanitation district also will Qt the public. `S monitor water quality around the 1 11,Wednesday: District's board will °t outfall pipe to make sure the o: - vote on whether to release a draft 51 higher levels of discharge do not •environmental impact report to the at harm marine organisms. public. Same address,7 p.m. - c. The proposed waste increase is ■June 29: If approved,the report is 2 the product of two years of analy- - released to the public; copies will be 'c I. sis and review by wastewater 1-t available in local libraries. ;; and environmental experts, as •July 21: Board will hold a public I. well as public focus groups, Her- l hearing on the report and discharge t ;: berg said. a proposal. And it will help avoid some- II ■Date uncertain,but probably in !! :: thing the district does not want to October: Board will decide whether r do — build another outfall pipe. I to certify report and approve the dis- "We've looked at various ways ! • charge increase. -• to defer building a new outfall, 1 ►Questions?Call districts spokes- 1. '• which would cost $150 (million) • woman Michelle Tuchman, (714)962- •• to $200 million," said district ' . 2411, Ext.2050. spokeswoman Michelle Tuch- man. To: Orange County Register, INTERNET:letters @link.freedom.com CC: D.Slaven, INTERNET:eyes9 @earthlink.net CC: E.Kliszewski, INTERNET:eveklii @earthlink.net CC: Emiko, INTERNET:ekobayas @csulb.edu CC: G.Labedz, INTERNET:Labedz @aol.com CC: G.Leslie, INTERNET:gleslie @ocwd.com CC: G.Sargent, INTERNET:Gary.Sargent @west.boeing.com CC: M.Cousineau, INTERNET:mcousineau @aol.com CC: M.Waldron, INTERNET:mrimpact @hotmail.com CC: Gary Sargent, INTERNET:Sarg22 @juno.com CC: J.Herberg, INTERNET:jherberg©ocsd.com From: DON SCHULZ, 103475,1154 Date: 6/29/99, 9:43 PM Re: Plan Would Boost Discharge to Ocean. In the above referenced article dated friday, June 18, 1999 Mr. Jim Herberg, engineering supervisor at Orange County Sanitation Districts is quoted as saying "We're not going to degrade the ocean environment."There are many of us in the environmental stakeholder community who would disagree with the position of the Sanitation District that 20,000 metric tons of suspended solids dumped into the ocean each year(400,000 metric tons by the year 2020) "does no harm to the marine environment." There are bacterialogical ,toxic, and carcinogenic materials contained in the discharged polluted effluent that are at concentrations far in excess of current California Ocean Plan concentration levels. The plan put forward by the Sanitation District to increase the suspended solid discharge concentration by 17% ( 3,000 metric tons) because "800,000 more people are expected to move into north and central county" is misleading. The real reason for this increase is that the Sanitation Board has failed to implement a policy that would have collected sufficient funds from builder connection fees necessary to upgrade the Sanitation Department facilities to accommodate this anticipated population growth. D.P. Schulz P.E. member, CSDOC policy advisory committee 1 Huntington / Long Beach Chapter Aug. 13,1999 Orange County Sanitation District. 10844 Ellis Avenue Fountain Valley, CA 92708 Attn.: James Herberg RE: 1999 Strategic Plan Draft Environmental Impact Report. Dear Mr. Herberg As members of the District's environmental stakeholder community, Surfrider Foundation,Huntington Beach/Long Beach Chapter,appreciates the opportunity to review and comment on the very informative Draft Environmental Impact Report(DEIR),referenced above. As you know,we have always been, and continue to be, supportive of the joint OCSD/OCWD Groundwater Replenishment Project(GWR). Of the three scenarios described in the DEIR that include this option,however,we are disappointed that OCSD does not recognize and endorse Scenario 4 (full secondary with GWR)as the true environmentally superior option. This is the only(GRW)option that fully complies with the intent of the 1972 Clean Water Act (CWA). Specifically among our concerns regarding the District's recommendation of scenario 2(permit limits with GWR)are the following: • As indicated in the report,the concentration of pathogenic virus discharged into the ocean is one order of magnitude(10x)greater with the District's recommendation(scenario 2)than it is with scenario 4. Neither the District,nor the County Health Service routinely monitor for virus concentrations in the off shore or near shore surf zone.This places swimmers and surfers and others that enjoy recreational water contact activities at a much greater health risk. • The determination that scenario 2 is"environmentally superior"to scenario 4 "because it generates less impact to land and air resources" should be made,at least in part,by County health agencies,and the AQMD. It is problematic as to weather the short term detrimental impact to land and air resources caused by scenario 4 is offset by the long term detrimental impact to ocean water quality caused by scenario 2. • The planned use of the 78" "emergency"discharge pipe off of Huntington Beach during peak wet weather events would have a detrimental impact on both the surf zone water quality, as well as the economy of our coastal communities that depend on income from beach visitors. 0 • The projected frequency of occurrence of use of the 78" "emergency" discharge pipe(once every three years in the year 2020)does not meet any reasonable interpretation of the RWQB definition of "emergency" (extremely rare and infrequent)usage. • It would be inconsistent of the RWQB,which has already denied planned discharges of treated (chlorinated)secondary effluent into the near shore,to permit the planned discharges of untreated secondary effluent under anything less than extremely rare and infrequent(emergency)conditions. P.O. Box 3087 Long Beach , California 90803 (310) 438- 6994 • Increasing the ratio of primary to secondary treated effluent into the offshore discharge pipe, as currently planned by OCSD and permitted by their 301(h)waiver, could lead to greater concentrations of certain toxic and carcinogenic pollutants released into the ocean than that presently allowed by the California Ocean Plan. It is not clear in the DEIR what plans(if any)OCSD has to mitigate this problem. We would encourage the technical staff at OCSD to continue to seek solutions to these problems, such as the application of microfiltration technology to reduce the polluted effluent discharged to the ocean,and offsite temporary storage to reduce the frequency of emergency discharge during peak wet weather events. Sincerely, D.P. Schulz Surfrider Foundation,H.B./L.B. Chapter Blue Water Task Force cc: Surfrider EIT Return-path: <cdchase @sdearthtimes.com> Received: from mta4.snfc2l.pbi.net (mta4-pr.snfc2l.pbi.net) by sims3.snfc2l.pbi.net (Sun Internet Mail Server sims.3.5.2000.03.23.18.03.p10) with ESMTP id <OGC200687LS43F @sims3.snfc21.pbi.net>; Thu, 19 Apr 2001 20:02:29 -0700 (PDT) Received: from smtp3.san.rr.com ( [24.25.195.40) ) by mta4.snfc2l.pbi.net (Sun Internet Mail Server sims.3.5.2000.01.05.12.18.p9) with ESMTP id <OGC200GD8LRWOZ @mta4.snfc2l.pbi.net>; Thu. 19 Apr 2001 20:02:23 -0700 (PDT) Received: from [192.168.0.9) (dt010n3e.san.rr.com [204.210.12.62] ) by smtp3.san.rr.com (8.11.3/8.11.3) with ESMTP id f3K33BV01275; Thu, 19 Apr 2001 20:03:12 -0700 (PDT) Date: Thu, 19 Apr 2001 20:00:33 -0700 From: Carolyn Chase <cdchase @sdearthtimes.com> Subject: Health Dangers Arise From Pumping Of Sewage Into Deep Sea X-Sender: cdchase@mail.sdearthtimes.com To: sd-urban @ucsd.edu Message-id: <v04210107b70556acb5f9 @[192.168.0.9)> MIME-version: 1.0 Content-type: text/plain; charset="us-ascii" ; format="flowed" X-Mozilla-Status2: 00000000 Health Dangers Arise From Pumping Of Sewage Into Deep Sea From Ocean Update September 1999 Vol. 4, No. 9 Paul R. Epstein, Center for Health and the Global Environment, Harvard Medical School. Tel (617) 432-0493 An outbreak of cholera on the southern Coast of Bangladesh in 1992 may presage the risks posed to developed and less-developed countries alike from deep-sea dumping of human sewage, according to some researchers. Scientists have noted that the 1992 outbreak was accompanied by an upwelling that brought deep-sea water to the surface near the Bangledeshi coast. In recent years, researchers hale discovered a variety of pathogenic microbes, many usually found only in human feces, at unexpected depths of the ocean. Marine scientist D. Jay Grimes of the University of Southern Mississippi says that a variety of viruses that infect the human gastrointestinal tract - including poliovirus and rotavirus - have been identified in ocean water samples taken below 1,0000 meters (3,300 feet) . In the late 1980's, Sagar M. Goyal of the University of Minnesota isolated gut bacteria from samples obtained as sewage-sludge dumping sites more than 170 kilometers offshore from New York City, 30 months after the sites were closed to dumping. The bacteria were resistant to several antibiotics, showing that they originated from humans who were taking the drugs 2 Surfrider Foundation HuntingtonBeach/Seal Beach Chapter Blue Water Task Force News January 2001 NEW STUDY TAKES AIM AT OCEAN OUTFALLS IN 1999 HUNTINGTON BEACH CLOSURES A recent S1.5 million study lead by Dr. Stanley Grant, a University of California,Irvine,engineering professor, has concluded that wastewater from the Orange County Sanitation District outfall pipe is the most likely source of the bacterial contamination that caused the beaches in the city of Huntington Beach to be closed for over 2 months during the summer of 1999,and continues to plague local surfbreaks. The District's outfall pipe.xas tested for leaks by OCSD during their intensive investigation, and determined not to have any gross leak:, however plume tracking of the dye