Environmental Press # 83

Subj: OOG: Fwd: Original Blake letter to the directors
Date: Sat, 27 Jul 2002 5:54:05 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):

Forwarded is a letter sent by OCSD General Manager Blake Anderson to the OCSD Board and Staff two days ago. It's a good letter, and could just as well have been sent to the public. In fact, I spoke with Blake yesterday, and he gives encouraging news that the staff feels the waiver is gone, and that they will be ramping up secondary treatment, and that addition of more chemicals to the Advanced Primary Treatment has reduced BOD to 45. I asked him to consider writing a letter to the public and it may be worthwhile to have an OOG meeting with Blake some weekday morning to go over what's next. Blake really wants microfiltration to work because of the argument of less biosolids, less energy, less air emissions. Whether this non-biologic treatment is acceptable to the regulatory agencies is an open question, because the Clean Water Act requires "significant biological treatment of wastewater", and MF is not a biological treatment. Maybe there is a combination of MF and conventional secondary



treatment that would be acceptable that could meet the 30/30 standard, or perhaps if an oxidative process is required for reclamation, then all of it may have to be secondary treatment. Blake also felt that the directors' vote would not have been so close except for the last 10 minutes where the question of fines and penalties dampened the enthusiasm for increased level of treatment without the waiver. At any rate, secondary treatment will be gradually increased, because if it is ramped too quickly then the good bugs get washed out the back end and the BOD goes up. So look for gradually increased secondary treatment to 65% shortly, from the current 53%, and that's all for the good.

Jan Vandersloot (949) 548-6326

Subj: Original Blake letter to the directors
Date: Sat, 27 Jul 2002 13:16:01 -0700
From: Doug Korthof <doug@seal-beach.org>
To: hillaryh@bigplanet.com
Cc: jonv3@aol.com

This attachement was sent to me by someone trusted, and I opened it successfully. Here is the text in clear:

An Open Letter to the Directors and Staff of the Orange County Sanitation District By Blake P. Anderson, General Manager
July 25, 2002


Last week, THE big question was answered, "How Should the Orange County Sanitation District effective protect public health and the environment in the future?" The answer is we will begin to disinfect our effluent in mid-August, 2002, and we will secondary treatment standards at the earliest possible date. The purpose of this letter is to provide an overview of what that means

Our Commitment to Achieve Secondary Treatment Standards On July 17, on a 13 to 12 vote, the Orange County Sanitation District Board of Directors directed staff to begin the process of modifying our treatment processes to achieve secondary treatment standards. That vote was an historical event, to be sure, with the Directors casting what can only be described as a "legacy vote," one that determines the future of Orange County Sanitation District for generations to come.

After hearing from the public for 45 minutes and following their own thoughtful, balanced and respectful discussion that lasted another 2 ½ hours, the Directors decided to change our existing level of treatment from a blend of 50% advanced primary and 50% secondary treated wastewater to secondary treatment standards. This means our effluent must eventually be 30 parts per million of Total Suspended Solids (TSS) and 30 parts per million of Biochemical Oxygen Demand (BOD). The board's decision, however, did not specify the treatment technology we must use. This gives us the latitude and flexibility to investigate and utilize the newest, most cost-effective processes available. You can find the resolution at..\..\GM\Bd. of Directors\Resolution_level_of_treatment_071702.pdf

At this time, we estimate that it will take 11 years to achieve both the TSS and BOD standards. That's the time it will take to plan, design, permit, construction, startup and achieve full peration of facilities that are expected to cost approximately $270 million. All of that work must be done while we continue to operate our existing facilities 24/7/365 and while also providing over a $1.6 billion dollars of other projects that will replace, rebuild, upgrade, or add other facilities also needed to serve our community over the next 20 years.

This does not mean that we won't be making progress in the meantime. Far from it. Operations staff has already begun work to provide improved removal efficiencies for both TSS and BOD. Improvements will begin to occur in the next several months.

But Why the Change? And What Does It Mean to Other Programs?

For the last 20 years we have employed the existing level of treatment for four reasons. First, we have years of convincing data that has led us to believe that the beneficial uses of the marine waters off Orange County are adequately protected. Second, that the other equally as mportant environmental considerations (air impacts, land impacts and energy use) are better served by the existing level of treatment. Third, that we have consistently achieved all of the regulatory expectations of the State of California and the Federal Government as expressed in the permits they have issued to us and the observations and findings they have made of us. Fourth, that we have achieved considerable cost savings by our 50:50 treatment method.

Nevertheless, the Directors decided to move to secondary treatment standards for several excellent and convincing reasons. First, the marine monitoring data cannot conclusively demonstrate that we haven't and can't impact beach bacterial quality. In fact, we have recorded incidents when our plume has been uncomfortably close to Newport Beach. Second, that upgraded treatment clears the way for future increments of additional water reclamation with the Orange County Water District. Third, that the public clearly favors upgrading wastewater treatment now. Fourth, that the cost for doing this is affordable for domestic customers. And, fifth, that the Sanitation District should show clear leadership in providing the highest standards of regional and environmental stewardship.

On the matter of our other environmental programs, including urban runoff management, water reclamation, and watershed-based management principles, the overwhelming majority of the Directors who spoke about these issues urged that we continue this good work. In other words, there was very little support expressed for "trading" what we have been doing for upgraded treatment. The Directors clearly are supportive of a visionary and proactive Sanitation District.

I wholeheartedly agree and will continue to manage this agency toward increasingly responsible and competent leadership in protecting water quality for this County and this Region.

