HomeMy WebLinkAboutSS3 - Ocean Outfall for Wastewater•
ITEM 553.
TO: Members of the Newport Beach City Council
FROM: Dave Kiff, Assistant City Manager
SUBJECT: The Ocean Outfall for Wastewater— Issues and Discussion
RECOMMENDED None — discussion item only.
ACTION:
BACKGROUND: All of north and central Orange County's wastewater — or sewage — is received
and processed by the Orange County Sanitation District (OCSD), a single -
purpose special district formed in 1921 as the Joint Outfall Sewer (JOS) agency.
The 1920s saw sewage treatment and disposal start at a treatment plant in
Fountain Valley and end at a 24" cast -iron surfzone outfall at the Santa Ana
River mouth releasing "screened wastewater" into the ocean.
Both the JOS /District and the Outfall changed in scope over the years. The JOS
• became an alliance of sanitation districts (called the County Sanitation Districts of
Orange County or CSDOC) in 1948. The late 40s and 50s saw new treatment
facilities in Fountain Valley and Huntington Beach and a new 7,200' long, 78"
diameter ocean outfall off of Huntington Beach that terminated at an ocean
depth of 60'.
0
OCSD Outfall History
Year Built Outfall
Diameter
Distance O .-
Capacity
GPM
op
Served
Today?
1920 24"
Surtzone I
unknown
1 70.000 est I
NO
1954 78"
7,200' long
60' depth
245
200.000
Yes
(unused)
5.1 miles
1971 120'
Diffuser @ 4.5 mi
480
2.35 million
Yes
185.200' depth
Today, the now - consolidated OCSD serves about 2.35 million people across 24
cities and 470 square miles in north and central Orange County, including the
residents and businesses of Newport Beach (see OCSD territory map in
Attachment A). OCSD's 650 -mile wastewater collection system takes in about
241 trillion gallons per day of wastewater. OCSD produces about 533 wet tons
of wastewater biosolids each day and sends another 236 million gallons per day
of effluent out a 5.1 -mile ocean outfall ( "Outfall").
Newport Beach City Council
OCSD Ocean Outfall
Page 2
• OCSD (www.ocsd.com) is administered by a 25- member Board of Directors that
includes representatives from the District's municipal sewering agencies, 2
sanitary districts, one water district, and from the Orange County Board of
Supervisors. Mayor pro Tempore Tod Ridgeway serves as Newport Beach's
representative to the OCSD Board of Directors. The District employs almost 500
staff members.
Wastewater Treatment at OCSD. OCSD, like many sanitation agencies, has
facilities to treat wastewater using the following process:
• Preliminary Treatment & Odor Control. To control odor, OCSD adds
sodium hydroxide within trunklines before wastewater reaches the
treatment plant. Once at the plant, OCSD adds hydrogen peroxide for odors.
The wastewater then flows through bar screens to catch large solids and grit
chambers to pull out small gritty things like coffee grounds and sand.
• Primary Treatment. In this phase, settleable solids fall from the wastewater
in large clarifiers. OCSD adds ferric chloride and an anionic polymer here to
"clump" small solids. Finally, the District skims oil and grease from the
surface of each clarifier. About 70% of solids settle out here — these solids are
later used for fertilizer after additional treatment.
• Secondary Treatment. Wastewater from the primary treatment phase is
attacked by bacteria that consume organic wastes. The bacteria are assisted
by OCSD's "trickling filter' which sprays the wastewater over rocks and
• "activated sludge' which exposes the wastewater to a variety of aerobic
microorganisms.
Secondary treatment with activated sludge removes about 95% of viral
pathogens. Since about 90% of solids are removed by the time effluent
finishes secondary treatment, the lower amount of total suspended solids
(TSS after secondary is usually <30 mg /liter) allows for more effective
chlorination — if necessary — to remove even more pathogens.
See Attachment B for a graphic of this process (graphic provided by OCSD).
Some sewering agencies that produce reclaimed water (like the Irvine Ranch Water
Distrct) use a fourth step — Tertiary Treatment — to "polish" the wastewater
further. Tertiary treatment may include sending the wastewater through sand or
charcoal filters, reed beds, or grass plots. Disinfection using ultra- violet light can
also be used at this stage of the treatment process.
The Federal Clean Water Act — Section 301(h). The federal Clean Water Act
(1972) required publicly -owned treatment works (POTWs) to achieve full
secondary treatment capability by July 1977. At the time, some agencies argued
that full secondary treatment might be unnecessary since some POTWs discharge
wastewater into deep waters with large tides and substantial currents. In
response, Congress added Section 301(h) to the Act — this section allows for the
United States Environmental Protection Agency (US EPA) to, upon request of a
POTW, conduct a case -by -case review of treatment requirements and,
• potentially, waive the Act's secondary treatment requirement via the issuance of
a permit under the National Pollutant Discharge Elimination System (NPDES).
CI
E
•
OCSD Ocean Outfall
Page 3
Section 301(h) has been amended several times since 1979, but it still allows
wastewater treated at a level less than full secondary to be discharged into deep
ocean environments. In 1990, about 60 sanitation agencies (out of about 15,000
agencies) held permits with waivers — today, about 36 such permits remain.
According to US EPA, the majority of Section 301(h) waiver recipients are small
POTWs that discharge less than 5 million gallons per day (MGD), although the
flows from these small POTWs represent only 4% of the 620 MGD of wastewater
under the Section 301(h) program. Recall that OCSD's discharge is 236 MGD of
the 620 MGD authorized under the waiver program nationwide, making OCSD
the largest agency in the nation using the Section 301(h) waiver.
From US EPA's Website on the 301(h) Waiver
r;- I s
Me
Any POTW applying for an NPDES Permit with a Section 301(h) waiver must
meet the criteria within the Clean Water Act, including:
• Existence of and compliance with water quality standards.
• Protection and propagation of a balanced indigenous population of fish, shellfish,
and wildlife.
• Allowance of recreational activities.
• Establishment of a monitoring program.
• Satisfactory toxics control programs, including an approved pretreatment program.
• No additional treatment requirements for other sources as a result of the waiver.
• No increase in effluent volume or amount of pollutants discharged above limits in
301(h) modified permit.
• Protection of public water supplies.
OCSD's Permit to Discharge Less Than Full Secondary out the Outfall. OCSD
first received a permit (Order 84 -1, Permit #CA0110604) with a Section 301(h)
waiver in 1985. US EPA and the California Regional Water Quality Control
Board, Santa Ana Region, issued the Permit. Because NPDES permits typically
are in effect for five years, OCSD's first permit expired in February 1990. OCSD
reapplied for — and received after a regulatory delay — a renewed 5 -year Permit
from US EPA and the Regional Board using Section 301(h)'s waiver provisions.
The term of the current (2nd) Permit (Order 98 -5, same permit number) is June 8,
1998 -- June 7, 2003.
OCSD Ocean Outfall
Page 4
• The Permit sets limits on pounds of solids, biological oxygen demand and
concentrations of other chemicals and parameters of concern. It also allows
OCSD to discharge a mix of 50% primary treated wastewater and 50% secondary
treated wastewater out the ocean outfall. As noted, about 236 million gallons per
day of this 50 -50 mix goes out the 5.1 -mile Outfall (with diffusers at about 4.5
miles out at about 185 -200' depth). Please see Attachment C for a graphic that
shows the Outfall and diffuser process (graphic provided by OCSD).
•
•
OCSD must reapply for another 5 -year renewal of the Permit in December 2002.
Prior to the December deadline, OCSD staff tells us that the OCSD Board of
Directors will evaluate their options for discharge and determine what level of
treatment the district will use in the future. The term of this 3rd Permit would be
June 2003 through June 2008.
OCSD believes that a 3rd Permit using the waiver is appropriate for the following
reasons:
• OCSD's 20 years of monitoring has not shown an adverse public health
impact of the current Outfall use. Ongoing testing (with UCI) off of
Huntington Beach will test a hypothesis that bacteria from the Outfall may
reach the shoreline — if so, OCSD has said (presentation on July 14, 2001):
If testing indicates that (additional pathogen reduction) is necessary, zoe will apply
additional treatment technology, such as:
-- Secondary treatment + disinfection
-- Filtration + disinfection; or
-- Microfiltration
• OCSD's monitoring programs have not shown an adverse environmental
impact of the current Outfall use. OCSD says that "liver pathologies are seen
in some fish, but are decreasing;' that "since early 1990s, effects relating to
the Outfall have not been seen;' and that no State consumption advisories
associated with the Outfall exist today.
OCSD's Monitoring Program
H
OCSD Ocean Outfall
Page 5
• • In order to appropriately reflect OCSD's 1999 Strategic Plan that directs
OCSD to meet changing population and economic conditions, meet
regulatory requirements, minimize operational costs, use existing facilities
efficiently, and to distribute costs fairly, OCSD says that any treatment
alternative used for the Outfall must:
- Be technically feasible
-- Meet regulatory requirements
-- Protect public health and environment
-- Meet city and local agency requirements
-- Provide reliable service
Water Quality Concerns in Summer 1999. In Summer 1999, high levels of
indicator bacteria off of the surfzone and shoreline along Huntington Beach led
officials with the Orange County Health Care Agency (CC HCA) to close
significant stretches of the beach in July and August. A new law that took effect
that same summer (AB 411, Wayne, 1997) directed officials to close beaches when
officials know of or suspect a sewage spill.
With vital beaches closed during high visitor season, OCSD, the County of
Orange, the City of Huntington Beach, California State Parks, the California
Regional Water Quality Control Board (Santa Ana Region), and others embarked
upon an expensive and extensive testing program to determine the cause of the
high bacteria levels. At least $5 million has been spent to date on Huntington
Beach- related studies (and expert reviews of the studies).
• Experts from the Southern California Coastal Water Research Project (SCCWRP),
the University of Southern California's Sea Grant program, the University of
California, Irvine (UCI), and more participated in the studies and reviews (which
continue today). To date, there is no consensus on what caused the high bacteria
counts. Theories as to the cause of the high bacteria include /included:
• Sewage leaking from sewer lines at the Huntington City and State Beach restrooms,
• Sewage leaking from Huntington Beach's sewer system or OCSD's trunklines
• Urban runoff (animal waste, bird waste, trash, and more) from storm drains and
channels that drain into the Ocean off of Huntington Beach;
• Urban runoff carried to the surfzone from the Santa Ana River (including from the
Newport Slough area);
• Bird waste from the Talbert Marsh - with the Marsh possibly incubating and
promoting more bacteria; and
• Bacteria in wastewater from the OCSD ocean outfall returning to shore thanks in part
to an electrical generation plant's effects on the "thermocline" (an ocean temperature
differential that typically exists parallel to the water surface but 15' to 20' deep) that
might otherwise block the wastewater's intrusion to the shoreline.