discharged from the outfall pipe during the tests indicated that pollutants could be transported downcoast and shoreward,then drift upcoast with the prevailing longshore current,and be upwelled by the warm water discharged periodically from the AES Corp. (formerly Edison)Electric Power plant in Huntington Beach. Although termed a theory, or "hypothesis"by the report's author, it is accompanied by a great deal of supporting data,and appears to be the only explanation to date that fits all of the observable facts. This theory may be validated with further testing of our near shore and off shore waters. The District's sewage treatment facilities in Fountain Valley and Huntington Beach have not kept pace with the rapid population growth in Orange County,and have been allowed under the terms and conditions of a 301(h)waiver to the Clean Water Act, granted by the EPA,to discharge a blend of primary and secondary treated effluent into the ocean. As a consequence,the off shore water quality is substantially lower than that which can be achieved with full secondary treatment as required by the Clean Water Act, and California Ocean Plan water quality limits. If transported to the near shore,as suggested by the UCI study, this would pose a serious health threat to surfers. The view held by the Santation District that the offshore discharge of up to 20,000 metric tons of suspended solids per year as allowed by the permit"does no harm to the marine environment" is not shared by the entire scientific community. For example,it has been suggested that greasy,bacteria laden suspended solids may reach the surfs;a and be rapidly blown ashore by prevailing winds, and pollute the surf zone. Also,the Amidegradation Policy of the Clean Water Act states that a degradation to the receiving waters has occurred when a beneficial use has been impaired. Beneficial uses include swimming, diving surfing, and gathering shellfish. Beach closures dearly qualify as a loss of a recreational benefit, and should be considered a violation of this policy. We would be remiss in our responsibility to our Chapter membership if we did not aggressively pursue this issue, and request that both the EPA and the Santa Ma Regional Water Quality Control Board review the 301(h)waiver recently granted to OCSD Don Schulz Blue Water Task Force Surfrider Foundation, Huntington Beach/Seal Beach Chapter P O. Box 878 Huntington Beach,CA. 92648 To: [unknown] , INTERNET:surfrider @ucsd.edu From: Chris Evans, INTERNET:cevans @surfrider.org Date: 03/16/2001, 4:54 PM Re: Fwd: County agency will ask EPA to renew ocean-dumping permit >> AOC sent us this one from the OC Weekly---Chris »March 16 - 22, 2001 >>Poop Chute »County agency will ask EPA to renew ocean-dumping permit >>by Dave Wielenga »OC Weekly >>About 240 million gallons of partially treated sewage-the equivalent of »three Anaheim Stadiums filled to the brim with Orange County's shit, >>piss, table scraps, whatever-will pour into the local ocean today. >>Same thing tomorrow: 240 million gallons of the grossest kind of gunk >>will flow from Joe Public's toilets and garbage disposals, through a >>huge pipe-10 feet in diameter and four and a half miles long-and into >>Davey Jones' Locker. >>Same thing yesterday: a huge pipe-10 feet in diameter and four and a >>half miles long-spewing our excrement 200 feet below the sea at the >>almost unimaginable rate of 10 million gallons per hour. »Same thing almost every day, for years and years and years. >>Yes, there is a law against this: the federal Clean Water Act, passed by >>Congress in 1972. It mandates that all sewage receive primary and >>secondary treatment before it is disbursed into waterways. >>No, the Orange County Sanitation District (OCSD) is not breaking that >>law. In 1985, the Environmental Protection Agency granted the district a >>301 (h) waiver. This gives OCSD permission to dump substandard >>wastewater-in this case, a 50-50 mixture of primary- and >>secondary-treated sewage-into the ocean. Two times the waiver has >>expired, and both times OCSD has been granted extensions. The current >>301(h) waiver expires in 2003, and OCSD intends to apply for another >>five-year extension, insisting that constantly spewing sewage into the >>ocean is not damaging. »This time, however, a small band of activists is mobilizing to oppose »OCSD's application to extend its 301(h) waiver. The Ocean Outfall Group »suggests that the constantly spewing sewage is responsible for the >>bacterial infestations that have repeatedly closed Orange County's >>beaches to swimmers and surfers during the past few years. Bolstered by »a recent UC Irvine study, the group hopes to convince the EPA that >>Orange County ought to live up to Clean Water Act standards imposed on >>the rest of the country since the 1970s. »"Here it is the 21st century, and we're still trying to drag Orange >>County sanitation kicking and screaming into the 20th century, " says Jan >>Vandersloot, a Newport Beach dermatologist who is a longtime activist in >>Orange County's water-quality issues. >>Blake Anderson, general manager of OCSD, insists county sewage is >>carefully measured and falls well within the parameters of the >>waiver-which he says is justified because the sewage is dispensed into »deep water and neither damages the environment nor public health. >>"We spend $2 million a year on a monitoring system that looks at >>everything from fish populations to fish-tissue analysis to bacteria on >>the beach, " says Anderson. "From our observations, we have maintained a >>balanced indigenous population of sea life, and our discharge plume has 1 »not impacted the beach's bacteria quality." >>Vandersloot disagrees. "Their own reports have discovered fish around >>the outfall pipe with liver lesions and other abnormalities, " he says. »"Populations of invertebrates are different around the outfall; some are >>increased and some are decreased, but the point is that they are »different. We disagree that 240 million gallons of sewage a day does not >>change the ocean environment." >>Additionally, a study by UC Irvine professor Stanley Grant suggests that >>bacteria from the sewage plume is drawn toward the shore because of hot >>water discharged into the ocean by the AES power plant in Huntington >>Beach. >>"That hypothesis is interesting, " OCSD's Anderson acknowledges, "and we >>are going to do our own study on that idea this summer." >>The UCI study has attracted the attention of the EPA, too. "We're >>curious about that study, " says Janet Hashimoto of the EPA's regional >>office in San Francisco, which will consider Orange County's next >>application for an extension of the 301 (h) waiver. "Bottom line: the >>sewage that goes into the ocean cannot be damaging. If it is, the >>situation does not warrant a waiver." >>The Ocean Outfall Group, which has completed four of nine scheduled »informational meetings with OCSD representatives, hopes to accumulate >>enough evidence of environmental damage that the district won't even >>bother seeking an extension. >>"We want to persuade OCSD not to apply, to instead voluntarily initiate >>full secondary treatment of the county's sewage, " says Vandersloot. "But >>at this point, they are resisting this all the way. Their bureaucracy is >>trained to say everything is fine and dandy. They say the sewage >>actually works to feed the fish. They are very glib about it. But we are »determined not to swallow their B S literally." >>****************** >>Suzanne L. Giles >>Water Quality Program Coordinator »American Oceans Campaign >>600 Pennsylvania Avenue SE >>Suite 210 »Washington, DC 20003 >>(T)202.544.3526 »(F)202.544.5625 >>www.americanoceans.org >Christopher J. Evans Esq. >Executive Director >Surfrider Foundation >(949) 492-8170 >JOIN SURFRIDER TODAY! --> http://www.surfrider.org Internet Header Sender: list-relay @mlistl.ucsd.edu Received: from mlistl.ucsd.edu (mlistl.ucsd.edu [132.239.1.50] ) by sphmgaad.compuserve.com (8.9.3/8.9.3/SUN-1.9) with ESMTP id TAA14547 for <103475.1154 @compuserve.com>; Fri, 16 Mar 2001 19:54:27 -0500 (EST) Received: from mailbox3.ucsd.edu (mailbox3.ucsd.edu [132.239.1.55] ) by mlistl.ucsd.edu (8.11.1/8.11.0) with ESMTP id f2H0fxm22741 for <surfrider @mlistl.ucsd.edu>; Fri, 16 Mar 2001 16:41:59 -0800 (PST) Received: from mta6.snfc2l.pbi.net (mta6.snfc2l.pbi.net [206.13.28.240] ) by mailbox3.ucsd.edu (8.11.0/8.11.0) with ESMTP id f2H0fwQ24971 for <surfrider @ucsd.edu>; Fri, 16 Mar 2001 16:41:58 -0800 (PST) 2 I° TO: Harbor Quality Committee FROM: Jack Skinner DATE: April 28, 2001 RE: OCSD's 301(h) waiver I am writing because I have concerns about the re-issuing of the Orange County Sanitation District's 301(h) waiver. I recently learned that the Orange County Sanitation District (OCSD) performed a study in the fall of 1996 known as the 20-Meter Study. This study tested ocean water quality on ten different days between September 26, 1996, and November 25, 1996, to determine if the wastewater plume was moving shoreward. There were five sample sites located at the 20-meter depth contour. Three samples were taken at each sample site (at surface, bottom and middle depths). No samples were taken closer to shore than the 20-meter depth at the time of this study with the exception of the samples taken at ankle depth right at the beach. To the best of my knowledge, this study was never released to the public or included in OCSD's yearly marine monitoring reports. However, this information was available to OCSD before they applied for the renewal of their current waiver, which was issued in June 1998. The study was only discovered by the public in January 2001. The findings of this study are troubling because it appears that, intermittently, the wastewater plume moves toward the beaches. On November 20, 1996, bacterial readings indicate that the plume did reach the beaches in West Newport. This is shown on the enclosed chart. Note the elevated total coliforms at the Newport Beach shoreline sampling locations and the exceedingly elevated fecal coliform levels taken near the ocean bottom at the 20-meter sampling sites, stretching all the way from off the Huntington Beach power plant to off the Newport pier. Also enclosed is a picture apparently showing a composite of the bacteriological results of the 20-meter fecal coliform study. The ocean bottom fecal coliform samples equaled or exceeded 400 MPN in the area circled in red, showing that the wastewater field comes very close to Newport's beaches. Recently, a more extensive plume study was done on November 27, 2000, by OCSD, the results of which are shown on the enclosure marked Figure 28. Again, it shows that the wastewater plume is coming toward the shore, especially near the power plant in Huntington Beach. Please note how far the plume has moved toward shore from the end of the outfall. Dr. Stanley Grant of UCI has performed an extensive review of the bacteriological data and has concluded that since a bacterial pulse arrives at the beach at station 9N during flood tides before any bacteria has entered the ocean from the Talbert Marsh that this is further evidence of an offshore source of bacterial pollution of the beach. This is because the high tides act as a temporary barrier, preventing the marsh water from entering the ocean. Extensive studies of offshore currents are planned for this summer. Based on the above evidence, I believe that there should not be a renewal of OCSD's 301(h) waiver. These studies indicate that there is a strong possibility that, intermittently, bacterial contamination from the outfall can reach the shoreline and thereby pose a threat to swimmers. It is for OCSD to prove otherwise. Secondary treatment with activated sludge removes about 95 percent of the viral pathogens. The lower suspended solids present in secondary treated sewage allow chlorination to be more effective should that prove necessary. Perhaps the only safe solution is to treat the entire effluent to the tertiary level to be used for reclamation purposes and eliminate all ocean discharges. Treating sewage to less than the secondary level becomes a disincentive to reclamation since all reclaimed water must go through the secondary process and beyond. In the past, Nancy and I have opposed the granting of 301(h) waivers to sanitation districts with short outfalls but until recently, we had not been concerned about the Orange County Sanitation District's discharge four and a half miles off the coast. However, we have had second thoughts about the safety of OCSD's ocean discharge because of recent evidence that there is shoreward movement of the wastewater plume. Jack Skinner . • . . ;Isii.z.;• . \ • ,....1.•,•4:4•••:,...i ,:. , 0 i ) ,' .,,,..,..::•:. ,c,•,....•:::.::.:-... 7.4..7.....• = = . n . CO *3 f:',..•...4:4.*:....::::::-:4. 0 ■•• .. • g 1 ZI ......y.g.•...e.-.., e X.I, (I) )4 ,C 1 '4 • :.e:C'',■*:•••;;“";• M LI) 0 . 0 . 7),,R• : U4 ..'..••••:'•'....)t.i.;;;:. , I g■r• Ili 7 • Cu CU — 4 • m co Cl) co '0 , • . , . 1 ). , 1. t ■ • \ .. . I . - , / ; /4 A , . • its) -.) -/I \_./ r-77---4 m o - > - r- o 0 o 0 f:.-..!. -• ''•-i!'.-.*:•.'t:-:.';',$... • '''' '...::-; :rkI1414.!ti.4.! '" • • ,....,,... 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' 1.75 '' '-'1:f!.k.i.4.1;; 4,..::!",::''.'''. ":.44`.‹ • 1.50 ••••• `.-',-1,,P.4 .-'74:ic4.-,4,4%,.#!:-,P : •:;*:3,, • O.. 0.1. -' ,- 0.15 '44,144!•'',_,,':,->,'''),e..ri,‘.-",44 ,..•.7rrt.,..q..tel,..-.A - +'-• 0.10 Ss, 0.00 ,„.■-- -- I-< - ' - - ":01T Bottom Conk)u r E Coll / fido F(TH (log transtomied) '^k•e. ."' ;„27.-- 4•44 1,%444" ..-'4%-:•- ■,___ 3.10 .:3 ..• .. .,„., . ii ■t.e" 1— 1.23 0.50 "1- / ...1" . 0.00 ill < 0.00 / ..... / ..........„........,...,_....... '''. ..-1.... 1,i, ■:......4....14 / ...--. _.... Figure 28. Bottom depth surface planes of Top)Total Coliform(log transformed)and Bottom)E.Coll(log transformed)for November 27,2000. °tangs Courtly Sarsitatron District,Cattromitr Health Dangers Arise From Pumping Of Sewage Into Deep Sea From Ocean Update September 1999 Vol. 4, No. 9 Paul R. Epstein, Center for Health and the Global Environment, Harvard Medical School. Tel (617)432-0493 An outbreak of cholera on the southern Coast of Bangladesh in 1992 may presage the risks posed to developed and less-de.eloped countries alike from deep-sea dumping of human sewage, according to some researchers. Scientists have noted that the 1992 outbreak was accompanied by an upwelling that brought deep-sea water to the surface near the Bangledeshi coast. In recent years, researchers have discovered a variety of pathogenic microbes, many usually found only in human feces, at unexpected depths of the ocean. Marine scientist D. Jay Grimes of the University of Southern Mississippi says that a variety of viruses that infect the human gastrointestinal tract - including poliovirus and rotavirus - have been identified in ocean water samples taken below 1,0000 meters (3,300 feet). In the late 1980's, Sagar M. Goyal of the University of Minnesota isolated gut bacteria from samples obtained as sewage-sludge dumping sites more than 170 kilometers offshore from New York City, 30 months after the sites were closed to dumping. The bacteria were resistant to several antibiotics, showing that they originated from humans who were taking the drugs. Thursday,May03,2001 America Online:Jon V3 Papa: 1 • To: [unknown] , INTERNET:JonV3 @aol.com From: INTERNET:JonV3 @aol.com, INTERNET:JonV3 @aol.com Date: 5/28/01, 11:43 AM Re: OOG: Article LA Times Today Dear Group, below is an article from the LA Times today. Thanks to reporter Seema Mehta for her comprehensive coverage. We still have a lot of work to do to persuade a majority of OCSD Board members to oppose the waiver, as well as the EPA and California Regional Water Quality Control Board to not issue the waiver. We need Letter To the Editor in response to this article. Send letters to: ocletters @latimes.com. Also, please calendar the 4th Wednesday of each month, 7PM to 6PM, for the Board of Directors of OCSD meeting. Here is where the rubber meets the road in lobbying the directors and speaking against the waiver in the Public Comments Section. Thanks. Jan Vandersloot (949) 548-6326 Monday, May 28, 2001 Home Edition Section: California Page: B-1 A Stink Brewing Over Offshore Sewage Beaches: O.C. agency is exempted from thorough treatment of waste. Many want reprieve to end. By: SEEMA MEHTA TIMES STAFF WRITER Angered by a rash of beach closures and public health warnings, environmentalists and some coastal officials are demanding an end to a federal waiver that allows the Orange County Sanitation District to discharge moderately treated sewage four miles out into the ocean. Though many pollutants have been removed, the effluent still contains high concentrations of bacteria, human waste and other organic matter compared to sewage being piped offshore by the nation's other public sanitation agencies. "Sometimes I wonder how hard we have to get hit on the head before we learn that we can't keep treating the ocean like a garbage can," said Christopher J. Evans, executive director of the Surfrider Foundation, a San Clemente-based environmental organization. Evans is among those calling on the federal Environmental Protection Agency to refuse to renew the sanitation district's special waiver from the federal Clean Water Act--a law Congress passed in 1972 to keep the nation's waterways safe for swimming and fishing. The waiver exempts the sanitation agency from having to conduct a more rigorous, and costly, treatment process that would remove many of the contaminants. A local battle is brewing over the exemption, which is up for renewal late next year, and several Orange County coastal cities are expected to lobby heavily against it. In Newport Beach, the city's harbor quality advisory committee recently voted to oppose the waiver, and the City Council will probably follow suit, said Councilman Tod Ridgeway, who also sits on the sanitation district board. Huntington Beach and Seal Beach are expected to take up the matter this summer. Topping their concerns is the massive plume of sewage formed at the sanitation district's ocean "outfall"--effluent created by the 243 million gallons of waste water from showers, dishwashers, toilets and sinks that is piped out to sea each day. Some researchers suspect that the plume may have drifted back toward the coast, causing the devastating 1999 shoreline closures off Huntington Beach. Additional Treatment Could Cost $400 Million. Vocal environmentalists are already demanding that the sanitation district switch to the more rigorous treatment process similar to treatment standards adopted years ago by almost all of the nation's 16,000 sanitation agencies. The cost, however, would be enormous--upward of $400 million. That alone makes it a difficult decision, some sanitation district board members say."We have some environmentalist tree-huggers out there who, instead of 1 using common sense, always want to overreact with a big clobbering of the taxpayer, " said John M. Gullixson, a sanitation district board member and Yorba Linda city councilman. "My job is to represent the taxpayer here."Since 1977, the EPA has been allowed to grant Clean Water Act waivers to agencies that discharge effluent into deep ocean water with strong currents--if doing so would not harm the environment or public health. Congress approved the exemption, thinking there was no reason to spend millions of tax dollars on an intense, full-force treatment process if it was unnecessary. The Orange County Sanitation District is one of 36 agencies nationwide that