Our Commitment to Disinfection our Effluent

Two days after our Directors took action to move to secondary standards, another important event occurred. On July 19, the California Regional Water Quality Control Board unanimously adopted modifications to our ocean discharge permit that will authorize us to use chlorine bleach disinfection followed by sodium bisulfite de-chlorination. We expect to have this disinfection in full operation by August 12, 2002. This is excellent news. It will mean that all remaining concern regarding the Sanitation District's role in contributing to AB 411 bacterial standard exceedances
will be fully answered.

You may recall that in early February, while conducting our own routine ocean-monitoring program, we detected our plume in the Newport Beach Submarine Canyon at depth but within a half mile of shore. You may also recall that by the end of February we had committed to disinfect our effluent because this was just too close for comfort. We wanted to be extremely confident that we would not in the future cause the California beach water quality standards (known as the AB 411 standards) to be exceeded in Orange County.

Now, with this recent action of the RWQCB accomplished, our staff, contractors and suppliers can completed the last of their very hard work to achieve the agreed-to August 12 deadline.

Staff engineers, scientists and operators have determined that the only way we could effectively and quickly provide disinfection is to use a chlorine-based method. Other methods were considered, including micro-filtration, ultraviolet radiation, ozone, and peracetic acid, but none of them can be implemented to provide a short-term solution.

We will continue to look at these alternatives and others over the next several months in keeping with our own commitment and with the terms of the permit modifications authorized by the RWQCB. In all likelihood, we will select another disinfection method for medium-term and long-term purposes. The studies needed to make the selection must be completed before decided what to do next. I won't even hazard a guess what will be our ultimate solution. But you can rest assured that whatever we do will fully evaluate all environmental consequences.

What's Ahead

Over the next several months, we'll be preparing a permit application to the EPA and the Regional Board that will not, for the first time in nearly 30 years, include a 301(h) waiver. Instead, we will be negotiating an agreement with the EPA and Regional Board that allows us to transition our operations over the next eleven years from our current permit limits to secondary standards.

Over the next few months we will ramp up additional secondary treatment as operations allow. This could result in approximately 65% secondary treatment-up from the present 53%. Over time, as systems are taken out of service and returned to service for necessary rehabilitation and upgrades, this level will move up and down. However, we can substantively improve our effluent quality by "revving up" what we now have.

Over the next few weeks we will begin to operate our disinfection and de-chlorination facilities. We did disinfect our effluent back in the old days-up until about 1972 when we started up the long 120" outfall and stopped using the short 90" outfall. You'll have a hard time finding many folks who were working here back then. But we successfully did it back then, and we can do it again. I would add that chlorine-based disinfection is by far the most commonly used method in water treatment and wastewater treatment facilities in the Country with long term success. We can be confident is using it here.

Over the next several months we will provide progress reports to the Steering Committee and the Board regarding TSS, BOD, permit, and budget implications. And, we will develop a 3-, 6-, 9-, 12-, 18-, 24- and 36-month forecast of TSS and BOD effluent concentrations.

As always, open communications will be maintained with the public at all times. All documents and reports submitted will be available on our web site www.ocsd.com and emailed to the board.

A Special Note of Thanks to Staff

I want to express my thanks and gratitude to everyone who played a role in all of this. Let me begin with the most recent efforts: the preparations and activities supporting last week's board meeting. Everything ran smoothly and I'm proud of the job staff did - from crowd control to security to parking. It was a well-coordinated effort. There were over 300 people on site that evening without a single serious incident. Traffic snarls were kept to a minimum and everyone was dealt with respectfully and fairly.

Next are the actions of the disinfection team that will be so important to a mid-summer start-up of our bleach facilities. Have their efforts been sustained! Once the decision was made in February to do this, a talented, tireless and creative group of staff from every department pitched in to decide on the method, figure out where to place the equipment, design the facilities, procure a contractor, buy the equipment, bid the chemicals, negotiate with the RWQCB, conduct hundreds of laboratory tests, put the paperwork together, and inform the public and the press. What a team!

And there's the even longer sustained effort that was required to conduct the millions of dollars of studies and perform the tens of thousands of hours of staff hours needed to provide a clear understanding of the conditions that impact the marine resources of our stretch of ocean. This information was critical to our Directors for making an informed decision. The ocean studies we conducted in 1999, 2000, and 2001 took weekends, nights, broken personal commitments, and eating too many damn microwaved corn dogs and mini-cheese pizzas. Staff from every division of this agency took part in that work at one time or another.

I want to also remember all of the onshore work that was done to eliminate our own Coast Trunk as a pollution source, the beach sand studies, the beach bathroom studies, the complex sanitary survey conducted by our staff, and the cooperative studies with UCI, the County and so many other local entities.

Our own engineering staff with the help of key engineering and environmental consultants recrafted our Strategic Plan to accommodate a number of options for the Director's consideration on the 17th. That was a daunting task, particularly considering the short time frame in which the work had to be completed and communicated to the Directors.

And finally, I want to acknowledge the communications team that provided support to all of this. Nearly everything that the press, the Directors, staff and the public heard, saw, read or contemplated required the professional and personal touch of the communication experts that work here.

In the end, this magnificent team of individuals did amazing things in an effort that first started in the summer of 1999 when the AB 411 standards changed. At that time, a member of our staff and of the County's staff met for the first time looking at some bacterial results and said something like, "this looks interesting?"

A Final Thought

Last week's actions end one chapter of OCSD's long and illustrious history and begins another. I continue to be proud to work here and to be a part of this team. It is a privilege to know people who are committed to protecting the environment, public health and the quality of life we enjoy in Orange County. I am confident that we will execute the board's decision in the most timely and cost-effective manner possible. We have always taken a leadership position in wastewater treatment and will continue to do so?working together.

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