A Focus on the OCSD Outf all. The last theory identified above - a theory
studied by Dr. Stanley Grant of UCI and which is under investigation today -
sparked calls by environmental groups and beach advocates like the Surfrider
Foundation (www.surfrider.org) and the Natural Resources Defense Council
is (www.nrdc.org) for OCSD to go to full secondary treatment upon expiration of
the current 5 -year Permit.
5
OCSD Ocmn Outfall
Page 6
• Grant told a UCI newspaper in late 2000 that:
"there is no strong evidence that the outfall is the source, but it's quite a
complex problem ... we (have] to do a really careful study of all the currents
keeping track of where Ithe sewage is] going at what time, which wasn't really
done."
Opponents of a third 5 -year Permit issued with a Section 301(h) waiver argue
that:
• Any modem sewering agency in an urban coastal environment should treat all
wastewater to full secondary regardless of any outfall's ocean depth or currents.
• Orange County's residents and businesses —who use beaches and receive their
economic benefit — will be willing and able to pay the full cast of protecting ocean
waters to current federal standards (full secondary).
Two Newport Beach residents — Dr. Jan Vandersloot and Dr. Jack Skinner —have
argued the following regarding a new 5 -year Permit using the Section 301(h)
waiver:
"The basis for continuing ... the waiver (Permit) ... is that the OCSD, through
its monitoring program, is showing no harm to the environment or public
health. However, OCSD's own monitoring reports show statistically significant
incidences offish liver lesions near the outfall, showing possible harm to the
environment, and the beach closure and postings in Huntington Beach show
possible harm to public health... The (wastewater) plume's motion depends on
currents and waves, and is present off the shore of Newport Beach as well as
• Huntington Beach. The potential exists that the plume may show up on the
beaches of Newport Beach and Huntington Beach depending on the internal
waves, upwellings, and wind."
Dr. fan Vandersloot
Letter to HQCAC dated April 5, 2001
"I recently learned that ... OCSD performed a study in the fall of 1996 known
as the 20 -meter (fecal colfform) study. This study tested ocean water quality on
ten different days (in 1996) ... to determine if the wastewater plume was
moving shoreward.... Thefindings of this study are troubling because it appears
that, intermittently, the wastewater plume moves towards the beaches. On
November 20, 1996, bacterial readings indicate that the plume did reach the
beaches in West Newport...
"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...
"Based on the above evidence (more evidence listed in letter), I believe that there
should not be a renewal of... (a Permit reflecting a continued waiver of Section)
.... 301(h) ... (by OCSD)"
Dr. Jack Skinner
Letter to HQCAC dated April 28, 2001
Experts disagree, but the 1996 OCSD 20 -Meter Fecal Coliform Study to which Dr.
• Skinner refers suggested that the Outfall's wastewater plume may have extended
so close to Newport's beaches that it caused bacteria counts that — if AB 411's
I
OCSD Ocean Outfall
Page 7
• standards had been in place — would have caused postings of Newport's ocean
beaches northward of the Newport Pier on or about November 20, 1996 (see
related information on map in Attachment D).
Going Forward — Proposals, Options and Costs. As noted above, OCSD
intends to apply for a 31d Permit using the Section 301(h) waiver and the same
discharge (50 -50 mix) of primary and secondary treated wastewater out the
Outfall — but only if the summer 2001 tests off of Huntington Beach disprove the
theory that the Outfall contributes to surfzone and nearshore water quality
problems (Alternative #1— the least expensive -- on Page S of this Staff Report).
Other options are available to OCSD to kill or remove pathogens (viruses and
bacteria) present in the 50 -50 mix. These include:
• Filtration of Primary + Disinfection of all Discharge Effluent (Alternative #2).
OCSD believes that this method (where the Primary effluent is sent through
a filter then both the post -filter Primary and the 50% Secondary are
disinfected using UV light). This alternative is about $100 MN more
expensive than Alternative #1, but is both less expensive than going to full
secondary and may actually be one of the two most effective alternatives for
killing or removing pathogens.
• Microfiltering the 50% Primary before mixing it with the 50% Secondary
(Alternative #3). This method (whereby the Primary effluent is filtered
• through screens small enough to catch most, if not all, bacteria particles and
many viruses) may also achieve near complete removal of pathogens on the
Primary half while costing slightly less than Alternative #2.
• Full Secondary Treatment of all Effluent (Alternative #4). This method
would treat all Outfall material to a secondary treatment level (second most
costly alternative — causes some reduction in pathogens).
• Full Secondary + Disinfection (Alternative #5). This method would treat all
Outfall material to a secondary treatment level, then would disinfect the
post- secondary effluent using UV light (most costly alternative, but it assures
near - complete removal of pathogens).
As noted, these alternatives are summarized — with appropriate footnoting that
notes estimations in both cost and effectiveness — on the next page.
In reviewing these alternatives, OCSD staff suggests that we:
"not confuse the issue of a clean shoreline with treated wastewater releases 4 miles out...
It may not be prudent to change operations at OCSD if the hopes that ocean postings
and closures (often based on contamination from urban runoff, birds, and more) will go
away. At the very least, (decision - makers) should wait until (the) intensive testing this
summer (to determine if OCSD's treated wastewater is traveling to shore) is complete."
• 7
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OCSD Ocean Outfall
Page 9
• Questions for Newport Beach. OCSD's ultimate decision regarding whether to
apply for a renewed permit with a Section 301(h) waiver will directly impact the
City of Newport Beach and its residents and businesses. The decision raises the
following questions:
• Will full secondary treatment of the Outfall discharge lead to water quality
improvements at the surfzone? What other water quality impairments —
urban runoff, vessel waste, or bird waste — might be as or more determinate
of ocean water quality than discharges out the Outfall?
• What "message' should the City send to OCSD regarding this issue — is the
"go to full secondary" message the only one that appropriately reflects a
beach city's concern for ocean water quality?
• What about treatment processes involving less than full secondary treatment
— are these more cost - effective and beneficial than full secondary?
• Given that full secondary doesn't kill all viruses nor eliminate all bacteria, is
full secondary good enough? Assuming our goal is the cleanest ocean water
possible, is full secondary + UV disinfection more appropriate?
• How will residents and businesses in Newport Beach react to sewer rate
increases should OCSD's treatment process be expanded?
The Newport Beach Harbor Quality Citizens Advisory Committee (HQAC)
discussed this issue on May 3, 2001 and voted unanimously to recommend to the
City Council that it take a formal position in OPPOSITION to OCSD's request for
a renewed 5 -year Permit reflecting a waiver of secondary treatment requirements
for the Ocean Outfall under Section 301(h).
THIS AGENDA This Agenda Item is informational only.
ITEM:
ATTACHMENTS: Attachment A — Map of OCSD Service Area
Attachment B — OCSD's Treatment Process
Attachment C — OCSD's Ocean Outfall and the Outfall Diffuser
Attachment D -- Map of September- November 1996 Bacteria Test Results
• 9
• ATTACHMENT A
Map of the OCSD Service Area
•
9
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etas Ahead
♦ OCSD Public Hearings (July '01, November '01, March '02,
June '02)
• Huntington Beach studies (underway -- end in 9 -01)
• Treatment Options report (draft released March '02)
• Final report(s) to OCSD Board (May 102)
• Prepare draft permit application (Aug '02)
• Public Comment period (AugSept'02)
• OCSD Board adoption of permit application (Nov '02)
• Permit submittal, review by Regional Board, US EPA (Dec
102 to Feb 103)
• Permit renewal lissuance (May '03- June '03)
ORANGE COUNTY SANITATION DISTRICT
Secondary Treatment for all sewage discharges
Orange County Sanitation District (OCSD) is the largest of a very few sewage
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
Ocean. Fecal bacteria is notremoved 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's "temporary" waiver under
sect. 301 (h) has been extended a number of times. The latest waiver will
expire in 2003. OCSD must plan now for full secondary treatment.
Staff admits 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 $15 million per year -- 2 cents per day per
person. Considering how much of our money government blows away, that's not
too much to pay to stop dumping live bowel bacteria into the Ocean.
Yet OCSD is preparing to go the OTHER WAY! They now want to move to "80-
20": 80% live bacteria, and only 20% secondary. The people must tell OCSD
to stop this, and clean up our sewage.
The OCSD Board of Directors consists of 25 members, who can vote to direct
OCSD staff to clean up our sewage discharges. 21 of those members are
elected city officials. Please ask your elected representative on the OCSD
Board to prepare now for at least full secondary treatment.
You can find out the latest meeting and letter- writing information on
www.LittleShell.org
"Do us a favor, get rid of the waiverl"
Signature Add
q I a14101 - ss-+ 3
a 0
meeting of the
Orange County
Sanitation District
Board; the 4th
md. of each
month -- or contact
your own rep!
Follow the latest on
www.LittleskO.org
OCSD is at the
Euclid off ramp
to the 40$,
10844 EBLs.
You don't have to
live in ae to he
disgusted!
iame TelelEmail
After signing, please send to STOP THE WAIVER, P.O. Box 2911, Seal Beach 90740.
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(6) WAIVER COMMENTS
NPDES permit decision states "This decision and the psrnfit implantuing this decision ae subject to
revision on the basis of attbsegtseraly acquired information relating to the unpacta of Ima• than- secondmyy
discharge on the marine envitonman.'
Owed in 1997: Since then the following events have ocamd:
Episodic and periodic beach dosures in Fkank gton Beach. (1999)
Frequent beech posted warnings in Nttatington Beach
A new and mere sensitive bacterial irdtrator mandated by AB dl 1 sad roeonunended t:y the EPA
(Enterocxas)
A new COP FFED and new comphance reporting standards.
At Iasi 3 scientific studies have been completed with no firm conclusions regarding tins source of the
bacteria c using these beach dowres. A fourth and Mh are planned.
A are EPA rule bas been approved by the Clinton administration to require new discharge standard for
offalwre (Federal waters) POTW plants.
An expansion of the AES power plant is planned which may have a detrunestal imtpact ten the near shore
pothriion in Huntington Beach.
Poseidon Corp. is planting a denknatsm plant with water from the AES plant which awry be taking water
from the discharge phtme of the OCSD cudlow pipe.
it is not dear that this event is not to violation of the waidegradation policy of the CW A
Comments made to the CSOD Board of Directors on May 23, 2001
References;
NPDES permit issued 1997
1972 Clean Water Act (EPA)
AB 911
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.
COUNTY SANITATION DISTRICTS
OF ORANGE COUNTY, CALIFORNIA
P.O. BOX 8127. FOUNTAIN VALLEY, CALIFORNIA 92728 -8127
10844 ELLIS. FOUNTAIN VALLEY, CALIFORNIA 92708 -7018
(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:
COUNTY SANITATION DISTRICTS OF ORANGE COUNTY
FACT: SHEET
April 18, 1989 Volume 2 Revision 2
"2020 VISION"
A Wastewater Management Action Plan
BACKGROUND.
The Orange County Sanitation Districts are responsible
forwastewater management formost of Orange County.
We currently operate under the terms of a modified
ocean discharge permit issued by the federal
Environmental Protection Agency (EPA) and the
California Regional Water Quality Control Board
(CRWQCB). The existing permit is based on a waiver
of the federal Clean Water Act's full secondary
treatment requirements. Section 301(h) of the Act
permits deep ocean dischargers, like the Districts, to
dispose high quality but less than full secondary treated
wastewater to the ocean. Our 301(h) waiver was issued
in 1985 and requires an extensive ocean monitoring
program to determine whether the marine environment
is being protected and whether we are maintaining
compliance with the California Ocean Plan. Our current
permit expires in 1990. We are consistently in
compliance with all ocean discharge permit conditions
and all federal and state discharge standards and quality
limitations. In August 1989, we will be applying for a
new permit from the EPA and CRWQCB.
ISSUE
We must decide whether our treatment level beyond
1990 should be partial secondary or full secondary.
Providing full secondary treatment to all of our flow
would cause less solids to be discharged into the ocean
and would result in the least change in the composition
of ocean bottom life forms in the immediate vicinity of
the outfall. It would require a major expansion of our
facilities, which would cost more money to construct,
operate and maintain. The added facilities would require
more equipment and materials, which would increase
total energy use. The additional removal of solids would
also increase the amount of sludge requiring land
disposal. The issue involves numerous trade -offs.
FUNDAMENTAL QUESTION
The critical question underlying this Important public
policy decision is: "What is the optimum wastewater
management program that will protect public health and
provide balanced environmental protection ?"
PLANNING PROCESS
We have been conducting a comprehensive planning
study to assemble the information necessary to make a
well - informed policy decision in mid -1989. The
"Action Plan for Balanced Environmental
Management" is the Districts' program for coordinating
the necessary engineering, environmental and fiscal
studies and for consulting with the public. When
completed, the Action Plan will result in:
♦ A 30 -year facilities Master Plan with a
focused construction and financing plan
through the turn of the century;
♦ An Environmental Impact Report (EIR) to
ensure that all elements of the environment
are adequately protected;
♦ A determination of public opinion regarding
the optimal level of treatment and the most
appropriate wastewater management
options;
♦ An application to the EPA and the CRWQCB
for renewal of our discharge permit.
To date, draft versions of the Facilities Plan, EIR and
Financial Plan have been completed and input from
interested members of the public regarding the
preliminary wastewater management options has been
solicited and considered.
I. WASTEWATER TREATMENT
ALTERNATIVES
We have been studying and evaluating alternative levels
of wastewater treatment prior to the treatment level
policy decision by our board of directors and submission
of our ocean discharge permit renewal application.
On the following two pages, you will find a summary
table presenting information from the Draft EIR and
Facilities Plan relevant to the treatment alternatives
being considered. Please note that it is the finding of the
Draft EIR that each of the treatment alternatives would
protect the environment from significant impairment
from the ocean discharge and would comply fully with
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."
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DESCRIPTIVE SUMMARY OF ALTERNATIVE
WASTEWATER TREATMENT OPTIONS
Portion of Flow
1989
FUTURE WASTEWATER TREATMENT
'
Quao/f ana
ALTERNATIVES'
12
1/3
12
(Preliminary
Trmmenl
Areas of Primary
Current
California Ocean
preferred Perrmit)
Full Secondary
Interest
Operations
Plan
fly%
Biochemical Oxygen
bland
OceanRand
Ocean/Land
Limits
Demand (BOD) Removal
Portion of Flow
Ocgn/land
Qce =Land
'
Quao/f ana
Receiving Secondary
12
1/3
12
Full
Trmmenl
Tots/fruckload
wet Tons(fruckloaa
wet Tons(rmckload
wet Tom(rmckload
Solids Removal
75%
75%
75%
fly%
Biochemical Oxygen
bland
OceanRand
Ocean/Land
Oceanlland
Demand (BOD) Removal
70%
30%
60'le
fly%
Tordo & Heavy
Most Important objecllve Control at source to meet all existing and future standards. No future increuses.
Metals Control
Toxic control equivalent to full seeoodwy under all alternntiva. Environment and public health protected
Solids to Occan/LT
Ocgn/land
Qce =Land
Oaan/l�
Quao/f ana
(dry ttws/day491115
Sludge Reuse Potential♦
43/150
781180
46234
Sludge to Land (d
Tots/fruckload
wet Tons(fruckloaa
wet Tons(rmckload
wet Tom(rmckload
wet tow/truckloads))
72033
930/47
1120/56
1520176
Toxia & MetalOcea
bland
OceanRand
Ocean/Land
Oceanlland
Occan/Land (Ibs/
600/600
6201580
550 /650
370/830
Dissolved Oxy
(% Depletions
12%
1S%
13%
Ocean Bottom
16 Acres
28 Aces
18 Aaa
5 AcLfe
CompaitrImpacted
Impacted
Impacted
Impacted
Bacteria Leve13
1.8
13
2
(Million/100 m
(I..engtb and depth
of outran results in no identified
health risks for all treatment
altemativm)
Virus Levels
(phousand/300 ml)
2.4
3.5
2.4
3
Air Impacts
Minor differences in air impacts between altemauves. Many volatile subsmnca not measured
' No significant adverse impacts on air quality from facilities operation.
Total Energy
Not comparable to future
requirements which reflect
61900 Equivalent
9,100 Equivalent
13,400 Equivalent
Requirements+
the efficient reuse of
Households
Households
Households
on -site sewage gas.
-
Water Reclamation
Up to 15 Million
Amount reclaimed is independent of treatment level.
Gallons/Day
An additional 58 MGD is proposed
Sludge Reuse Potential♦
APpn"umately 50% of
Sludge is Reused
Equal, pending new fedeml regulatiotts.
Less due to higher
water content.
' Baeed 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 ease" outcome, for each treatment option. In practice, the treatment alternative which is ultimately sanctioned for our next permit
period would guide opemtions from 1990:o 1995 only. The estimated year by which full mcondary, 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. Environmenml
Protection Agency and the South Coast Air Quality Management District.
+Denotes an area reflecting differences among the alternatives.
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DESCRIPTIVE SUMMARY OF ALTERNATIVE
WASTEWATER TREATMENT OPTIONS
30 -Year Ca 'W Crest of
Current Facilities Valued
Yes
Yes
1989
FUTURE WASTEWATER TREATMENT
at Appnodmately $625
5244 Billion
ALTERNATIVES'
$3-16 Billion
Inflauoo)+
Million
(Prefiminary
Yes
Areas of Primary
Current
California Ocean .
Preferred Option)
Full Secondary
Interest
Operations
Plan
Current Permit
54.11 Billion
$3.75 Billion
Total Cost of Debt
N/A
limits
598 Billion
30 -Year Ca 'W Crest of
Current Facilities Valued
Yes
Yes
Yes
Facilities (aF %Annual
at Appnodmately $625
5244 Billion
$276 Billion
$3-16 Billion
Inflauoo)+
Million
Yes
Yes
No
30-Year-Cost of O&M
The impacts of future air regulations are unknown
Air Qualit • Com liacxs
3 P
Yes
( @5% Annual IuOation)+
N/A
$178 Billion
54.11 Billion
$3.75 Billion
Total Cost of Debt
N/A
$-82 Billion
598 Billion
$1.34 Billion
Total 30 -Year Cost of
sludge goes out of minty
and public accepaoce
Facilities (@5 % Annual
N/A
37.04 Billion
PAS Billion
35.25 Billion
Inflation)+
Annual Cost to
Households.. (1989 S)
$405105
$90,5170
$1055175
$1305195
Annual Cost to I arse
Food Processor (1983 S)
1709, 000
32 ,0001000
32,100,000
$2,500,000
Annual Cost to Medium
Sized Food Processor
5'33,600
$90,000
5961000
$114,000
(1989s)
Annual Cost io
Metal Finisher
11,400
32,900
$3,000
$3,200
(19893)
Calif. Ocean Plan
Yes
Yes
Yes
Yes
Compliance?
301(h) Waiver Rcgwred?
Yes
Yes
Yes
No
The impacts of future air regulations are unknown
Air Qualit • Com liacxs
3 P
Yes
and muid 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 minty
and public accepaoce
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 tau" 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 construeted is 2005.
The 2005 date is premised on 1990 mostruetion son -up and timely procession by key regulatory agencies such as the U.S. Environmental
Protection Agency and the South Coast Air Quality Management District
°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.
+Deootm an area reflecting differences among the alternatives.
II. WASTEWATER MANAGEMENT PLAN.
OBJECTIVES
A. Taxies Control
Current Conditions: Our toxics source control program
regulates the discharge of toxic substances and heavy
metals from industrial dischargers to the sewer system.
The program is approved by the EPA and the California
Regional Water Quality Control Board. Current
performance is better than all existing standards for
removing toxics and heavy metals.
Plan roach: Toxics control is an important
objective regardless of treatment alternative. Our
program controls the impact of toxics on air, water and
land (i.e., sludge). This program will result in more
stringent source control limitations for a greater number
of toxics and will commit to holding toxics and heavy
metals in the wastewater stream at or below currant
levels.
B. Facilities Construction
Current Conditions: Our existing facilities are adequate
to meet the hydraulic and treatment needs of ourservice
areaand the requirements of state and federal regulatory
agencies.
Plan ' aroach: Based upon land use information from
local and regional planning agencies, sewage flows
within our service area could increase by as much as
55% between 1990 and 2020. Our existing facilities
could not handle this increased demand. Consulting
engineers have updated our facilities Master Plan to
address the expected increase in flow and service
demand as well as the various alternative treatment
levels.
C. Water Reclamation
Current Conditions: We contract to reclaim up to 15
million of our 260 million gallons a day (MGD) of
wastewater in a joint reclamation project with the
Orange County Water District. Up to 15 MGD will be
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 roach: 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
♦ Site shape and size
♦ Proximity to environmentally sensitive areas
D. Sludge Management
Current Conditions: Nearly 50 percent of the sludge
produced by our treatment process is recycled and used
for agricultural land application and for composting.
The remainder is trucked to sanitary landfills.
Plan ppm=h: As sewage flows increase, the volume
of sludge will also increase. In addition, the more
stringent the wastewater treatment level, the greater the
quantity of sludge produced. Therefore, we need a
practical, long -term plan-for managing more sludge.
The Master Plan approach is to have independent,
multiple sludge management alternatives giving us the
flexibility to ensure that sludge disposal options are
always available and to continue to stress toxics source
control as a way to ensure sludge quality and maximize
its reuse potential. The most promising sludge
management alternatives which have been identified in
the Master Plan are:
In- County and out -of- County co- disposal with
municipal solid waste
♦ Sludge -only landfill (monofill)
♦ Additional reuse via land application
♦ Composting at approved sites
♦ A detailed long -term sludge study to
thoroughly evaluate specific options in light
of more restrictive sludge management
regulations forthcoming from the U.S.
Environmental Protection Agency.
III. FURTIIER INFORMATION
For further information or copies of the draft Facilities
Master Plan or Environmental Impact Report, please
contact the Districts' Public Information Office at Box
8127, Fountain Valley, CA 92728 -8127 or call (114)
962 -2411.
nswerw to questions about...
301 (h) Provision
of the Clean Water Act
• Background The Clean Water Act (CWA) is a 1972 amendment to the Federal
Water Pollution Control Act. The 1972 CWA requires publicly owned treatment
works (POTWs) to use secondary treatment prior to discharge to ocean waters.
In 1977, § 301(h) was added to the Clean Water Act. It allowed qualified POTWs
employing rigorous pretreatment and extensive ocean monitoring programs to
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
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
• Protection and reproduction of a balanced native population of fish,
shellfish and wildlife
• Protection of beach and nearshore recreational activities
• Establishment of an extensive ocean monitoring program
• A rigorous pretreatment program in order to meet secondary water
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
(OCSD) has consistently complied with this and all other federal, state and local
regulations.
Who issues OCSD's Ocean Discharge Permit? When was the
last permit issued? The Orange County Sanitation District's (OCSD) ocean
discharge permit is jointly issued by the federal Environmental Protection Agency
(EPA) and the State of California by the local Regional Water Quality Control Board
(RWQCB). The ocean discharge permit requires review by the United States Fish
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
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.
• How does OCSD treat wastewater? What is advanced
primary treatment? OCSD treats wastewater using three processes:
preliminary treatment, advanced primary treatment, and secondary treatment.
In preliminary treatment, wastewater passes through screens that remove large
and nonorganic materials. It then flows into grit chambers where the heaviest
materials such as egg shells, coffee grounds, and sand settle out. The materials
removed here are then sent to a landfill.
nrcmmA,nm nm n-n .a.
After preliminary treatment, the wastewater is pumped to large settling basins.
Chemicals are added to reduce hydrogen, control odors, and combine small
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
off the top of the basins. The thickeners that are added to improve settling of the
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.
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
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
dissolved organic material in the wastewater.
What is the difference between the standards required in a
full secondary treatment permit and a permit issued under
the § 31 O(h) section? The § 301(h) provision of the federal Clean Water
Act allows for a slight increase in the amount of total suspended solids (TSS)
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
§ 301(h) permit requires increased ocean monitoring by OCSD and increased
environmental examination by regulatory agencies.
• 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.
• Does OCSD test to make sure fish and other sea life are not
affected by the outfall's treated effluent discharge? OCSD
conducts an annual multi - million dollar ocean - monitoring program. The extensive
monitoring program tracks and evaluates water quality, sediment quality and sea
life from Seal Beach to Corona Del Mar.
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
sediments using rig fishing, trawling, sediment grabs, water column testing and
in plant wastewater samples to ensure the safety and health of the public and
marine life. OCSD is required to perform more sampling than other agencies,
but annually the agency does considerably more that the minimum requirements
due to its interest in overall watershed and environmental protection.
OCSD /042001 /301(H).cd,
page 2
Why does OCSD choose to be regulated under the § 301 (h
provision rather than implement full secondary treatment.
OCSD believes that the § 3O1(h) provision allows the agency to strike a balance
between the impacts upon the air, land and water environments due to the
wastewater treatment process. As a result, OCSD believes that the § 3O1(h)
provision allows for greater overall environmental protection of the land, air and
sea and assures future flexibility for the agency to implement the newest and
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.
The ratepayers in Orange County would pay an additional $200 -400 million dollars
for construction of secondary facilities and approximately $10 million dollars more
a year in operations and maintenance. The bulk of the amount is the cost of
handling and disposing of biosolids.
How is the § 301(h) provision linked to ocean water
closures? The § 3O1(h) provision is not related to the ocean water closures.
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
decrease in the abundance of the fish around the discharge zone. There has been
an ecosystem established that uses some of the discharged nutrients for food.
By removing additional solids, we would be removing nutrients currently being
released to the ecosystem.
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 for 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 § 3O1(h) provision of the Clean Water Act. OCSD believes
that § 3O1(h) permit allows for a beneficial balance overall between the land, air
and ocean environments.
OCSD is not progressing towards full secondary at this time. If the decision were
made today to proceed to full secondary, it would take 5 -10 years for OCSD to
begin operation.
OCSD/042001/301 (H).cd, page 3
Is the Ocean a, Damp?
O.C. Sanitation Says -. Yesi
Here is your chance to hear the reasons why the
Orange County Sanitation District thinks that they
should expand ocean & swage disposal. They are
proposing an increase in the amount of treated
urine and feces that are dumped into the deep
ocean oft shore of the Santa Ana River. Not only
do they want to increasa their dumping, but they
want to continue their M emption from the
Federal Clean Water Act._
They are asking for an
extension of their sectio, t l
301 h waiver. The 301 h
waiver is a loophole in'
the Clean Water Act the,
says that it a polluter
can prove that their
dumping does not
degrade the
environment they can .
continue to dump without obeying the law that
says that all sewage treatment plants should treat
their sewage to "full seec•ndary" standards.
Sewage treated to "full st!condary standards" if
swallo',rrrd in even small amounts would cause
grave illness and perhap c death within a few
days if untreated. Seconuary treatment removes
most of the solids from the sewage. Orange
County Sanitation says tt,is is too expensive.
Let's Hear Their Side of the Story!
More Pipes ii► the Ocean?
Recycle Water or Ocean
Dumping?
C
Thursday at 7 pm
10844 Ellis Ave., Fountain Valley
405 Frwy. of Euclid/Ellis exit
( tell guard you are going to the Admire t Won Building )
Speaker Nancy Wheatley,
Director of Technical Services
Grange County Sanitation
Radioactive Waste
►5pM Near -the
Santa Ana River
Recently the 405 Freeway was closed for
►.cr,. �, five hours while workers cleaned
up an overturned truck full of
radioactive medical waste. None
was discharged into the Santa
River —this time.
Soon they will be using old nuclear pager plant
fuel to irradiate meat. Isn't it time we rethink our
society's dependence on dangerous chemicals?
Do we want toxic trucks running all over our local
streets and freeways?
Please Support Your Chapter
Supporters this Holiday Season
River's End Cafe -19M st, seal Beach
Harbour Surfboards - seat Beach
Bruce Jones Surfboards
- Sunset Beach
Juice'for YOU - Warn
To: N.Wheatley, INTERNET :73222.1532 @compuserve.com
Date: 219/98, 11:23 AM
Re: CSDOC NPDES permit application. 301(h) waiver.
Nancy,
In the message Dtd. 2/5198 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 discharger's projected
suspended solids mass emission rate to below 19,788 MT/yr by the end- of-per hA
term."
The EPA Tentative Decision of theRegional Administrator (Pg.7 Par.3), states;
"Mass emissions: In terns of mass, suspended solids loadings have ranged from
14,000 to 17,500 MT/yr since 1985."
Once again,this appears to be a dear 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 Pemrit Re- opening, revision,
Revocation, and Re- issuance condition J.3).
Based on the previous technical information that f 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 plaos a maximum end -of -tern 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 effkient 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,00nsistent with your current regulatory requirements.
Your frtend,Don Schutz
To: Donald P. Schulz, SurfDeddy
From: Nancy Wheatley, NWheatley
Date: 219198,12:46 PM
Rw 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 C ounty's population. That must
be factored into calculations on future discharges. Also, please note that the permit reooeners 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 1 do not btdieve d 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 took at our marine monitoring information over many years. It is almost impossible to
find impacis from our discharge once you move away from the immediate area of the dituser. (It is true that you can find
bacteria offshore, which is an impact, but there is no evidence of harts 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, 1
would encourage you to state why and provide the basis for your opinion.
Nancy
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 we 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 ma -dmum 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
ORANGE COUNTY GRAND JURY
700 CIVIC CENTER DRIVE WEST -SANTA ANA, CALIFORNIA 92701.714/834 -3320
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,
Sheldon S. Singer
Foreman
SSS:cj
MA 1�c
MIT M-
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 17,1996
P.O. Bo: 3087 Long Beach, California 90803
(310) 439 - 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.
U. 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
HBILB 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).
TT 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.
TT 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
PAGE 3
I. CSDOC 301(h) WAIVER (continued)
OUESTIONS,
(1) In the opinion of the OC Grand Jury, is the decision by the EPA to allow a 25% increase in effluent i
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 i
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 C WA?
(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
HBILB CHAPTER
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 GABRML RIVER COLIFORM LEVELS:
25% OF YEAR ABOVE BODY CONTACT STANDARDS.
QUESTION:
(1) Should the Counties of Los Angeles, San Bemadino and Riverside be held financially liable for the
health and water quality of Orange County beaches?
SURFRIDER
HBILB 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.
OUESTION:
(1) Should the O.C. Grand Jury request the O.C. District Attomgy• reassess the NPDES fine structure to
cover the increase in sediment testing at CSDOC required as a condition of the 301(h) waiver?
SURFRIDER
HBILB CHAPTER
PAGE 6
IV. 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 I 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
HBILB CHAPTER
PAGE 7
IV. SEWAGE AT NEWPORT BEACH (con't)
(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
HBILB CHAPTER
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:
I
(1) Is the current fee structure at CSDOC fair and equitable? i
(2) Is the current fee structure at CSDOC being administered according to policy?
(3) Is the current income to CSDOC (from Ad Valontm taxes, raze -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? j
(CONTINUED ON NEXT SLIDE)
SURFRIDER
HBILB CHAPTER
PAGE 9
V. INCREASES AT CSDOC (continued)
i
QUESTIONS: (con't)
I
(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
HBILB 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 USEDQfflL-E 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' 120" .OUTFLOW PIPE.
/ SURFRIDER
HBILB C_ HAPTER
PAGE 11
There are two answers that are correct; answer
one - YOU ARE! and answer two NOBODY!!
There is a third answer, but you won't find it very
satisfying, our government agencies. First, there
is the Regional Water Quality Control Board. They
are funded by our federal income taxes through
the E.P.A.. There is one for the San Gabriel River
and another one for the Santa Ana River. They
don't communicate very much. They don't
measure water quality anywhere, unless asked. .
They have a policy that we call "correct your,own
homework." a.
policy
Permits .
The Regional Water Quality
Boards give ,polluters a permit
to pollute (NPDES permits).
Then they ask,them to monitor
the water to be sure that their
permit is being obeyed The
Regional Boards. are way too
understaffed to look at..any. of
this monitoring and sometimes
these polluters .':...(called
"dischargers') -get away with
murder. If we catch them,'we
can sue them under the.Clean
Water Act.:
Sewage Plants.: reassuring comments to the media.
Most of the surf - ione.water quality monitoring is �•
done by sewage agencies. The Regional Board It is up to Us -
gives-,them a :pe'rmit to dump partially treated. There'are a great many other bureaucracies R,
sewage'. in the.deep :offshore waters. If this that have some control of water. ,Most _don't' .
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;,
not their problem: When -the bacteria counts are Foundation to empower local activ!sts...td . .
high after a rain,' they at 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:.All :F;
not you, then who?
'Factory Pollution
The Regional Water Boards give them permits to
pollute, also. Except for run -off from industrial
sites, there are very few factories left that have
pipes in the rivers or ocean. Power plants are a
big exception. That's why the water in Seal Beach
is so warm. The power plants take Alamitos Bay
water to cool their turbines and then they dump the
hot water in the San Gabriel River.
The Local Cities
Cities are responsible for the sewer pipes that lead
to the sewage plants.. Some of these pipes are
fifty years old, rusted and bent
by earthquakes and subsidence
(ground' sinking from oil
extraction). During heavy rain,
these pipes can leak sewage to
the storm drains and beach. It
is a case of out -of- sight, out -of
-mind.
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WASTE: 17%
increase is
expected
FROM 1
cent secondary.
Only the amount of microscop-
ic particles in the water would
increase; the amount of water
discharged would remain about
the same.
The increase in the concentra-
tion of particles in the water is
needed because of the district's
plans for a new groundwater -re-
plenishment system. That sys-
tem involves pumping highly
treated wastewater by pipeline
to- settling ponds in Anaheim,
where it would gradually perco-
late into groundwater aquifers.
But it also means diverting up
to 100 million gallons of water per
day away from the outfall pipe
and into the new groundwater
system. And that, in turn, means
there will be a higher concentra-
tion of solid particles in the water
that is discharged.
The sanitation district also will
monitor water quality around the
outfall pipe to make sure the
higher levels of discharge do not
harm marine organisms.
The proposed waste increase is
the product of two years of analy-
sis and review by wastewater
and environmental experts, as
well as public focus groups, Her-
berg said.
And it will help avoid some-
;' thing the district does not want to
do — build another outfall pipe.
"We've looked at various ways
to defer building a new outfall,
which would cost $150 (million)
to $200 million," said district
spokeswoman Michelle Tuch-
man.
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MORE SEWAGE
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The amount of microscopic waste `
em
particles suspended in water
discharged into the ocean could
oil
increase 17 percent under a
Ja
proposal by the Orange County
W;
Sanitation District. .
•
s1
The Orange County Register
S1
GETTING INVOLVED
'a£
The Orange County Sanitation Dis-
e0
tricts must collect public comment
aq
and gain approval from their board
si
of directors before increasing the
14:
amount of waste discharged into the
to
ocean. Here's what's next:
41
► Saturday. A workshop geared to-
sr
ward board members, districts head-
SE
quarters, 10844 Ellis Ave., Fountain
I ,
Valley, 9 to 11:30 a.m. It is open to
e1
the public.
1
► Wednesday: District's board will
0:
vote on whether to release a draft
environmental impact report to the
public. Same address, 7 p.m.
► June 29: If approved, the report is
t
1'
released to the public; copies will be
available in local libraries.
► July 21: Board will hold a public
i
hearing on the report and discharge
e
proposal.
p
► Date uncertain, but probably in
October: Board will decide whether
r
to certify report and approve the dis-
charge increase.
I
► Questions? Call districts spokes-
woman Michelle Tuchman, (714) 962-
.. 2411, Ext. 2050.
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To: Orange County Register, INTERNET :letters @link.freedom.com
CC: D.Slaven, INTERNET:eyesg @earthlink.net
CC: E.Kliszewski, INTERNET:eveldii @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.Sarrgent @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 Califomia 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
Aug. 13,1999
Orange County Sanitation District.
10844 Ellis Avenue
Fountain Valley, CA 92708
Arm.: 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 tern detrimental impact to land and air resources
caused by scenario 4 is offset by the long tern 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.
• 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. Boa 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
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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
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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 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
Surfrider Foundation
HuntingtonBeach/Seal Beach Chapter
Blue Water Task Force News
January 2001
NEW STUDY TAKES ADD AT OCEAN OUTFALLS IN 1999 HUNTINGTON BEACH CLOSURES
A recent $1.5 million study lead by Dr. Stardey 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
dosed for over 2 months during the summer of 1999, and commues to plague local suAbreeks.
The District's outfall pipe •nas tested for leaks by OCSD during their intensive investigation, end determined
act to have any gross lealu4 however plume tracking of the dye discluagad from the outfall pipe during the
tests indicated that pollutants could be transported downcoast and shoreward, then drift upcoest with the
prevailing longshore arrmrt, and be upwelled by the warm water discharged periodically from the AES
Corp. (formerly Edison) Electric Power plat 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 gird 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 Cowry, and have been allowed under the terra and conditions
of a 30l(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 Plmr 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 surface and be rapidly blown ashore by prevailing winds, and pollute the surf zone.
Also, the Antidegradation Policy of the Clean Water Act states that a degradation to the receiving
waters has ocvj red when a beneficial use has been impaired. Beneficial uses include swimming, diving
surfing, and gathering shellfish. Beach closures clearly 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 bosh the EPA and the Santa Ann 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 378 Huntington Beach. CA 92649
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
>>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
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2
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
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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 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.
Therm ,MaYt3,=t AmMiu Iim:J W PW: t
To: [unknown], INTERNET:JonV3 @aol.com
From: INTERNET:JonV3 @aol.com, INTERNET:JonV3 @aol.com
Date: 5/28/01, 11:43 AM
Re: COG: 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 9th 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
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
$9.1- 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 $900 - 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
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JAN D. VANDERSLOOT, M.D.
2221 East I& Street Home Phone (949) 54&6326
Newport Beech, CA 92663 OSice 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 dw Sierra Club recommends the Sierra Club oppose the
extension of the 301(h) waiver being sought by the Orange County Sanitation District
(OCSD),
Batcheround: 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 Stases receive full secoaidary treatment at a minimum. In 19-M, the Cleat
Water Act was amended to allow certain ocean dischargers to discharge less than full secondary
treated sewage. Secondary trammnt refers to a process where most solids, bacteria and viruses are
removed from the sewage prior to discharge. Primary treatment mfers to removing lager objects
from the sewage stream only. The Orange County Sanitation District applied for and received the
301(h) waiver in 1985. h received a 5-year extension to die waiver in 1998, whidt 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 (butlogic oxygen
demand), both standards being 30mg/liter for 30 days average. Currently, OCSD is discharging
240 mgd (million gallons a day) of a 50/50 blend of primary and secondary treeard sewage
through a 10• foot outfall pipe extending 5.1 miles off the coast of Huntington Buadi, CA, 200
feet deep, creating a sewage plume of 6 miles by 3 miles by 100 feat. The sewage: is disci aged
through a 6,000 -foot long diffuser pipe with $00 ports. This diffuser pipe eaxtermb; from the and of
the outfall pipe north up the coast. OCSD discharges a total of 15,000 metric tore; a year of TSS a
yea, in concentrations of 55mg11 of TSS and 80 mg/1 BOD. The permit allows a Maximum of
20,000 metric tons of solids a yea. The recently approved Groundwater Replmehment System
(GWRS) will divert up to 100 mgd of secondary, mood sewage to the Orange County Water
District (OCWD) from OCSD for tertiary new ant, disvrfecaon, and injection ino the
groundwater basin under Orange County for drinking -water use. The brine from this process will
go out the oudfall pipe, Because of growth, the oufall discharge in the yew 2020 will still be
240mgd, with increases of primary treated sewage to 809/o of the oudfall, and TS5• of 17,000
metric tons of solids into the ocean each yea. The sewage plums is thought by OCSD to remain
trapped offshore by a temperature thesmoctme that caps the plume and prevents it from reaching
the surface of the ocean or the shore. It moves tip and down the coast from tae end of the
discharge pipe. The permit granted by EPA and RWQCB is conditioned by a monitoring
requirement that OCSD show no ham to due environment or the public health wi It annual reports.
These reports still show effects on the mvironme w in Ending ft liver lemons treat the omafall
pipe. The reports omit evidence that the plane may reach shore with elevated baaerial readings in
19 %. In 1999, and the years afterward, due City of Huntington Beach has experienced beach
closures and beaten postings due to elevated bacterial readings. In November, 2000, a study by
UCI sciartist Staley Grant, pot forth due theory that the warm discharge into the now by the
AES power plant in Huntington Beach pokes a hole in the therrmocline, entim mirilt the bacteria
from the OCSD sewage plume and dmwwg do bacteria to the beady. This theory is being tested
.... - --
JAN D. VANDERSLOOT, M.D.
2221 Eau 166 Street Home Pbone (949) 5486326
Newport Beach CA 92663 Office FAX -;714) $486643
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 shore. 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 year 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 treament,
baud on public continents. Orange County ratepayers pay approximately $80 per gear 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 consistem 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 nclamation of all
sewage water.
4. Disinfection of sewage is easier and more energy- efficient than disinfection of primary vested
sewage.
5. Fewer bacteria and viruses in sewage. Full secondary reduces bacteria by 95 %.
6. Cleaner beeches.
7. Healthier fish and other ocean creatures.
Cons:
1. Cost to Orange County ratepayers of 5 cents per person per day, $75 per year fir a family of
four.
2. Increased biosolids disposal including increases in truckloads of biosolids per day 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 monitoring requirements if no waiver.
7. Possible increase in odors from treatment facilities affecting adjacent neighbodtoods.
S. Other treatment methods including microfiltradon, new technologies, and disinfection with
ozone and bleach can be used to disinfect primary sewage while still retaining the waiver.
9. Full secondary only removes 951/6 of bacteria from sewage. Further disinfection will be
required to achieve 100% removal of bacteria
10. Kcrofilmmon of primary treated sewage will remove solids to below the TS S standard of the
Clean Water Act, but not below the ROD standard. INicrofiltration will still require a waiver from
BOD.
11. Disinfection of current sewage will cost only $30 million, while full secandau y requires $400
million.
Volunteers ee e clo j
d'.'d-..f
Huntington Beach
�Z
A
�i� to Y
1, 50 rmonth %W
Contar'n"ffidlidn''." ......
777`
Jr
Five, cents -Asddy-;ur 50 a month .to Lhave.psewage F, s,
Cha membe' rs now h ave an. opportunity to assist treated before it is dumped I
ran Conty Sanitation' District' (UCS13) _this
wou co
'This 'i§41idt -it: 'Idi"
summer �in this�._ve'ry im ov tai n scientific':, study.
"66dhty'to"if,,-ave'-sec'ondary�-
(Huntii &66 .Beach - Shoreline contamination clean.'
' '
sewage -iniii drinkaWem'ateeb6fore it ig di" -inio---; .
ifivestigation).' This heir shore Water i::j4ality. study' is - , - - .. I. �; - , '' .
-'th . .. ......
o . nly one :'corn ponent of 'a , v"e*r' e, ocean.
,y coinplekliand:. 1-4
comprehensive 'workplan recently bonioleted by.the If an of u
Joyr, local.'. city
technicial staff at OCSD.:: In addition -May .. r . epresentitive".'
to the n e". County'
21--22 (24 hour) sampling schedule describ'e'd in the" Sanitiati6n is t ur
-so s .0
Attachment, the tests are to be repeated over a 48 hour concerns "T 6 301 fSt' t complying
period'(ho (hour samples) es) durring the 'peak tidal cycles the-CleariMater Act•wh req rcs � full se' 60 n
for the following 4 months (June . 4-6,.July 5-7, July treatment. of sewage be I fore. b . eing released: into- the
19-21, and Sept. 15-17. Complete details of the ocean. It is. not giving. the' greatier :dilution n' and
workplan can be obtained fro the. OCS13 Web Site: disperstion with large tides and substantial currents, is
http: Hwww.ocsd.com and the Ftp Site: required by the Clean Water Act..!
Hftp.ocsd.com:
T11 I - I We Can not 'Allow this dumping into our ocean to
Although no training appears to be required.., The lab continue, (1):..30lh Waiver has not complied with
work weill be carefully supervised... by.. qualifi-ed -.-,.CI6a.n,Wat.er. Act.and the.State Porter-Cologne,. Water;
OCSD personnel, they would , probably prefer Quality: Act standards. (2) Has . not protected the
wolunteers with some labp experience I 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 ate . d i I tem's. (4) Has not had
Let's show our support forthis project! r an extensive monitoring tensive adequote ocean monitong 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) Proteciltion of public water supplies. ti
STOP THE DUMPING IN THE OCEAN
Next General Membbrship Meeting June 7th at River's End cafe in Seal Beach
@ 7pm. Program Bolsa Ch,ica Wetlands Restoration, H.B.Councilmem'ber
Debbie Cook
Publication of the Hu
Beach Chapter of the Surfrider Foundation
Pubiication'of tote` IC6ntmgton /Sea�'Beach,:Gtiapter of the Surfrider Foundation
'sewage '6` long, 2 3
... to
of miles.. •
miles wide and' `100 -.feet deep.
i /� V� P
Ocean Outl all f'OU
This sewage plume theoretically is' .
.. capped: : by: "_: a..; , .-temperature
(OOG) i
'thermocline: that.prevents it from
coming to shore; _ but the theory
OCSD 301H Waiver`.'
has been "challenged by a' UCI
study in November 2000.- , This:..,
The Ocean OutCall Group (OOG) is ;
theory, by UCI Professor Stanley
a group that formed in December, ...
Grant, proposes that the plume
2000 opposing the Orange_ County.:,:
does_ come to shore:ibecause a .
Sanitation District's 301(h) waiver :`.
separate warm -water outfall pipe .
that allows it to discharge sewage '',.into
the.. ocean'; from 'the AES
into the ocean off Huntingdon '
energy plant in Huntington Beach'
Beach that is not treated to Clean..:'
pokes a hole in the thermocline,
Water Act standards. The Orange
entrains the bacteria, and .draw's
County Sanitation : District
it to the beach, thus explaining
(OCSD) discharges 240 - million :..i.:.
the .1999 .,beach. closures -,and
"postings.
gallons a day of sewage from a
'sporadic/ beach:
Y
B20 ac'.`. SATURDAY, JUNE 9, 2001
r.
JOHNP.PUERNER
qtr �"'e•'°+ L blNw haidentand -'
Chkl ODkrf J �
- Z �: JOHNSCARROLL r;
��^ • +� 1f7i. ,, Ali. h "114 ..i it
JANET C7AY[ON 1..r
n. !rTe� �(� i.f. �,� t.FdborgfduFAltorlalPrrg�a'v _::
_
LEo b C. WOLINKYN
I
~j �rrO�cA ��1L'ele ��ielV Assbt
,'d . •� :. , '�7
:7! MELISSA McCOY f •.
•),_r. -n_d w _ _•, <'JOSeeH IY1. RUSSIN
- it.7' . ` - AaneNnFdlfaer 4 ix,{#''!�••q:
1 t',a -`FRANKDELOLMO Hri`Rdi Wt —
:> .'..
, ARDI7H HILLIARD'y';:,yi;.�
(if Cl l m m Pr a Yl rl CPI7U51 (iP'
1.
urfers shredding the breakers and par-
questioned the model thathad predicted the
:•
entshelpingtoddlerssloshthroughthe '..offshore
topography :;would:trap. the : "moder -z:
w _. ' ,::, :shorebreak have every right to ques- :,i:
ately treated" sewage and-hold itat' a safe dis -,T± -
*: tionwhy the Orange County Sanitation',.,
tance: One theory the district.:will''test this ;v'Y
• - 'District is allowed to pump more bacteria, hu- .
summer suggests that a'nearby,powei' plant's;:.:
man waste'and bther organic matter into the
suction of ocean wa ter; cool..equipmentis _>
",° ocean than most other - districts. The answer is .
.:
bringing in sewage too.'? ='
• P, a federal waiver that holds.the district's waste
_ To its credit, the district `.haS promised'to'
:.ems;
• ;water;areatment to a less rigorous standard
take steps to improve_ reatment after the reF'.'`:;;;_
•. { +,underAhe Clean W.ater:Act. It's a waiver that
suits are in, but piecemeal meas ures won't do. ' „•
no longer;.makes sense:
At some point, common 'sense must take'over,,,a.,
Orange County has grown enormously since ..:
and ratepayers will have to bite the bullet ands .,
•— ;;: the.
Environmental Protection'. Agency. first ,;.
do the job. right. Estimates put the cost of the "LL•
the exemption; one of 36 nationally, in
advanced treatment thaCremove's more solid'.
granted
- 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. .
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
".. : 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.
4
Letter No.l:
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
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:EDITORIALS
Tracki -n Durres ` a.
wJ
of.ocean pollution_^
'.` hen it.comes to environ near- doubling of sewer rates for l ''
y : ` Xental,protection,Amer homeowners.'
ica is approaching the r , ,. 'The district meets strict state''.
' point'at which balance is and EPA water - discharge stan-
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 -..i;:
actual improvement. : merit in many instances. OCSD is .'
A case in point is occurring in operating in a professional and re"'
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'
r because of high levels of bacteria, that treated water is causing on- .
near the shore. 'This is a disastrous ' 'tainination.
situation for a city best known for But some environmentalists, .offi-
its surfing and swimming, so. local cials and media critics are focused
I� officials and residents are right to on the process, rather than on the
demand a solution. cleanliness of the water that's com-
Of course, it's silly to spend sev- ing out of the district's pipes.
eral hundred million dollars to "fix” They're obliviou's 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 d
`' t V �. =.7,1, .°�•.i4o ±ink'ois'90*— 'R:°!N.+.
Z
Rte"
`— C'ool heads need io prevail. -- - -'much of the county's treated sludge 4
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-, 'r
Sequent studies suggested the pipes
. banned the use of O.C. sludge by
are not the source of the beach pol-
farms.
lotion: The latest theory,-offered by .
The Huntington Beach problem
a UCI engineer, is that the treated
may no[ be, the result of any new '±
sewage pumped out to sea by the
pollution sources. It may simply re-
'Orange County Sanitation District
fleet tougher stiiewide pollution
is being pulled back to shore -.
standards that went into effect in
' r
drawn in 'part by the warmed water
1999. Now similar:levels of pollu -,';
released by the AES plant in Hun-
tion that always have existed trig -
��
tington Beach...''
ger beach shutdowns: That means':'
�_
It's' a plausible theory, and OCSD,
. the problem'may; take' more time
is spending more than $4 million to.
and effort to pinpoint.
test it.'Eatly results suggest the dis-
One possible improvement. :..
. `r
charged water is not the source of
would deal with part of the prob= ,
high bacteria levels.
lem. Sanitation district officials 6e-
The district is under no obliga-
lieve urban; runoff moving along
tion to spend millions to test any
the Santa Ana River could be a cut-
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 .':
irate - pollution: One idea is to
nof'enough for Tome local residents :
spend about $10 million in up-
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 :
It's worth remembering, also,
level of treatment ihat targets mi- .
that the ocean is not a pristine.
!
croscopic'solids. t.','• :.
place. "Whales poop in the ocean,"
Recently,'Los Angeles: city and
is how one observer put it. In other
county adopted'a'secondary Sys =
words, the pollution could stein in .
tem. There's no noticeable differ-.
part from high concentrations of
ence in the cleanliness 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 haw -'
Clearly, pollution problems of
son, spokeswoman for the O.C. San-,
F:
this importance need to be cor -;r,; „
'1
itation. district.' ` :' '' : ^: '' ``; "'
>..
rected. By'all means, let's leave. no
'Yet the §e`additional facilities:iii �'=
'stone -:or mound of bird poop - , '
Orange County would cost $400 •.: - ..
unturned. But tracking the pollu -�
million for the initial capital in -.,- , ,
; loon culprit needs to be done scien-
vestment, then $15'million an- ; ;.' :
': tifically:= Throwing mqney at un- '
nually. This is not Insignificant It ':
proven solutions will only. mean
could meati thousands of dollars ., '
,less money is available to fix the
more for businesses annually and a• ':
real problem once it's found.
i
`If•1 \ga\. -•.:i /f• 7 .If•1
9, LlL
�t
i1
i f(
')'AYy
�
4:1
9, LlL
�t
i1
i f(
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 92711 -1626
Subject: TRACKING SOURCES OF OCEAN POLLUTION
Dear Editor,
I read your editorial of July 1, 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 y(arr own opinions.
However, in the interest of fairness I believe that you should give a voice to to those thst 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 ease 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 954/o of the viral path)gens. Additionally,
from their own engineering estimates, a reduction of total suspended solids (TSS) of 18-000 mttyr (a 62%
reduction) and a reduction in biological oxygen demand (TBOD) of about 32,000 mdyr (a 909A 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 requicrd in the event that
the GRS project be expanded beyond its present modest goafs.The operating costs for fall secondary
treatment amounts to an increase of about $800,000 per year, or about 10 cents per wesk per person. The
capital costs (5400 million) can be amortized over a long period of time, but is sure to i wease if we
continue to delay in making the much needed improvements in our sewage disposal sysrems.
� 61J, 1z
o achulz
Surfrider Foundation
Huntington Beach/Seel Beach Chapter
(562)430 -2260
jorn( irea(men( woncs
Table 423
Ultimate Facility Requirements (Phase 111 of GWR System)
Component
Flows
Scenario Y'
Plant Plant
N
No. 1 No. 2
Scenario 2'
Plant Plant
No. 1 No. 2
Scenario 7
Plant Plant
No. f No. 2
Scenario 4
Plain Plana
No. f No. 2
Influent wastewater flow (mgd)
236
235
236
235
236
235
236
235
Sidestream flows (excluding OCWD backwash)
4.2
4.4
4.5
4.1
5.6
5.1
5.7
5.5
Trickling filter flow (mgd)
30
N/A
30
N/A
305
N/A
30'
N/A
Trickling filter flow to OCWD (mgd)
0
N/A
30
N/A
0
NO
0
N/A
Activated sludge flow (mgd)
80
100
80
75
213'
2445
2265
2445
Secondary effluent pumping (mgd) P2 to P1
NIA
0
N/A
65
N/A
0
N/A
0
OCWD backwash treated' (mgd)
5.0
0.0
14.0
3.5
5.0
0.0) 1
14.0
3.5
OCWD maximum gross sec effluent demand (mgd)
49.5
N/A
174.5
N/A
49.5
N/A
174.5 N/A
Outputs
TSS Mass Emission to ocean (ml/yr)
N/A
30.535
N/A
29,399
N/A
13.492
N/A
11,255
BODs Concentration to ocean (mgll)
N/A
90
N/A
115
N/A
21
N/A
22
BODs Concentration to OCWD (mg/1)
N/A
20
NIA
25
N/A
2C
N/A
20
TSS Concentration to ocean (mg/1)
N/A
50
N/A
59
WA
22
N/A
22
TSS Concentration to OCWD (mgll)
N/A
20
N/A
27
N/A
2C
N/A
20
Electricity usage (million kiss
79.1
102.3
B0.5
98.4
116.0
1399
120.9
140.7
Cake solids to disposal (wUmonth)
17.580
16.220
16.950
15.680
22.450
20,990
23,700
21.060
Digester Gas Production (million ft3/month)
113.9
137.3
132.6
130.7
127.2
1420
134.4
142.6
Total Additional Units Needed I year 2020
Bar screens
1
1
1
1
1
1
1
1
Headworks pumping" (mgd)
251
71
251
71
251
71
251
71
Grit chambers
7
9
7
9
7
9
7
9
Primary clarifier basins
29
18
30
18
29
18
30
18
Trickling filters rehabilitated
4
N/A
4
NIA
4
N/A
4
N/A
Trickling filter clarifiers
8
N/A
8
N/A
8
N/A
B
N/A
Aeration basins (diffused air)
0
0
0
0
B
19
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
8
4
8
Digesters
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
10
10
10
Activated Nudge c dsecaiy based upon maximum GVM system reou aments ony, and not on omer Want raw sYNem services dunng me same penoo
20C V V / bnne i3 allays d,e Y mNJiWs to me WIIYI MIhW Ve111mtem'
'New tndlrLng /Iw danfiems vnd be rnsanginar(15Vx401 Tdal new TF dardtenindudas lAOae need,ed Miem demoesnmp ensanp la(lpm diamtludwlem
d2ditl to make mpom tom acids Handing la ithes
IUltimate SC dins 1 and 1 used a Boo and Tss Wn4nVBUon of lag /d,0 mgd as goxarmng NTM1. Mm me anlpVnl al aemridiy be8lment Myer dePaaeang
begw 2o2o,"ouement5
'FU ar<nanos 9 and s IFYII secondary scenanasl me tow secondary rapudry needed, mduaes vaestream flows
Induces 2(1 pemcenl a ion.one, to addWla W new standby
GC3M! G�mP 13lig of 4 McKee Volume 2 Summary Report
exsmpraee_lsi PO TSWOJIIe.e_]"
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 Costa
$107
$352
Annual 0 &M Cost'
$26.2
$367
Present Worth of Annual Cos?
$390
$546
Total Present Worth Cost'
$497
$898
Year 2003
Capital Cost
$179
$202
4447
$457
Annual O &M Cost'
$29.3
$28.9
$40.2
$41.0
Present Worth of Annual Cost2
$437
$431
$598
$610
Total Present Worth Cost"
$616
$632
$1,045
$1,067
Year 2010
Capital Costa
$279
$321
$593
$630
Annual O &M Cost'
$34.8
$319
$44.4
$46.2
Present Worth of Annual Cost
$518
$504
$661
$687
Total Present Worth Cost2
$797
$825
$1255
$1,317
Year2020
Capital Cost
$361
$408
$714
$776
Annual O &M Cost'
$39.3
$39.5
547.7
$50.2
Present Worth of Annual Cost?
$554
$587
$709
$747
Total Present Worth Cost2
$945
$995
$1.423
$1,523
Ultimate
Capital Costa
$673
$712
$1,327
$1,377
Annual O &M Cost'
$484
$47.8
$63.9
$65.5
Present Worth of Annual Cost
$720
$711
$951
$974
Total Present Worth Cost?
$1,393
$1.423
$2.278
$2,351
Legere
Scenario 1 Oman Plan w/o GWR System
Scenano2 Ocean Plan w/ GWR System
Sceam 3 Full Secondary Wmo GWR System
Scenano a Full Secondary w/ GWR System
lmmY Ow omn Im 19% ONIvs7 based upon cdmnway opera" all am.atee swage Vemmem capacity needed tv sumlMl OCYM demand.
'Present wart Wets based upon a 20 yaw panoa at a meal addled tale of 3 D%
'Ca nel costs at ENRL 6663
CDM Camp Dresser & McKee
r'bcsd\pnase2Veoor [ s \ial2 \TCM.2a as
Volume 2 Summary Report
ORANGE COUNTY SANITATION DISTRICT
Secondary Treatment for all sewage discharges
Orange County Sanitation District (OCSD) is the largest of o very few sewage
districts still discharging live pathogens -- toilet water -- into the Ocean.
Orange County is no longer o rural community of forms and clean beaches --
each day, millions of people and hundreds of businesses dump waste products
into the sewage pipes.
Half the doily sewage of 2,200,000 people plus untold numbers of industrial
plants -- 120,000,000 gollons per day -- receives only "primary treatment"
with settling chemicals for 2 hours before being dumped straight into the
Ocean. Fecal bacteria is not removed from this sewage.
The other half, another 120,000,000 gollons per day, receives secondary
treatment with beneficial microbes -- "good bugs" -- to remove almost all the
corbon -based compounds, including coliform and other fecol 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 o "temporary" waiver under
sect. 301 (h), allowing it to postpone treatment.
The original waiver was for 5 years, and has been extended o number of times.
The latest waiver will expire in 2003. OCSD must plan now for full secondary
treatment. They hove enough space, and the cost is not too high -- $200
million now, or $400 million if we wait until 2020. Operating costs ore
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.
Yet OCSD is preparing to go the OTHER WAY! They now wont to move to "80-
20": 80% live bacteria, and only 20% secondary. The people must tell OCSD
to stop this, and clean up our sewage.
The OCSD Board of Directors consists of 25 members, who con vote to direct
OCSD staff to clean up our sewage discharges. 21 of those members ore
elected city off iciols. Please ask your elected representative on the OCSD
Board to prepare now for of least full secondary treatment. Better yet, come
to the OCSD meeting on the 4th Wednesday of 7PM in Plant 1, , ust continue
straight off the southbound Euclid off romp from the 405 -- or see the mop on
the website.
orange county
Sanitation O'rttrict
Board, the 4th
Md. of each
month -- or contact
your own rep!
Follow the -latest on
www. Li tle"all. org
ocSD is at the
Euclid off romp
to the ADS,
10844 Ellc.
You con find out the latest meeting and letter - writing informotion on you don't hove to
www.LittleShell.org live in oc to be
"Do us a favor, get rid of the waiver!" di;gustcd!
Signature Address
Name Tcle /Email
After signing, please send to STOP THE WAIVER. P.O. Box 2911, Seal Beach 90740.
13200C 'SATURDAY,JUA9,2001
A
'A l.}! JOHN P.
T
1CW
DEANI
Afanq#
7
_41t
p.
JOSEPH lit
LEOU M
t :7!
14M Co,,
JOHN A
WLELLW
,-JOSEPH N
--- — -------
ZFN C"Ci
Al.
!=7i6eddQ.the breakers and par- questioned the. model £ L.d.r c
J;
N
ot
t offshore z.topography : o .trap
caw heipuig Loddlers slosh through the,.
Nt' sho rebreak have every right to ques-� . ately treated" sewage and hold 1 8
ltiori,why the Orange County Sanitation tance.' ne�th the �di ct
Via;.., is allowed to pump more bacteria, hu- summer:suggests that a 'nearby
man wiste:'and'other organic matter into the suction of ocean:.wa to c I �ki
oc6iii than most other.districts. The answer is bringing in sewage
ii:federg waiver that holds the. district's waste ': To its credit 01 r - o
viai& treatment to a less rigorous - standard take . steps to t
after
the Clean Water:Act. WE a waiver that suits are but piecemeal 0.
uhde in,'
-.-'no longer makes sense.- At some point, common sense 'must take over
....lunge 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:
9 . ranted the exemption, one of 36 nationally, in advanced treatment' thivremo v�esi more `solid'
1985. Today,. its sanitation district. is the larg- waste at more than $400'inilboh to build new
w est holder of a waiver anywhere. It's time for facilities and $15 million a ye'aT' in
the EPA to make sure Orange County subjects costs. It would be money well speroE
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 L49 Angeles. waste from water fowl in the Talbert Marsh,
The waiver expires in.2003, and scientists area. The hundreds of millions of gallons of
and environmentalists are already voicing sewage, discharged daily froth, the distr,ic.
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' resillent as.
closings threatened Huntington Beach's this great resource is, we can't afford to treat it Z
economy. Last fail, UC Irvine researchers as a sewer.
-71NItb) —
�SS:3
®C S D S LVrr ' 16&fe 05.01
JAN D. VANDERSLOOT, M.D.
Residence: u ine ss: I q
2221 E16Street 8101 Newman, Suite C j
Newport Beach, CA 92663 Huntington Beach, CA 92647
Phone: (949) 548 -6326 Phone: (714) 848 -0770 xl
Email: IonV3 A&al.com Fax: (714) 848 -6643
April 5, 2001
Tod Ridgeway, Chairman, and
Newport Beach Harbor Quality Committee
City of Newport Beach
3300 Newport Blvd
Newport Beach, CA 92663
Re: Harbor Quality Meeting this afternoon, April 5, 2001, 3 PM
301(h) Waiver, Please Oppose
Dear Chairman Ridgeway and Harbor Quality Committee Members,
1 understand your committee will be discussing the 301(h) waiver this afternoon and whether or
not to approve the Orange County Sanitation District's request to approve an extension of this
waiver. I request that you not approve an extension of the waiver, and instead, to actively oppose
the waiver and ask for early termination of the waiver, perhaps through a revocation procedure.