have been granted a waiver. The district, which services 2.2 million people in central and northern Orange County, is the largest waiver-holder in the nation. The district's first waiver was approved in 1985 by the EPA and the Santa Ana Regional Water Quality Board, which also oversees the sanitation district. Both in 1985, and when the waiver was renewed in 1998, there was no indication that discharged effluent was causing a problem, said Kurt Berchtold, assistant executive officer of the Santa Ana board. There wasn't much controversy either, he said. The sanitation district had queried ratepayers about adopting the more rigorous and costly "secondary treatment" sewage process, and most were against paying the additional costs, Berchtold said."Whether they would get that same answer today--I don't know," Berchtold said. "Obviously, there's a lot more focus on coastal water quality issues in general and bacteria contamination in particular. The public seems to be much more sensitive to those kinds of issues than they were five years ago."An EPA official declined to predict whether the waiver would be renewed."In terms of EPA, we're not either for or against waivers. We're just applying the law and regulations. If it meets the regulations, then we'll make a positive decision, " said Terry Fleming, the environmental scientist at the EPA's San Francisco office who has worked on the sanitation district's waiver for nine years. The final decision may, in part, hinge on the results of a $4.1-million study being conducted this summer. The study, funded by the sanitation district and others, will test a theory by UC Irvine researcher Stanley Grant that the district's sewage plume is being brought back to shore by internal waves, tides and the ocean water-fed cooling system of the nearby AES power plant. Environmental activists say they already have evidence that the plume is causing harm. A 1996 study showed the plume had moved inland, reaching less than two miles off Newport Beach and about two miles off Huntington Beach. Another study showed that fish near the outfall have liver lesions, says activist Jan Vandersloot, who organized the Ocean Outfall Group, a grass-roots environmental group. Robert P. Ghirelli, manager of technical services for the sanitation district, said it's impossible to draw conclusions from those studies because they lacked adequate sampling and comparative data. The effluent discharged by the district is a 50-50 blend of waste water that undergoes primary or secondary treatment. During primary treatment, settling basins and chemicals are used to remove most solids, and "scum"--mostly oil and grease--is skimmed off the top. After this, some of the solids have been removed. In secondary treatment--a stage used by the vast majority of the nation's sewage districts--microorganisms eat organic wastes, removing even more solids. The district's critics want the sewage to undergo both primary and secondary treatment--the standard for the vast majority of the nation's sanitation agencies. Officials Waiting on Sewage Study Results. The majority of sanitation district board members favor the status quo, though they offer one caveat--wait and see what the summer study reveals. Board member Brian Donahue, who represents Stanton, said that in the past, the sanitation district has passed environmental requirements "with flying colors, " so he questioned the wisdom of adopting a multimillion-dollar treatment process before all the facts are in."We don't have any proof yet, and we're not going to do anything to jeopardize what we're doing now unless we have proof, " Donahue said. Others agreed, but acknowledged that if this summer's study determines that the sewage plume is causing health concerns along Orange County shorelines, the district will take appropriate action."We're dead serious about keeping those beaches clean, " said sanitation board member James Ferryman, who represents the Costa Mesa 2 Sanitary District. "If we find out our plume is the cause of the beach contamination, then we're going to do something very proactive about it and try and solve it. If it means secondary treatment or tertiary treatment, we'll do what it takes. As far as I'm concerned, it's all premature now."If the plume is found to be the culprit contaminating the county's shoreline, installing a secondary treatment process may not be the best way to solve the problem, said district spokeswoman Lisa Lawson. Other less costly treatment options available include disinfection, ozonization, ultraviolet light and microfiltration--all of which are being reviewed in case the district needs to change treatment level because of this summer's study. The district's critics say it's money--the about $400-million price tag to install a full secondary treatment process--that's the main sticking point. Vandersloot says the sanitation district has that in its reserves, or that it would cost a nickel a day per person."It's to everyone's advantage to have a clean ocean, " he said. "What we have to do is persuade the board not even to apply for a waiver, but to do the right thing and plan for full secondary treatment of their discharge."Sanitation district officials say the reserves are needed to fund about $1.5 billion in capital improvements over the next 20 years. If required to adopt the treatment process, ratepayers would be socked with the bill: A family of four could pay $75 per year more, and some businesses could be hit with an $120,000 annual rate hike. This isn't Southern California's first battle over sewage effluent being pumped out to sea. The Natural Resources Defense Council in Los Angeles and Santa Monica-based Heal the Bay fought, and helped win, the battle to make sewage plants in Los Angeles city and county switch to full secondary treatment."The one truth about environmental and public health issues is we're frequently surprised that what we thought was safe and effective is in fact not safe and not effective, " said David Beckman, a senior attorney with the defense council. "There are many good reasons to upgrade the [Orange County] plant based on what we know today." PHOTO: Partially treated sewage from Orange County is discharged into the ocean from one of hundreds of small portals off the coast. GRAPHIC: How Clean? Los Angeles Times Internet Header Sender: JonV3 @aol.com Received: from imo-m02.mx.aol.com (imo-m02.mx.aol.com [64.12.136.5] ) by spdmgaaf.compuserve.com (8.9.3/8.9.3/SUN-1.9) with ESMTP id PAA26391 for <SurfDaddy @compuserve.com>; Mon, 28 May 2001 15:43:41 -0400 (EDT) From: JonV3 @aol.com Received: from JonV3 @aol.com by imo-m02.mx.aol.com (mail out_v30.22. ) id o.104.406f294 (17085) for <JonV3 @aol.com>; Mon, 28 May 2001 15:39:57 -0400 (EDT) Message-ID: <104.406f294.2844038c @aol.com> Date: Mon, 28 May 2001 15:39:56 EDT Subject: OOG: Article LA Times Today To: JonV3 @aol.com MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="partl_104.406f294.2844038c_boundary" X-Mailer: AOL 6.0 for Windows US sub 10519 I 3 • ,. vlvv YYGaY G, . .r.+v.� .v,,.v.... _._ r atilt; i l JAN D. VANDERSLOOT, M.D. 2221 East 16"Street Home Phone (949)548-6326 Newport Beach,CA 92663 Office FAX (714)848-6643 May 10, 2001 • Re: Proposed Sierra Club Resolution Against the Orange County Sanitation District's 301(h) Waiver RESOLUTION The Orange County Chapter of the Sierra Club recommends the Sierra Club oppose the • extension of the 301(h)waiver being sought by the Orange County Sanitation District • (OCSD). Background:The 301(h)waiver is a permit granted to the Orange County Sanitation District by the EPA and Regional Water Quality Control Board. The waiver refers to an exception to the standards of the 1972 federal Clean Water Act that mandated that all sewage discharged into the waters of the United States receive full secondary treatment at a minimum. In 19'17,the Clears Water Act was amended to allow certain ocean dischargers to discharge less than full secondary treated sewage. Secondary treatment refers to a process where most solids,bacteria and viruses are removed from the sewage prior to discharge. Primary treatment refers to removing larger objects • from the sewage stream only.The Orange County Sanitation District applied for and received the 301(h)waiver in 1985. It received a 5-year extension to the waiver in 1998,which expires in 2003. It is currently seeking another extension of the waiver in 2003.The waiver allows the OCSD to exceed federal standards for TSS total ( suspended solids)and BOD(biologic oxygen demand), both standards being 301'11g/liter for 30 days average. Currently,OCSD is discharging 240 mgd(million gallons a day)of a 50/50 blend of primary and secondary treated sewage through a 10-foot outfall pipe extending 5.1 miles off the coast of Huntington Beach,CA,200 • feet deep,creating a sewage plume of 6 miles by 3 miles by 100 fed. The sewage:is discharged through a 6,000-foot long diffuser pipe with 500 ports. This diffuser pipe extend:,from the end of the outfall pipe north up the coast. OCSD discharges a total of 15,000 metric ton:,a year of TSS a year,in concentrations of 55mg/l of TSS and 80 mg/1 BOD. The permit allows a maximum of 20,000 metric tons of solids a year. The recently approved Groundwater Replenishment System (GWRS)will divert up to 100 mgd of secondary treated sewage to the Orange County Water • District(OCWD)from OCSD for tertiary treatment,disinfection,and injection into the • groundwater basin under Orange County for drinking-water use. The brine from this process will go out the outfall pipe.Because of growth,the outfall discharge in the year 2020 will still be 240mgd,with increases of primary treated sewage to 80%of the outfall,and TS5 of 17,000 metric tons of solids into the ocean each year.The sewage plume is thought by OCSD to remain