COMMENTS ON PUBLIC MEETING AND TECHNOLOGIES INITIAL PLAN
TO: Columbus Dept. of Public Utilities, Division of Sewerage and Drainage
(Laura Young Mohr, Steve Salay)
COPIES: Columbus City Council, Utilities Committee (Patsy Thomas)
Columbus Mayor’s Office (Steve Campbell);
Ohio EPA Div. of Surface Water, Permits & Compliance (Paul Novak)
FROM: Cyane Gresham, Central Ohio Sierra Club
36 West Gay Street, Suite 314; Columbus OH 43215
RE: Public Meeting and TIA Report
DATE: September 16, 2004
The technical information presented at the August 31 meeting included:
-DOSD introduction on the waste water system, consent orders and overflows,
-Brown and Caldwell presentation on the Management, Operations, and Maintenance (MOM) program,
-Brown and Caldwell presentation on wet weather mitigation,
-Brown and Caldwell presentation on Large Scale System Strategies (LSSS) and System Evaluation and Capacity Assurance Plan (SECAP),
-Malcolm Pirnie, Inc. presentation on the Long-Term Control Plan Technologies and Initial Alternatives Report (LTCP TIA).
These comments follow the subject and organization of the meeting, preceded by general process suggestions. Each section has major points followed by a narrative.
PROCESS OF PUBLIC INVOLVEMENT
· Have more public sessions: at least one per major report/project.
· Publicize the information sessions to ensure good attendance.
· Assure that public input will be incorporated and influence the process.
· Continue a Public Advisory Group.
· Make information more accessible.
One public session in a six month period is not sufficient to cover such extensive information. There should be at least one meeting per large topic: one meeting for the LSSS, one for priority areas, one for SECAP generally, one for the TIA, etc.
Public input can direct the planning process and is important before final reports are generated. Interested parties need to be involved in an ongoing effectual way.
The Public Advisory Group is one way to continue involving stakeholders outside DOSD. It should continue to operate and be expanded (with the Sierra Club involved).
Important planning documents must be publicly available. Posting on the DOSD website is always preferred. Electronic and hard copies should be given to those who request them. DOSD Public Information Center should have high-quality hard copies of all major documents in binders available for viewing at the Utilities Center. This includes high quality maps, diagrams, tables, and charts, which may not reproduce well.
DOSD PROJECT CLEAN RIVERS
· The public interface component is inadequate (see above).
Six public advisory group sessions are a start - the process should be extended. There need to be more than three open meetings during the year between now and July 2005. “Public involvement” requires more than an update on what has been decided during the previous four months. Stakeholders outside DOSD must be informed in an ongoing and effective way – most of the attendees on August 31 were contractors or from DOSD.
Hearings of the Sewer and Water Advisory Board and City Council do not provide an adequate forum for public input because of time constraints.
CONSENT ORDERS AND WET WEATHER ISSUES
· Post on the DOSD website: map and list of SSOs, map and list of CSOs.
· Monitor and report occurrences of SSOs and CSOs; report on DOSD website.
· Monitor and report volumes of SSOs and CSOs; report on DOSD website.
· Post on the website when overflows occur: clear warnings, location & maps
· All reports required by consent orders should be publicly available: website, hard and electronic copies, and also available for viewing at DOSD.
MAINTENANCE, OPERATIONS AND MANAGEMENT PROGRAM (MOM)
· Post a map of priority areas on DOSD website.
· The program should emphasize preventative sewer maintenance, cleaning and repairs, focusing especially on older sewer lines, along with the monitoring.
· Educate restaurants and the public to avoid putting grease down the drain. Strictly enforce the grease ordinance.
WET WEATHER MITIGATION
· Do not base planning strategies on blending.
Considering technologies of source control, conveyance, storage, and treatment are fine. It would be better to explicitly include reduction and conservation of waste water and growth planning based on infrastructure requirements.
Blending does not solve overflow problems. Regulations easing restrictions on blending have not been implemented and should not be.
SYSTEM EVALUATION AND CAPACITY ASSURANCE PLAN (SECAP) AND LARGE SCALE SYSTEMS STRATEGIES (LSSS)
· The LSSS Technical Memorandum needs publicizing and evaluation.
· Initiate an open discussion of LSSS alternatives rather than assuming that Alternative A is already fixed.
· Post maps of Priority Areas on the DOSD website, along with sites, occurrences and volumes of SSO events.
· Do not go lower than one year level of service.
· The elimination of SSOs quickly should be explicitly addressed. The LSSS is a long-term plan and does not accomplish that.
· Stopping basement sewage backups is a priority. Project Dry Basement may help a few but does not accomplish the goal of stopping sewage backups.
The August 31 meeting was the first public discussion of the LSSS report results. It is unacceptable for a controlling technological alternative approach to be chosen with no public notification and extensive discussion. The August 31 meeting presented the use of centralized, deep tunnels, with high rate treatment separate facilities for combined and sanitary systems as the chosen approach. Open and inclusive consideration of other planning approaches is essential, as future planning is constrained by the choice of large scale strategy.
Level of service should not go below one year, and the goal should be for a higher level.
COMBINED SEWER OVERFLOW LONG TERM CONTROL PLAN TECHNOLOGIES AND INITIAL ALTERNATIVES (CSO LTCP TIA) REPORT
· We support complete sewer separation.
· Stormwater should be mitigated in all scenarios and not directly discharged.
· Any mixed storm water and sewage should be fully treated before discharge.
· