Environmental Press # 76

Subj: OOG: OCSD Resolution & Votes, RWQCB Meeting Tomorrow, Friday, 9 AM,
Date: Thu, 18 Jul 2002 10:28:25 PM Eastern Daylight Time
From: Jon V3
To: Jon V3

Dear Ocean Outfall Group (OOG) dedicated to ending the 301(h) waiver held by the Orange County Sanitation District (OCSD):

Thanks for all your appreciative notes and congratulations. It was a group effort by all, and the hard work paid off. If you want to see the actual Resolution passed last night, go to ocsd.com and click on What's New. The Resolution is there as well as the roll call vote. However, after the meeting, Alice Jempsa of Los Alamitos told me she was going to change her "no" vote to a "yes" vote, bringing the final tally to 14 to 11 in favor of the Resolution.

Our work is not finished. As you may remember, one of OOG's principles is ultraviolet light disinfection of the discharge, not bleach. Tomorrow at 9 AM, Friday, July 19, the Regional Water Quality Control Board (RWQCB) is going to discuss the bleach proposal, as well as receive a report about water quality from Ken Theissen, and propose a change in the toxicity testing requirements, and a change in the water quality standards to extend to the whole water



column, not just the top 10 feet. The meeting will be at the Orange County Water District offices, right next to the OCSD offices at 10500 Ellis Ave. Fountain Valley.

Here is the Agenda: http://www.swrcb.ca.gov/~rwqcb8/pdf/020719a.pdf.

Here is the report on the bleach proposal:

Here is the report on the water quality of the beaches: http://www.swrcb.ca.gov/~rwqcb8/pdf/07-19-02/12.pdf.

After reading these reports, consider supporting the following issues in your comments to the Board. Broad-based support is essential:

"While we are strongly supportive of improved treatment, we nevertheless believe the Regional Board, EPA and the Orange County Sanitation District should make significant changes to the open-ended Draft Amendment before it is adopted.

Our concerns can be summarized as follows:

· First, the proposal to chlorinate/dechlorinate the effluent will not be fully effective in protecting human health and it is open-ended.

· Second, the proposed disinfection will prevent the District and regulators from tracking the plume through measurement of bacteria indicators.

· Third, the proposal will allow the District to dump up to 147 metric tons per year of additional toxic constituents into the ocean, creating potential additional adverse environmental and human health effects.

· Fourth, the proposed modification is being “fast-tracked” with limited public disclosure about to the details of the proposed process, and inappropriately limited time for full public review and comment.

· Finally, disinfection is being required without any express acknowledgment in the permit findings that the District’s discharge is causing or contributing to the failure to maintain water quality standards and without taking required steps to discontinue the District’s Section 301(h) waiver. "

Essentially, we want to make sure OCSD is using bleach as only a very short term method of disinfection, and the commitment to ultraviolet light disinfection is made at the start. As you may recall, UVL is effective for secondary treated effluent, but not primary, because the effluent is clearer after secondary treatment. OCSD could UVL disinfect the 120 mgd of secondary treated effluent right now, and move up to 165 mgd next year. The $8 million it costs for one year of bleach would nearly fully pay for a permanent UVL system that treats 100 mgd of secondary (the capital cost of UVL for the GWRS project is $9,749,405, according to yesterday's OCSD agenda item 12d). Thus, it will be cheaper in the short term and long term to begin UVL disinfection immediately. It will save on ultimate capital costs as well as eliminate the need for trucking in bleach and dechlorination chemicals, and prevent contaminating the ocean with further chemical pollution. This commitment and move to UVL should begin immediately. Let's not allow OCSD to get away with this bleach blunder.

Thanks again, and see you tomorrow.

Jan Vandersloot (949) 548-6326


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