1. "There are 37 permits, with 4 in california"
with 301(h) WAIVER out of 16,024 mostly inland cities. But Orange County
is the biggest, next largest is San Diego, which has international complications.
To see the rest of the waivers, http://StopTheWaiver.com/crazy301.htm
2. The vote on July 17th will be for just 2 alternatives. "Permit Limits" (all primary) and "advanced" are OFF THE TABLE.
YES -- continued dumping, lawsuits, testing, controversy
This is the showdown. Buena Park is needed to join the majority of people and cities against the waiver.
3. "...full secondary will not entirely eliminate virus or bacteria..."
is to the "30-30" standard in the Clean Water Act, the requirement
to reduce "Total Suspended Solids" (TSS) and "Biological
Oxygen Demand over 5 days" (BOD5) to 30 mg/liter.
Disinfection works much better on the resulting effluent since since most complex hydrocarbons are gone. Even more important, further treatment ("tertiary") to remove Nitrogen compounds (the smell) is much cheaper and easier.
The plain facts are that inland districts treat all primary, secondary, tertiary by one method or another. They get the "Total Coliform" content down below 3 per 100 ml (about 4 oz). The taste is bad, but the result is "potable", and can be discharged into rivers or wetlands for further treatment.
This is the way to get rid of our outfall entirely: pretend we are an inland city, and reuse *all* the 700 acre ft. per day of water now discharged!
4. "...bacteria will normally live 1.5 hours in salt water..."
Indications are that bacteria dumped off Santa Monica 20 years ago are not only alive, but thrive. And it's not just the bacteria, it's the virus, endocrine disruptors, and all the other nasty "suspended solids".
has approved disinfection to kill bacteria".
Disinfection of primary sewage is expensive, not very effective, and dangerous. Residuals often affect the habitat, even if disinfection were to be allowed. The cost would be more than $8 million per year, and increased monitoring would be an additional $5 million or more.
6. "disinfection of the discharge, if beach closures continue, will prove the outfall is innocent".
The issue is not "guilt" here. No one says the *only* problem is the outfall, it's just a contributor, along with urban runoff and crumbling infrastructure. When you have 3 potential causes for a problem, and you eliminate one of them, that's no "proof" that it wasn't part of the problem.
As Joan Irvine Smith pointed out, this is one problem that we can solve just by one decision. The other two potential contributors must dealt with as non-point source contributors.
No one is maintaining that full secondary will immediately clear up the beaches. So disinfection, even if it were allowed, and even if it were not a failure, would not "prove" a thing--except that we can waste lots of money on blind alleys instead of solving the problem straight on.
of full secondary is too high".
So the true cost of full secondary, even if OCSD reserves were not used, would be about $15m per year -- at most, a 33% increase over current O&M and a 7% increase in the total budget. This would be offset by savings (the GM testified they spent $14 million on ocean monitoring alone over the last 3 years).
8. "It will not remove all bacteria" but it will eliminate the $5m in testing, monitoring, and studies, which are required because of the waiver. In fact, if we treat to the potable level, we are not required to monitor receiving waters at all. This takes the sanitation district out of the oceanographic studies business. 9. "It will take up to 11 years to build the plant".
OCSD can go to 190mgd immediately, from the current 120mgd, which would leave only 50mgd of secondary plant deficit (plus margin).
showed that they could reach the TSS standard in a short period of time,
but needed additional
To find out more, call Mr. Don May, telephone on request, or former staff who spoke confidentially, or Dr. Irwin Haydock (firstname.lastname@example.org). The best estimate is 5 to 6 years, since OC's problem is not as complex as L.A.'s problems were.
10. "We need a waiver to avoid fines".
Once again: L.A. negotiated a sort of "consent decree" with the EPA, which allowed them to ramp-up without penalties. This sort of thing is common, any "trapping" of OCSD by the EPA is a phantasm, with no basis in fact. These agreements are standard operating practice.
11. "Cost to individual homeowner would be $192 per year".
If you look at those numbers, as Jim Hinch of the Register did, you will find that they are the projected cost in current dollars, of homeowner rates in 2020.
While figures vary wildly, from week to week, and no feasibility study has yet been done, the options are these:
COST BY 2020 (2002 dollars)
LEVEL OF TREATMENT: $163
That's right, by OCSD's own figures, they are planning to raise the rates to $163 per household by 2020, WITHOUT ANY OF THAT GOING TO BETTER TREATMENT!
What this really shows is that an audit is necessary as to how they spend the money, or rather, throw it around loosely with $170 Director fees, up to 10 meetings per month, catered food, etc.
Even by OCSD's own figures, the added cost of going to full secondary would be $32 per user, or less than a 15% increase over what they are going to charge for poor treatment.
What's more, these arguably bogus numbers do not account for the savings OCSD will achieve by less testing, monitoring, lawsuits, lobbying expense, travel and overtime expense in fighting for the waiver, and probably lots of other expenses they are incurring that could only be unravelled by an outside audit.
Hinch wrote a story showing that, by the GM's own statements, the difference would only be $18 per year. In fact, if you look at the value of the 700 acre ft. of water, the savings might outweigh the costs.
OCSD is planning to "donate" $300m and 8 acres to the Ground Water Replenishment Project, on the theory that it is cost-avoidance for a second outfall. However, we have seen that if we do things the correct way from the get-go, we can treat to the tertiary level (even L.A. does this, at the Sepulveda Basin, using water from the Tapia Plant, to revitalize the L.A. River) much more cheaply, and even get rid of the current outfall. The water can be fed into constructed wetlands and the Santa Ana River -- which could use some revitalization, itself.
12. "Industy can't stand the expense".
That argument, made by the GM, was contradicted by Kimberly Clark itself, when they were checked for reaction. The GM did not apparently know that K-C does pre-treatment to lower the TSS, by which they are charged, so that their increase would be much less -- and, they are moving toward full pre-treatment. After all, it's a lot easier to remove pulp from the wastewater prior to mixing with the "brown water" bacteria and virus.
The real reason why OCSD is so determined to keep the waiver? Many have wondered, but no one knows. However, there is one opinion which has lately been rumored:
"It's simple fear, and sloppiness. With the waiver, if they make a mistake, or encounter a problem, they can just dump the mix and catch up later, because they are evaluated by an average. But without the waiver, any mistake becomes, as it should, a fineable offense, and they could not only lose money, but their jobs, too..."
Who knows why they pay their people overtime to argue against Ratepayers who go on the city-by-city campaign. At Tustin, at Brea, at Westminster, even in Sacramento, OCSD staff were there, lone guardians of the waiver. NO citizens stood up and said they wanted the waiver. So the question is, who is paying for staff to do this? Are they ordered to go, and, if so, by whom? And how much are they paid? What is it billed to? It surely is not education, outreach or lobbying, when they oppose Ratepayers and argue for a policy position?
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