trapped offshore by a temperature thermocline that caps the plume and prevents is from reaching the surface of the ocean or the shore. It moves up and down the coast from the end of the discharge pipe. The permit granted by EPA and RWQCB is conditioned by a monitoring requirement that OCSD show no harm to the environment or the public health wi h annual reports These reports still show effects on the environment in finding fish liver lesions near the outfall pipe. The reports omit evidence that the plume may reach shore with elevated bacterial readings in 1996. In 1999,and the years afterward,the City of Huntington Beach has experienced beach closures and beach postings due to elevated bacterial readings. In November,2000,a study by UCI scientist Stanley Gram,put forth the theory that the warm discharge into the ocean by the AES power plant in Huntington Beach pokes a hole in the thermocline,entraining the bacteria • from the OCSD sewage plume and drawing the bacteria to the beads.This theory is being tested d • (10 ♦.IUU W oivu. hOJ\JIJ\IVY LV\I . JAN D. VANDERSLOOT, M.D. 2221 East 16•Street Home Phone :949)548-6326 Newport Beach,CA 92663 Office FAX :714)848-6643 in the summer of 2001,with a$4.1 million study conducted by OCSD. The thermccline is largely absent from October through April each year. The OCSD analysis of movement of the plume does not account for upwellings or internal wave events that may bring the plume to sho:•e. The cost of full secondary treatment is said by OCSD to be$400 million.The cost per person in Orange County would be 5 cents per day. For a two-person household,the cost is$36 per rear and for a 4-person household,the cost is$75 per year. The argument from OCSD is that it is not so much the cost,but the land disposal of increased biosolids(sludge),increased air emissions from full • secondary,and increases in energy required for full secondary,that they want the waiver. In April 2000, Chair Norm Eckenrode of OCSD asked for a feasibility study of full secondary treatment, based on public comments. Orange County ratepayers pay approximately$80 per rear for sewage service. The average bill for other ratepayers in California is$185 per year OCSD serves 2 8 million people and 650 industrial sources in a 470 square mile area Pros: • 1 No waiver means full secondary treatment of sewage consistent with the 1972 C lean Water Act. 2 Full secondary treatment reduces all elements of pollution in the ocean discharg.leading to a cleaner ocean 3. Full secondary treatment can lead to ultimate tertiary treatment of sewage and reclamation of all sewage water. 4. Disinfection of sewage is easier and more energy-efficient than disinfection of primary treated sewage. 5. Fewer bacteria and viruses in sewage. Full secondary reduces bacteria by 95% 6 Cleaner beaches. 7 Healthier fish and other ocean creatures. Cons: I Cost to Orange County ratepayers of 5 cents per person per day,$75 per year for a family of four. 2. Increased biosolids disposal including increases in truckloads of biosolids per cay to land application sites in Riverside, Kern,Kings,and San Diego Counties 3. Increased resistance in disposal-site counties to biosolids application in their county. • 4. Increases in air emissions from secondary treatment facilities. 5. Increases in energy requirements for full secondary facilities. 6. No monitonng requirements if no waiver. 7. Possible increase in odors from treatment facilities affecting adjacent neighborhoods. 8. Other treatment methods including microfiltration,new technologies,and disinfection with • one and bleach can be used to disinfect pnmary sewage while still retaining the waiver. 9. Full secondary only removes 95%of bactena from sewage. Further disinfection will be required to achieve 100%removal of bacteria. 10. Microfiltrathon of pnmary treated sewage will remove solids to below the TS3 standard of the Clean Water Act, but not below the BOD standard. Mrcrofiltration will still require a waiver from BOD. 11. Disinfection of current sewage will cost only$30 million, while full secondary requires$400 • million. 2 r14-zit }�o'n .'.. ' lw•t' t; . t,.voi, _ 'I..,,-y�` ,i -,+.-. w��y:v‘.,4-i.4,3-:,,,,:-:-.. t. ...--r1`It:7Alty : -�1Dt41.,pf A'`..L'.,. - tr-.w . . . .1..iq "'o"1;-5.4N;..A ,� ,I.1,t44'y y ti} .,,,v, ?'j 1�yj�tl + s k, .^r ' YM it, 1 - 00 vo ig .umb 3 �` ` ' Di ''' ° �V ,Ix 11 t f.: , .tf�" �?C •/ ,., A ,... a trA .4t,f ..4!.., !'.�a∎, , ;_. r .d1- ' ` A' •. '1 :• ,. ,�:, '-re as r ` 11�, rf9•ty f.^ .�f, r ti'St rt,r�. iF l !,c S' .. �1rr'Ar t''c`"iL' s- �,.`••4 f,k` k 4� - •7- �Pg"A ' •�Lt S , „,4: :. .' M``y�"#. It-,"''-';' r'r .t,}� '" ..'uc4. ? 14`6Iv y+ ki.-44A:•�LM1,►8:.:44,. 3 .4 ,; .. C •. f`n•. i01. r t '. „ 4,,f4.14-,.,.7 rti; . - r 1. ?. "' !'Y. x c„. .4 y t,} rrT-."... # ...i.;r f� 'Ss ' : ' 6 ({ .�'g#- / t� 1 'kM� '�3nf �a.,.r,, '. 't.• re( ''';4:;.-",14...;.;.4..',:;:, 'f } '� t t. r, 1c' A� ;'z :.,tit. .o.... ,n r "4--",-.71,4::::!- ' t El 4.. i :^-IP.��;.' ,.i�.X60; v ,4:S ill-l'? ":.-.:.;:,..4.11,!.v ti � c'�t,� F -'�� . �'� S.?fv -h y-'` P i.,+�t.r hK,+4>r�� �r;�:r�Vd2' ..:-.,-,t,„„...:„.' tl`f' pct+ r/'a . _•!tAj fa(;i 0 �� •. __� t('. r�� +l `" ;. `k�,W 4'n��? i litlf • r t.rl te..49 . A /.,, fir.`_ 1;•$:...-,.?:.,, :. ''a; c ��i 3 •,, »,34wM ,.:',4-,C rly':% �, ` Ay;r i 1.y t � „ - .1 fl `j A newsletter of Surfrider Foundation's Huntington/Seal Beach Chapter 'y a,f r ', "1 1. t t `�ri, r1 .. . -J -i. *;;',."1 :..."--4;34;,4W v T r litk. . ' .h,. k ~ tr .. K ,' ? r f �r �� r: ep�� , v r°°c ' < to '++ s. tt Volunteers:,Needed: fors 4Y - � � t'' , . _t :: ti 2, ''''''':1-'5''s -w. �xy i• cents$, bay ,lam' -. r `Huntington' BeachrA , t , :.�� ' � "'t'� :' �'. t,f .` . z . .: �: �� . � z , tz � ;. 1; 50 month .Yfix ?, a 1 � rt v t• + y SX Contamination.'Stud y .Phase r r y , '�,��, � + ra z.`s�C''^ ;rJk� �t pa, ••:sr'�1. ��' S�•.� . . . .. . R • 1 si14 At fT P , k:l� ��'" 3�- . ...� r . r+ +, III . • 2 J , .: .. ;r;,1" ' , �', ' � - ,Five cents a'day or:$1 SO::��onth•to;4;•-• ave sewa a'~. gti . •Chapter members now have an opportunity to assist treated before it is dumped into our ocean 1. )range;• Conty Sanitation District ` (OCSD) -this '.- r '' <{ y F summer in` this very impo.rant scientific study .^This is what ,it would`cost -for ;every'" person in the (Huntington.on . county to have"secondary treatment that would clean w ( gt Beach Shoreline contamination sewage-into drinkable water before it is dumped into investigation). This near shore Water Quality study is " the ocean. ' , _. only one ' component of a very complex:. and - t, comprehensive workplan recently :can' i i P p y completed by the If any of you members �go your local city 'technicial staff at OCSD. In addition to the May ' representitive who`•• is '. on,,..: the Orange'` County 21-22 (24 hour) sampling schedule described in the Sanitiation District Board please do so to'state our:-:• - attachment,the tests are to be repeated over a 48 hour concerns: "The 301h.Waiver is not complying with period (hour samples) durring the peak tidal cycles the-Clean :Water Act which requires'full secondary .,. . for the following 4 months (June 4-6, July 5-7, July treatment of,Sewage before being released:into'the-. 19-21, and Sept. 15-17. Complete details of the ocean. It is, not giving the' greater dilution. and workplan can be obtained fro the OCSD Web Site: disperstion with large tides and substantial currents as http: //www.ocsd.com and the Ftp Site: required by the Clean Water Act. _ //ftp.ocsd.com. - We Can not allow this dumping into our ocean to': Although no training appears to be required. The lab , continue. (1);,.301h Waiver has not complied with ;. work weill be carefully supervised by qualified Cleari,Water.Act and the State Porter-Cologne;Waterer:; OCSD personnel, they would probably prefer Quality Act standards. (2) ''Has .not protected the wolunteers with some labe experience, preferably balance of native population of,fish, shellfish and with the Idexx microbiological test kits. (some of our wildlife, (3) Nearshore & Beaches as posted, and ': chapter members have this background). closed due to sewage related items. (4) Has not had Let's show our support for this project! an extensive adequote ocean monitoring'program.',(5) . No rigorous pretreatment program in order to meet Call Holly at )CSD (714) 545-0208 for more secondary water quality equivalency for the removal information (Volunteers will be paid $10 an hour) of toxics. (6) Protecdtion of public water supplies. STOP THE DUMPING IN THE OCEAN . Next General Membership Meeting June 7th at River's End cafe in Seal Beach @ 7pm. Program Bolsa Chica Wetlands Restoration , H.B.Councilmember • Debbie Cook Publication of the Huntington/Seal Beach Chapter of the Surfrider Foundation ;may::,, ,.„,, s t r5 � '4, , °'!bTr` `�, Y..>itpt-4.-+.K• ri.,, .k-x M"- ',,,,„1,",:,.., .. . ; •j-;- .;:J.e,^ fry( Y 1 �' Sr iY �r���tY,?� r+Y�j t 'v �` ..._ . ,... .., I, ..u,4i•,„, •-•-','-, ':(1','.-''.i,' .'''''!itti.4itNk4." ' .' ' -' ' - ' • - .., •- •.; - -:'-• .-,1,•!Y,%;/'i, -e.',', ::.1".:::., - -,..J.:•,4:_. 4. ..,.!*.fi,f-i4r?i'.;.P."; .7!•,t. .V.6. '';'4-;..r.4". - 1*-:;4 : ": .....:(,....- .., 4.:,... r. -77,£..77.714-5AZ,." • .1';.ii! ' -ThAr,;h, .%. e•„..d4;AiV -,1!"':-.-,-- -'...,‘••,-',:•li:".•.:,,-7,.•: •!-,:•:, ,;-• - • , .•• . ' v •I • PUbliCailoif Or the'fiiiiiiinlicin7Seif Beach.C.Itapter of;the Surfrider Foundation . . . - of Sewage 6 miles long, 2 to 3 • educational seminars. over the. • . miles wide and a .100 Seet deep.;•. past.4 months and hasspoken up Ocean Outfall Group This sewage plume ... theoretically is . at the•OCSD.Boarcl;Meetings on - ' • • ,: capped :: by.,: ;a. :temperature •, the " 4th Wednesday,.'of- 'each. (OOG) . . ,• : therrhOcline that prevents it from . month. —-. We • have obtained . • coming to shore; but the theory ,. progress. The Chair of the OCSD , OCSD 3011-f Ili/Giver ...