This waiver from clean water standards embodied in the 1977 federal Clean Water Act grants the
OCSD the ability to discharge dirtier sewage into the ocean than allowed under the Clean Water
Act. The Clean Water Act sets standards of 30mg/liter of BOD (Biologic Oxygen Demand) and
30 mg/liter of TSS (Total Suspended Solids), achievable by full secondary treatment of sewage.
However, under the waiver, OCSD is discharging 240 million gallons a day of only partially
treated sewage into the ocean, with a 50150 mix of primary and secondary treated sewage,
exceeding the allowable limits of BOD and TSS by roughly double. Under the recently approved
Groundwater Replenishment System (GWRS), these parameters will increase even more, because
the mix will now by 80% primary and only 20% secondary, with BOD rising to 111 and TSS to
57 in the year 2020, with corresponding increases in bacteria and viruses discharged into the
ocean.
I have attached Table 5 -26 from the EIR for the 1999 OCSD Strategic Plan for, the Projected
Effluent Quality for the year 2020, describing the different scenarios. Compare Scenario 2, the
"Preferred Alternative" including the waiver plus GWRS, with Scenario 4, Full Secondary plus
GWRS. All parameters are dramatically reduced with full secondary. BOD drops to 21, TSS
drops to 24, well below the standards within the Clean water Act. When comparing Total
Coliform and Fecal Coliform, note the difference in order of magnitude 1.8E +07 is 18E +06. Full
secondary reduces this to 4.2E+06, a 75% drop in Total Coliform. Similarly Fecal Coliform drops
from 6.4E +07 to 1.5E+06 (E+06 is engineering shorthand for 10 to the 6's, E+07 is 10 to the 7m),
a 98% drop in Fecal Coliform. Viruses drop from .23 to .03, an 87% drop.
With fiill secondary treatment of the sewage, no waiver is required, and ocean discharge is much
cleaner.
Currently OCSD discharges its 240 million gallons a day through a 10 -foot diameter pipe
extending 4.5 miles out into the ocean near the Santa Ana Rivermouth about 200 feet deep. This
JAN D. VANDERSLOOT, M.D.
esidence:
2221 E16 Street
Newport Beach CA 92663
Phone: (949) 548 -6326
Email: JonV3aaol.com
usines :
8101 Newman, Suite C
Huntington Beach, CA 92647
Phone:(714j 848 -0770
Fax: (714) 848 -6643
discharge creates a plume extending 6 miles in length, 2 to 3 miles in width and 30 to 40 meters
in thickness. This plume is supposed to be capped by a temperature thermocline that acts like a
cap preventing surfacing of the plume. However, this thermocline is not present from October to
April each year. Moreover, the Stanley Grant UCI hypothesis is that the warm water discharge
from the AES power plant in Huntington Beach pokes a hole in the thermocline, drawing the
plume closer to shore, which maybe responsible for beach postings and closures. This hypothe sis
will be tested this summer through a $2 million study. In addition, internal waves and upwellings
may bring the sewage closer to shore than previously supposed. The plume's motion depends oD
currents and waves, and is present off the shore of Newport Beach as well as Huntington Beach.
The potential exists that the plume may show up on the beaches of Newport Beach and
Huntington Beach depending on the internal waves, upwellings and wind. .
The basis for the continuing granting of the waiver by the EPA and Regional Water Quality
Control Board is that the OCSD, through its monitoring program, is showing no harm to the
environment or public health. However, OCSD's own monitoring reports show statistically
significant incidences of fish liver lesions new the outfall, showing possible harm to the
environment, and the beach closure and postings in Huntington Beach show possible harm to
public health. Thus, the clear implication is that the waiver is not protective of either the
environment or public health, and the sensible approach is to follow the standards in the Clean
Water Act, which means no waiver and full secondary treatment of the sewage.
What is the cost of full secondary treatment of sewage? Projected cost is $400 million. This
equates to 5 cents a day per person in the 2.2 million - population service area. Sewer bills for
families may increase $3 per month or $36 per year. Orange County sewer rates are now $80 per
year. The average California sewer bill is $185 per year. One of the wealthiest counties in
California and the nation is paying much less for its sewage treatment and should be able to
afford full treatment of its sewage, leaving a much cleaner ocean. Moreover, there is a $50 billion
federal program that can be tapped to offset the cost, if only OCSD would make the commitment
for full secondary treatment and apply for the appropriate grants.
A clean ocean is important for the economy and the environment. I urge you to start the process
and recommend against the waiver. Let's send a message to OCSD to clean up its act and
immediately plan for fall secondary treatment. Ask OCSD to "Do us a Favor. Get rid of the
Waiver."
Thank you.
Sincerely, 7J
Jan D. 'gVan dersloot, MD
Attachment
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bo
Newport Beach City Council Members
Study Session on OCSD Ocean Outfa1U301(h) Waiver Issues
Newport Beach City Hall, July 24, 2001
Honorable Council Members:
I am Irwin Haydock, an Orange County resident now residing in Fountain Valley, CA.
My purpose is to provide you with information I believe will be useful in your decision -
making regarding the question of Orange County Sanitation District's (OCSD) 301(h)
Waiver. This joint EPA/RWQCB approved 5 -yr. NPDES Permit allows treatment that
does not strictly meet baseline Full Secondary requirements set out in the 1972 Clean
Water Act. The price of 301(h) renewal is achieving full compliance with EPA's Waiver
administrative rules. This requires a demonstration of no environmental or public health
harm by the discharge, based primarily on the results of extensive and intensive
monitoring specifically designed for the small region around the subject sewer outfall.
The main issue faced by OCSD is their outfall's responsibility for the two - month 1999
Huntington Beach closure. Although the General Manager has expressed the opinion that
the District's outfall was not involved, I respectfully disagree. I find more than enough
factual evidence to believe that the outfall was not only responsible for much of the
closure but continues today to occasionally fail to meet existing ocean water quality
standards along the local coastline. On more than one occasion I have written to the
District's expressing these opinions and offering my suggestions for assuring the public
that something will be done to alleviate the continuing unacceptable risk. We do not
need further studies to confirm the District's own data, we need action Now!
At the end of this letter I have provided a few personal facts about myself and about
Waivers as they have influenced my 30 -year career as a scientist. I assure you that I am
expert in the science and experienced in the politics of these matters, and also that
Newport Beach is being placed at risk by today's treatment and disposal operations.
I want to express my opinion, based on this career, of the ocean outfall issue before you
today and for all the future. Your coastal location, along with that of Huntington Beach
and Seal Beach, makes your wishes transmitted to the OCSD Board of Directors of
utmost importance to set the bar for Orange County's future. This will take more than a
Council resolution regarding the 301(h) Waiver. You need to actively pursue public and
political agreement of inland cities to be successful. This was made clear to me per
example of Los Angeles County, where coastal and inland cities were set against one-
another based primarily on estimated treatment costs. At that time Los Angeles County
Sanitation Districts (LACSD) was charging about $75 per family per year. Full
Secondary Treatment was estimated to roughly double that cost! No matter, in spite of
the fact of much higher gas, electric, water, and garbage bills, sanitary engineers proudly
pointed out that "the good old ocean will treat it for free." That turned out not to be true
but, of course, there was no contest among the 57 Board members, the much larger inland
contingent overwhelmingly voting to continue fighting to the bitter end for a waiver.
Just last year LACSD lost their final appeal to EPA, the lawyers went home and the
Districts is now marching toward Full Secondary (as already achieved by the City of Los
Angeles). The Waiver decision is not a question of cost, or about the degree of treatment
necessary. It is about taking a long -term view of our water future and about protecting
the publics' health and their critical perception of our beaches. Answering these concerns
will take the Wisdom of Solomon!
I am here today because I am deeply concerned about the quality of our ocean waters. I
place at your disposal all of my knowledge and experience in these matters of water and
wastewater treatment and environmental impacts. I do not propose to dictate your tough
decision, but I will support whole- heartedly the right decision that reflects "good
science". I am in a difficult position as a former employee of both Los Angeles County
and Orange County Sanitation Districts. As such, I know more than most about the hype
and the reality of ocean wastewater disposal. There are surely daily as well as cumulative
effects —just look in the mirror and see for yourselves.
I can assure you that nothing we do is without some environmental effect, regardless of
any agency's opinions and attempts to sell their position. At my level I know the agency
staff were honest and hard working. They were also loyal and committed to whatever the
District policy was, in spite of any internal disagreements over that policy. However, I
must now look to the future for my children and grandchildren, and at my age this is
foremost in my mind. Even if they will never have `St" as good as I, it is only fair that
they be given the greatest opportunity possible to live happily within the available
resources and enjoy amenities we do leave behind, including clean beaches. Orange
County faces limits; those of our making should not adversely impact future generations.
Today's decision should keep this fact in mind. This is why it is so important to have the
wisdom and experience of others no longer dependent on the system whose future you
will decide. The staff report put together by Dave Kiff for today's meeting is excellent,
informative and well done, but it does reflect a bit too much an OCSD point of view.
Had I written it you would be reading something with a different point of view!
Sincerely, and wishing you good luck,
4+, �
Irwin Haydock, PhD.
Attachment: Some Additional Background Notes
CWA SECTION 301(h): The 301(h) exemption was codified in CWA amendments of
1976 and "waived" the Full Secondary Treatment requirements of the 1972 Act. One of
my most important duties during the early 1970s was to assure that this exemption would
be passed by Congress, especially to benefit those agencies discharging to "deep" coastal
shelf waters here in southern California. Our success in doing just this was short lived. It
became quite apparent that the Federal EPA administration was not interested in having
to deal with this narrow exception to a basically simple requirement for a nationally
applied standard of Full Secondary Treatment. It may not have been totally right for
every situation but it was fair, involved a safety factor of being a living biological
process, and remains simple to administer. But, for the next decade, much of my effort
was spent in justifying continuance of the Waiver for Los Angeles. I wrote or supervised
the writing of many, many reports detailing why Los Angeles deserved a Waiver, in spite
of the fact that they discharged into "stressed" waters offshore of Palos Verdes. This
shelf was recently declared the nation's only ocean Superfund site, and the court recently
awarded well over $100 million in damages to the Federal Government, $44 million of
which was paid by the citizens of LA/Orange County.
MY BACKGROUND: I recently retired from over 30 years working as Supervisor,
Manager and Chief Scientist of Ocean Monitoring and Research Programs for the
Southern California Coastal Water Research Project (1969 -73), Los Angeles County
Sanitation Districts (1973 -87) and Orange County Sanitation District (1988 -97). I was
mostly trained as a marine scientist, attending several marine laboratories at La Jolla
(SIO/NMFS), Pacific Grove (Stanford) and Pacific Marine Station (UOP) then at the
mouth of Tomales Bay. I earned BS (CSUSLO,60) MA (UOP,62) and PhD (UCD,68).