-- has been' challenged by a' UCI • Board has recently recommended study in November 2000. This a feasibility ..study to,sgo to full , The Ocean Outfall Group (OOG) is • ' theory, by UCI Professor Stanley . •secondary. .Crtyouncil members a group that formed in December,... Grant,: proposes that the plume . from '''Huntington: Beach ••have 2000 opposing the Orange,Cotinty.. .,, does come to i shore' because a spoken;against the waiver Sanitation District's 301(h) waiver ' separate warm-water outfall pipe.. City of Newport .Beach's Harbor that allows it to discharge sewage ;'•:into the ocean : from the AES " .Quality Committee has'voted 0:,. into the ocean off Huntingtion - energy plant in Huntington Beach' - recommend the' NeWpOrt Beach Beach that is not treated to Clean '. pokes a hole in the thermocline, : Council to oppose the waiver. The: • Water Act standards. The Orange ' entrains the bacteria, and draws waiver .'application., process is County Sanitation . District • ,it to the beach, thus explaining ..lengthy,, but now is the time to (OCSD) discharges 240 . million ,,;, q1e 1999 beach...closures and : lake action. Surfrider is probably - gallons a day of sewage from a ' 'sporadic'/ beach -'.--: postings.= themost affected by.sewage in'the• population of 2.4 million people...::. Moreover, the thermocline is not .. • water, along with the other people The discharged sewage is a 50/50 , always there. being,• largely who.swim in the ocean. .,,• : blend of primary and secondary absent from October through :.••_,What can you.do".?. ;Take action a-t treated sewage that goes out a 10 ''' April of each year. In.addition, . your local neighbOrhood; formally •-: foot-wide outfall pipe 4 and a half•-.., internal waves and upwellings . . making 'resOlUtions opposing the; miles off the coast, 200 feet deep. • rimy carry sewage towards the 'waiver snd send them to your city' Primary treatment means that beach. The plume is not static - - councils, - OCSD,:',4-7:-EPA',--.4.. and floatables (rags, bottles, etc.) are that stays in one place,'but waves .. Regional;Water Quality Contra...jr .. skimmed off .-, the sewage. around in the •ocean;! tending - Board who :perm ited..thecVliaivei:4; Secondary treatment means that north, but also -going -,, south . Come to the 00G meetings...,„Send:most of the solids (kaka) are• .,.• towards Newport Beach.-;.,•,- , , • 'hie an e:rnair at=..iciziV3riaolcOm' '. removed, along with bacteria and ..'. The Ocean Outfall Group (00G):-. to get On the Iria.iiihg lisC other ' pathogens. The 1972 : was formed to oppose.the waiver, sure representatiVeg':*terikeach ..:: federal Clean.Water Act mandates • instead k' OCSD • cr'' ''bd§D'i3' d meeting,' .: '' instead as ing C D to treat its . and every .• • : , oar ,:. that all -' ..sewage . undergo , .'sewage . to' ''' full':''' Secohdary ' 4tl'i'• Tedrie-SdaYseclf'iVilih' 'IPM ,.; secondary , treatment before .. - -.%.. treatment at the very least, and to kir publidCoMmenii:1-..:0Wiite.• • discharge :. into - a waterbody.. • even higher levels-; of treatment - letterseto'-_;the,4:eclito6.a.C.'.theLk.f .. However,,a 1977 amendment tcr':'Stich'''as tertiary treatment at the ..TirrieS; -pearige..cqurity',..;RegiSter;.;;;;',,,... the Clean Water Act allows 9FP-11::"''.:',Veri.,..:?:best. '.•• :'Thik,;:has'i. very J.:•-•'beganiie .-Speaker-s;:io;:,::the;1CitY4(i'. dischargers tO,,get a '"vaiYer, .t4e:':-:- important ::. consequences -.•-.. to'!•::.,•,'COuncitS,•[ inclUdinir.i.hlarl d24;1...Cit&i..:".,': so-called 301 (h)..Waiver, so,...that: .Surfers who'are out in the waves:',:',:e(iiiikils;'4:T .:"Siriee'48tSq.reOun:.0.i1W, not -all ' sewage---is .;'seeokiaaiy-''.7..'.and•••!'will . be: eXPoSed.F'Id. the.'s!:-,:ii.1"eilib6iSt'ffCifil'7237Ciiie 'rhaii-e,'Uli: treated. : OCSD has :applied; for' -: .'bacteria and virfiseS7'and kaka:,,4,:the.:board,-of• directork:oti.00SII:e4,;• and obtained this Waiver:,since particles from 2:4 iiillidir.peOPle..,:: ::...the':,..OStcif:filll:SedOndary.1:RadOut',1.,i,,•.;-:., 1985?.with an extension in::199. 8,.., These pathogens pathogens Carl: Caii'Se7;eYe,••:::-.. -$400-MilliCin':;Whidli'firarisialeWfd',;':::i.."-'. and they plan.again to get this : "ear,-nose and thrOats.::iiifectiOnS7;:.'7A;nidkel:pet dayer personfi:-Trus_cf,,'-' waiver ,extensiorr.. ..when their.''. boils, vomiting and diarrhea Whefii"- 1:is a illait.:ii'riae':te:/*.Proi;4::.6IeaAt.. ...::... . permit expiresiri:•• .'2003.:. '' ' *d. ' h :1.''''. . --6 ,f fi''' 144,,, ,.). 4:,..,, .'.'-'.. .'' :: '-yOt.".`-`..are . blissfully ,•.ri riding. the ..n, ut. c!,Yi,aIYSEVS04•1•ngtpp' The OCSD discharge comes out.ai'• :..vbia g waves, not knowing what's irf:the:';';',..f:. be renewed'4diniZtijorkiii"*e::f0d.;y1....:31:-' : diffuser from the •end of the 10 • , . • . . ,. ..., ,.., __,.,,,•today water. . •- ,;.;,:..:;. --;-'. ;;-. - action ay... ..::r..,1:1,14,4?4,,, 4.,,_....,,, . 1.,t. • .- foot outfall pipe:extending. north,‘ . • ., : • . - =. ,• ...:., ..:•:„.....:.,: i:. .-,,,,c,•----.:•:t.;"•' -.''.4!;,‘,?..t.4,.*4.4tte.-e•- :;" --W-.(; ...00d'.has : been meeting.;;with •by jiiii.D Viiiideilbilo,t;.1116! %.',':,;k:::`: up the coast. .1t creates a plume .. .ots-b staff fin' a , senes . of • . - . . .. . .. , ''.r'::•. ,-:4,1' .....-' '. -‘,! •:. f.,..ra- :■; -•;:',..:;i11. -;`,4',--.:7• .-.,:.7....:;-- , ••,-Y.-3:-...,' ''''..”0.%•.' . '' ". '.'.., '' '',.._•'•''' • . -.. . ..,...4.,..A*::::. ..; .:r4.,..i.;-, ,:-7',f.:•-•:,2„,-,.r..-514,-,':;-,1:-L:,-- : • _ .••,...:•:,..t.,,-!,-.,-;-:•-•,,..-;,--•. 'r;-': ,'!:..:, 0,4aeis- s,c-,'0•:9';-4.;t..-51-1 ,4,0 •,;;•tig'0.-1,,,:e",-;--"-;".,.',I.•••• - 1 1 .. . z: ,-, -- . •-;.,'-', . -, • .:-,,-, -',.:.,: ' .`i.'4r-- • . . ':' -'..;, -'+',. ' '-. - ..: '.,.,1'';,;,--;'....' • •'‘,;',--4,4. :•tr: . ,- , .- . .--: , • -. . ,,,,, ..i.,.. . ,e, t ..e 1,...c i,,,-,,;.g7;R.N-41,,,, :..,A . -,:, _,,,..j... .),...., .,., • ci,l...tt ..,..tly,,..4. , .„, . ... , .,- sz:‘,7-..L.,,:___ • .e...,,„x,...-.,.,«.,,I.::1-(:;:, ...-.! I I-,.. ''. ' - . .".'(''''i':' . .. ' ''''Siiirtile . Br' ' 'eigNeiii'teriF"' - — s - ' April/Jude‘2001.t,' . r r- reak . s t -----p---p.,,,' +13-R5•- ,Afpage-S,.- r•-",:w. 4:21,,,„40,....,..#,,,,, . .,:..,..,,,:. •: : ••:. ,. ..,,,,,,,.:,.,..-•:•,..,-.,,,,...:::.„..,;,,,;:.,......-;,;Kri. ..;:_izyyr.t,::,,,....: :;:. ,,,,,,,,:;,...(.v.,.?.nr:,, r, ,. .. !,.....:-,. ,.....!,,I. 1 , ;-.•,,,,.i v :..,,,...,_ ,1::.:-.•.-:, •.,:/:•,,,,,I., • V 'tt " • B20 oc. SATURDAY, JUNE 9, 2001 ti r ; ;,.....%• :0:1 . 1 .' r y � , f. r *; /:; JJOHHN N P.CPAURERRNOELR .. r,. /, „! a ' r pubisher,PresidentaL n d • t. , ” :s,, ,. x o l,t i e C1rg-F.ti-oJJker, t ic � o $ k ,x i s' ♦ . �� 3•� ')S `1 •-9f r ��`Q`' � t' f'DEAN BAQUEr � t w: , ManaglilgEdltor ITS 11: ` 05 i. :/ ' . „.. 'r . . • '. _ :JANETCLAYTON 's .=:.iy,�. `t..••{«7 t ,r t.',■,!!l" EditorjtheFdioorlalPa,es Y ~ r ' , ' .i 1� , y. � - DeputyManagingFditors 7 l; ! S S i .r#£,e /'•..• s . . JOSEPH HUTCHINSON'., s]'• T .Tw s '2•i, ':, . }i. . .. ♦ . . .. ,3 : LEOCWOLINSKY , "+ •▪ _ Aneh3 : +f:rr AtankNaaogingFdltors' sw� i � �� aJ OHNAR7HUR ..?4 r:'t' +r MELISSA MCCOY ",r •' , r .,JOSEPH M.RUSSIN ''.'"Fc!i?. a fl ,,,',-44%,(4'.;',•r1 ' i:. t' FRANK DEL OLMO h.i'.R3t148:: r o r..'._ .i ' " ' s ' r is ARDI7H HIL IARD ts .,.. ,, . • y�i '' = Of Summer..'and:;S: yge a � :.: .�• � .. ..„ "'� • "S urfers shredding the breakers and par- questioned the model thatlhad predicted the'..!: .., ,- ents helping toddlers slosh through the offshore topography::would-trap the.."moder : �' . shorebreak have every right to ques- `ately treated"sewage and hold it at•a safe dis. tion why the Orange County Sanitation:. tance. One theory the•district will test this 3` ,District is allowed to pump more bacteria,hu- . summer suggests that a nearby,power plant's.::.;, . 1�- ''man waste-and other organic matter into the suction of ocean,water.to cool equipment is , ocean than most other.districts.The answer is bringing in sewage too. .,; ; • ''' • ` .- ; '.'a:federal waiver that holds the district's waste To its credit, the district has promised to -.T.-.A:7-1-:',.was 'water;treatment to a less rigorous•standard take steps to improve treatment after the re- •4r under:the Clean Water Act. It's a waiver that sults are in,but piecemeal measures won't do. :. no longer makes sense: At some point,common sense must takeover, t `Orange County has grown enormously since ; and ratepayers will have to bite the bullet and <'-_ the Environmental Protection Agency first do the job.right.Estimates put the cost of the ::: granted the exemption,one of 36 nationally,in advanced treatment that.'removes more'solid ' - "-.4 1985.Today; its sanitation district is the larg- waste at more than $400 Million to build new • est holder of a waiver anywhere. It's time for facilities and $15 million a year in operating`.;:: : the EPA to make'sure Orange County subjects costs.It would be money well spent. , •• , -.I its discharged water to the same treatment Orange County's beaches withstand urban: standard as many other densely populated ar- runoff from the Santa Ana River and bacterial. eas,including Los Angeles. waste from water fowl in the Talbert Marsh The waiver expires in 2003, and scientists area. The hundreds of millions of gallons of rr and :environmentalists are already voicing sewage, discharged .daily from the district's •'.` •.:: concerns about the wisdom of piping a plume outfall pipe should be as clean as possible. of •partially treated sewage four miles offshore The ways of the ocean tides and currents and hoping that it won't drift back to plague are a mysterious wonder.But every beachgoer : - swimmers. In 1999, a baffling series of beach knows one thing.intuitively: As resilient as closings threatened Huntington Beach's this great resource is,we can't afford to treat it ' _ economy. Last fall, UC Irvine researchers as a sewer. , . Letter No.1: The LA Times has the right idea. It is only common sense that the Orange County Sanitation District treat the sewage to the levels mandated by the Clean Water Act, which is full secondary treatment. No way should they get away with polluting our ocean with only partially treated sewage, using a waiver as an excuse not to treat the sewage to the proper levels. Every time I go to the beach, I wonder if I'm not being exposed to sewage in the water from 2.4 million people in Orange County. This is a disgrace. The Sanitation District should go to full treatment of its sewage now. Letter No.2; It is incredible that the Orange County Sanitation District is still able to only partially treat the sewage from 2.4 million people and discharge it out into the ocean under a 301(h) waiver from the Clean Water Act. This waiver was supposed to be only a temporary measure to give time for the sanitation districts to install the necessary equipment to do full secondary treatment of the sewage. The waiver was granted in 1985 and was supposed to expire. However, the sanitation district requested an extension in 1998, and now they're asking for another extension in 2003. When will the sanitation district do the right thing and treat the sewage to the full extent required under the Clean Water Act? The Times is right. This waiver no longer makes sense and should be revoked immediately. Letter No.3 Orange County is one of the wealthiest counties in the nation, but we have a sanitation district that treats its sewage to one of the lowest levels in the nation and then dumps this sewage into the ocean right off our coast. Why is this happening? I, for one, would be willing to pay the required 5 cents a day, to make sure my sewage, and everyone else's sewage, is treated to the right levels before going into the ocean. I want a clean ocean for myself and my children. Letter No. 4 Orange County Sanitation District has a motto: "To maintain world-class leadership in wastewater and water resource management" (see ocsd.com web site) . They must be kidding. They operate under a waiver that allows them to treat the sewage from 2.4 million people to less rigorous standards than most other sanitation districts, and then dump this partially treated sewage into the ocean right off our coast, treating the ocean like a toilet bowl. This is leadership? I have a suggestion for OCSD: "Do us a favor, get rid of the waiver". Sincerely, Name Address Phone Number Internet Header Sender: JonV3 @aol.com Received: from imo-d08.mx.aol.com (imo-d08.mx.aol.com [205.188.157.40) ) by siaaglab.compuserve.com (8.9.3/8.9.3/SUN-1.9) with ESMTP id OAA24305 for <SurfDaddy @compuserve.com>; Sat, 9 Jun 2001 14:10:30 -0400 (EDT) From: JonV3 @aol.com Received: from JonV3 @aol.com by imo-d08.mx.aol.com (mail out v30.22. ) id o.107.10b3a3b (16639) for <JonV3 @aol.com>; Sat, 9 Jun 2001 14:03:34 -0400 (EDT) Message-ID: <107.10b3a3b.2853bef6 @ aol.com> Date: Sat, 9 Jun 2001 14:03:34 EDT 2 I • . - •,,,,,,z.,,sis,' . - .•,,,Y.•(,:,,,.. - . .,,••-...,„,, ,, ,- ,,. - -• - . • . . - -- -,-* ' . • ,,...4;:, --',-...,. -s 4. ,,••■.",,,,!,":14.,4' 'Arci •,, .. Itto.?..i'i. •,, ' 1.!-},• ..- I „„1,:v,, Al;. ...,,,.',--, ..• •';•,.1 •,:l • <At . ..tr..)........111.. , ..... .- •-•,„...,- . •.. ,...: - .• ......, . - .. .• •,, . %Ill.., 4{it',.dii: *r• ; :.',, i•Pil., ii.,.4 c..r.,..: , . ,, ,,./;. zi, v. t p.........",....ciA) • .'•.1- • • ' -.' :'-%".;;;*?3,-....,c. -;r-:. . • — , ., .. , • . 2; ,,,.., .:. •.i...( t. . „• .-., ,T.,.1-4;.:., ',....k.I. .. j• . . .„ , 4.14V; -,r-, ' " ' i 1 -' .,. ' "';. ;1.AV , ' . '' ':;;'''' •'. .. 4 -.4 `.• ; ' - .. .4 . ,' . • .,-..'',. 1 . ' . , 4 4 - • ,„.... .. . • Commentary 2 I Sunday,July 1:20Ij1- .': ,. . . ,t,' . ,,,,.; ..);..EUIll • -' •• ;'- • .t,. •,-. ) -,. .••"•.; .,,..r. ... ; ., ,. Quote o e day . -i,, -- . -„..-1, .,...,. i •- ,,, , ..• . ,:, ;•, ' ' . 'r.; •,- . ..,. ' .*-1.• lo 1 - - :.! ..1,.., , - - A . ,.... . , , ., .,.., . ...,,-=,...., .•<v), r . -.V v •. .,,,.. ;,. . . - , . - ,., , . , Unless it's renewed;the,Internet Tax Fred "In the long run, the, ' expires on October 21.That means statei an • public interest depends on ibes could impose myriad new'taxes.But the -.mary sponsor,Rp.Chris Cox of Newport Be private virtue." , . §ponsored two new bills to maintain the tax tiMffl. H.R.1552 would extend the moratorlu JAMES Q.MILSON. •years,H.R.1675 would make it permanent, As has been the case for decades with cat • • • ‘ : , . ' -",.•••■ - -sales,taxes would still be allowed on sales't •• , , . , ,.•t:' , . , . . k . • EDITORIALS . ... Tracking e-■.- sources , f , t ' • ', • pollution•"4 • • • • • -ocean,:. . . • . hen it comes to environ-.. near-doubling of sewer rates for . ; - mental protection,Amer- homeowners. • . I ica i§approaching the , The district meets strict state . :4 r . ' point at which balance is and EPA water-discharge stan-. ' ., 1 . thrown'to the wind.If a given idea dards.In fact;it does such a good • promotes clean air or water,it ; job treating wastewater that it op- .• .. must be pursued-no matter the erates under a federal permit that .• . . . evidence,the cost or the degree of allows it to avoid secondary treat- , actual improvement. ment in many instances.OCSD is, A case in point is occurring in operating in a professional and re- - ,4 , I Orange County. sponsible manner.It is carefully. The city of Huntington Beach testing the waters.It has vowed to has been plagued by beach closings do what's necessary if tests show 4. because of high levels of bacteria • that treated water is causing con- s near the shore.This is a disastrous 'tamination. . '. situation for a city best known for But some environmentalists,offi- ...' its surfing and swimming,so local cials and media critics are focused , i t> officials and residents are right to on the process,rather than on the in I demand a solution. cleanliness of the water that's coin- F ( Of course,it's silly to spend sev- ing out of the district's pipes. • r eral hundred million dollars to"fix" They're oblivious to the costs;and a problem before anyone has a to the other problems of secondary good idea of what's to blame.Yet treatment. some local voices are demanding Not only is secondary treatment ... . just that, even though nothing has expensive,but it creates more yet linked the contamination to the sludge-which exacerbates waste problem being targeted. • problems on the land.Farmers take A. • 41ftitteMilliftr.4)brAtik.4MA40. .%11111111••41,3**PeicOtWoso-2,44,,,,--'24-sw:hPv•AeolikeetOgAIASAINAMIII00114010444•40AA0MMS110060111110 .!'''' fk, , :,,t.. • Cool heads need to prevail: "much of the county's treated sludge Initially,theories centered on from the sewer system, but fewer } Huntington Beach's neglected un-- agricultural counties are taking the derground infrastructure.Sub- • stuff.Riverside County last week sequent studies suggested the pipes . banned the use of O.C.sludge by .'" are not the source of the beach pol- farms. ''` lution:The latest theory, ';-- a UCI engineer, ry'offered by The Huntington Beach problem gineer,is that the treated may not be the result of any new '} sewage pumped out to sea by the pollution sources.It may sim l •Orange County Sanitation District P Y ie- is being pulled back to shore-. fleet tougher statewide pollution "='‘ "' dawn in standards that went into effect in " ",:; part by the warmed water 1999.Now similar levels of pollu-.' .. ; Nli released by the AES plant in Hun- `= tington Beach. ' tion that always have existed trig It's a plausible theory, ger beach shutdowns.That means - ry,and OCSD the problem may take more time '', is spending more than$4 million to and effort to pinpoint test it.Early results suggest the dis- One possible improvement charged water is not the source of high bacteria levels. would deal with part of the prob= ,,,A‘,;;,4 g The district es under no obliga- lem.Sanitation district officials be- ' . ' tion to spend millions to test ig lieve urban runoff moving along Y • the Santa Ana River could be a cul- theory that comes down the pike, , prit.Tests'showed treating that but it is intent on finding the ,. „runoff would reduce-but not elim source of the problem.But that's '•:mate-pollution. One idea is to not enough for some local residents . spend about$10 million in up- ,1 and pundits,who want the district • grades so that the the district could to expand its secondary treatment •- reduce the amount of untreated system to put all the wastewater runoff from reaching the ocean. through another,more advanced level of treatment that'tar targets nu-. It's worth remembering,also, . level of t solids. g that the ocean is not a pristine it. °� • Recently,Los solids. '', es city and ' place. "Whales poop in the ocean," county adopted a Secondary s. is how one observer put it.In other , azY Y words, the pollution could stems in ;;• -4' tem.There's no noticeable differ- ence in the cleanliness part from high concentrations of ,.",'. anliness of the water birds or sea creatures in certain ar- . before and after this massive in- eas that impact Huntington Beach:. vestment,according to Lisa Law-spokeswoman for the O.C.san- Clearly,pollution problems of itation district:' this importance need to be cor Yet thes riot tional facilities in reefed.By all means,let's leave.no Orange Colin stone-:or mound of bird poop- , • ty would cost$400..: . unturned.But tracking the pollu- million for the initial capital in- , tion culprit needs to be done scien- f vestment;then$1S'million an- • vestm.nt,This then is not insignificant. tifically.Throwing money at un- could mean thousands not in of dollanarslt proven solutions will only mean more for businesses less money is available to fix the annually and a• ' real problem once it's found.. ii f a 7 * ..al 9f r� tfi • '. ' :1_.':r.' .. .,.`r 1 ',;,..,.1. 1.r� (� „ . ti • rii1/. G , F f j e k ♦a'* ' i h r r 5 �I 44 y r I ' ' '',e;',ri r,; R t ? '„'' r . {{, .- i�� '�3 ' i'1..i''c. L 1iN.iMd�IJ _ cs uw.�wV ., 1 e+• i-• y - . _ p ” • , 2722 Main Way Dr. Los Alamitos CA 90720 July 5, 2001 Attention: Letters to the Editor The Orange County Register P.O. Box 11626, Santa Ana, CA 9271 1-1626 Subject TRACKING SOURCES OF OCEAN POLLUTION Dear Editor, I read your editorial of July I, 2001 referenced above, with great interest. As owners and publishers of one of the two largest newspapers in Orange County, you certainly have a right to voice your own opinions. However, in the interest of fairness I believe that you should give a voice to to those ihit may disagree with your point of view. In my view,the 301(h)waiver, and the continuing beach warnings and closures in Huntington Beach are two separate issues. In other words, weather or not the OCSD offshore discharge pipe is the "smoking gun"leading to beach closures or not, it is still by far, the leading point source of ocean pollution in Orange County? Lisa Lawson, spokeswoman from OCSD and others, would have you believe that, as may be the case in L.A. County, there would be no noticable difference in the(leafiness of the water before and after this massive(5400 million)initial capital investment. This is misleading,and clearly not the case in Orange County. Full secondary treatment with activated sludge will remove about 95%of the viral path)gees. Additionally, from their own engineering estimates, a reduction of total suspended solids(TSS)of 18,000 mt/yr(a 62% reduction)and a reduction in biological oxygen demand(TBOD)of about 32,000 mt/yt (a 80%reduction) would occur as a result of full secondary treatment togeather with the planned Groundwater Replenishment System(GRS)plant modifications. Full secondary treatment is also the first step required in the event that the GRS project be expanded beyond its present modest goals.The operating costs for lid] secondary treatment amounts to an increase of about $800,000 per year, or about 10 cents per week per person. The capital costs($400 million)can be amortized over a long period of time, but is sure to increase if we continue to delay in making the much needed improvements in our sewage disposal systems , I3�on Schulz " ^' `? Surfrider Foundation Huntington Beach/Seal Beach Chapter (562)430-2260 dornt 7 reatment Works Table 4-23 Ultimate Facility Requirements(Phase Ill of GWR System) Component Scenario 7' Scenario 2' Scenario.1 Scenario 4 Flows Plant Plant Plant Plant Plant Pia of Plant Plant No. 1 No. 2 No. 1 No. 2 No. 1 No.2 No. 1 No. 2 Influent wastewater flow (mgd) 236 235 236 235 236 235 236 235 Sidestream flows(excluding OCWD backwash) 4 2 4 4 45 41 56 54t 57 55 Trickling filter flow (mgd) 30 N/A 30 N/A 30`' N/A 305 N/A Trickling filter flow to OCWD(mgd) 0 N/A 30 N/A 0 N/A 0 N/A Activated sludge flow (mgd) 80 100 80 75 2135 244.5 2265 2445 Secondary effluent pumping(mgd)P2 to P1 NIA 0 N/A 65 N/A 0 N/A 0 OCWD backwash treated' ((odd) 5.0 0 0 14 0 3 5 5.0 00 140 3.5 OCWD maximum gross sec effluent demand(mg•'• 49.5 N/A 174 5 N/A 49 5 N/r>, 174.5 N/A Outputs TSS Mass Emission to ocean (mt/yr) N/A 30.535 N/A 29.399 N/A 13,492 N/A 11.255 BOD,Concentration to ocean(mg/I) N/A 90 N/A 115 N/A 21 N/A 22 BOO,Concentration to OCWD(mg/t) N/A 20 N/A 25 N/A 2C N/A 20 TSS Concentration to ocean(mg/I) N/A 50 N/A 59 NIA 22 N/A 22 TSS Concentration to OCWD(mg/I) N/A 20 N/A 27 N/A 2C N/A 20 Electricity usage(million kW/yr) 79.1 102 3 80.5 98 4 116 0 139 9 120.9 140 7 Cake solids to disposal(wt/month) 17,580 16.220 16.950 15.680 22.450 20.990 23.7021,060 Digester Gas Production(million wt/month) 113.9 137 3 132 6 130 7 127.2 142 0 134 4 142 6 Total Additional Units Needed/year 2020 Bar screens 1 1 1 1 1 1 1 1 Headworks pumping6(mgd) 251 71 251 71 251 71 251 71 , Grit chambers 7 9 7 g 7 9 7 g Primary clarifier basins 29 18 30 18 , 29 1E 30 18 Trickling filters rehabilitated 4 N/A 4 N/A 4 , N/It 4 N/A Trickling filter clarifiers 8 N/A 8 N/A 8 N/A 8 N/A Aeration basins(diffused air) 0 0 0 0 8 , 15 9 18 Blowers 0 0 0 0 2 5 2 5 Secondary clarifier basins 0 3 0 0 39 46 44 46 DAF tanks 0 0 0 0 4 Digesters 8 4 8 7 7 9 7 12 12 13 12 Holding tanks 1 0 1 0 1 , 1 1 1 Belt filter presses 9 3 10 2 14 6 14 6 Cake storage hoppers 6 7 6 7 9 1C 10 10 Activate°s.uade capac■y based upon maximum GWR system requrrements only and not on other plan.water system serv,ces dun 'OCWC bone is always d�recl.y d scnarged to the Duffel w,lhout treatment p me same period 'New tontt,nq filter danhers wd:be rectangular;150'x00') Toia,new T cianfrers rhdudes.nose needed aher demolsmnp ex,shn 1 a( clarifier to make room tar Solids',analog 1ac.iile5 p loot dilnleler GrCUlar 'Jihrhate Scenarios 1 end 2 used a BOO and TSS concentraoor,of 100/60 mp as govemmg lima Win the amount of secondary berow 2020 requirements c� trea inert never dedeas rip 'For Scenenos 3 ana l Fun secondary scenanosi the total secondary capac,ry needed includes srdestroam flows 'Includes 20 percent additional capacity to account toe new Standby CCNil Can-43 Drt%Serf & McKee Volume 2 Summary Report • • Section 4 Joint Treatment Works Table 4-24 Present Worth Cost Estimates for Various Planning Years (Costs in $million) Cost Component Scenario 1 Scenario 2 Scenario.3 Scenario 4 Year 2000 Capital Cost3 $107 $352 Annual O&M Cost' $26 2 $36 7 Present Worth of Annual Cost? $390 $546 Total Present Worth Cosy $497 $898 Year 2003 Capital Cost3 $179 $202 $447 $457 Annual O&M Cost' $29 3 $28.9 $40.2 341.0 Present Worth of Annual Cost` $437 $431 $598 $610 Total Present Worth Cost2 $616 $632 Year 2010 $1.045 $1,067 Capital Cost' $279 $321 $593 $630 Annual O&M Cost' $34 8 $33 9 $44.4 $46.2 Present Worth of Annual Cost2 $518 $504 $661 $687 Total Present Worth Cost2 $797 $825 Year 2020 $1,255 $1,317 Capital Cost3 $361 $408 $714 $776 Annual 08M Cost' $39.3 $39.5 $47 7 $50 2 Present Worth of Annual Cost? $584 $587 $709 $747 Total Present Worth Cost2 $945 $995 U Itimate $1,423 $1.523 Capital Cost3 $673 $712 $1.327 $1,377 Annual O&M Cost' $48 4 $47 8 $63.9 $65.5 Present Worth of Annual Cost2 $720 $711 $951 $974 Total Present Worth Cost? $1,393 $1 423 $2.278 $2,351 _egero Scenario t Ocean Plan w/o GWR System Scenario 2 Ocean Plan wr GWR System Scenario 3 Full Secondary wro GWR System Scenario 4 Full Secondary WI GWR System Annual Pau cost(ir'998 da.ars)based upon continually operattng all activated sludge treatment capacity needed for summer OCWO demand 'Present woin costs based upon a 20 year penod at a rea.Interest rate of 3 0% Capnal costs at ENRLA 6663 CDM Camp Dresser & McKee ,ocsatphase2vepon,r012t1 b4.7a.. Volume 2 Summary Report ORANGE COUNTY SANITATION DISTRICT Secondary Treatment for all sewage discharges Orange County Sanitation District(OCSD) is the largest of a very few sewage M districts still discharging live pathogens -- toilet water -- into the Ocean. Orange County is no longer a rural community of farms and clean beaches -- each day, millions of people and hundreds of businesses dump waste products � .�. ;,,� into the sewage pipes. Half the daily sewage of 2,200,000 people plus untold numbers of industrial plants -- 120,000,000 gallons per day -- receives only"primary treatment" with settling chemicals for 2 hours before being dumped straight into the M••.w. Ocean. Fecal bacteria is not removed from this sewage. • The other half,another 120,000,000 gallons per day, receives secondary • treatment with beneficial microbes -- "good bugs" -- to remove almost all the • carbon-based compounds, including coliform and other fecal bacteria. This level of treatment is considered minimal to avoid beach closures and destruction • of the balance of Nature. • The 1972 Clean Water Act required all sewage discharge districts to move to secondary treatment by 1985. Orange County got a "temporary" waiver under sect. 301 (h), allowing it to postpone treatment. The original waiver was for 5 years, and has been extended a number of times. The latest waiver will expire in 2003. OCSD must plan now for full secondary treatment. They have enough space, and the cost is not too high -- $200 &�.. million now, or $400 million if we wait until 2020. Operating costs are estimated to be perhaps as much as $15 million per year -- 2 cents per day per person. Considering how much of our money government blows away, that's not too much to pay to stop dumping live bowel bacteria into the Ocean. a �_ meeting of the Yet OCSD is preparing to go the OTHER WAY! They now want to move to "80_ Orange County 20": 80% live bacteria, and only 20%secondary.The people must tell OCSD Sanitation 4shrict to stop this, and clean up our sewage. Board, the 4th Wild of each The OCSD Board of Directors consists of 25 members, who can vote to direct month -- or contact OCSD staff to clean up our sewage discharges. 21 of those members are your own rep! elected city officials. Please ask your elected representative on the OCSD Follow the latest on Board to prepare now for at least full secondary treatment. Better yet, come WAY Littic5hell org to the OCSD meeting on the 4th Wednesday at 7PM in Plant 1,just continue OCSD G at the straight off the southbound Euclid off ramp from the 405 --or see the map on Euclid off ramp the website. to the 405, 10844 MI6. You can find out the latest meeting and letter-writing information on You don't have to www.Littleshell.org live in OC to be "Do us a favor, get rid of the waiver!" dgtGtcd! Signature Address Name Telc/Email After signing, please send to STOP THE WAIVER, P.O. Box 2911, Seal Beach 90740.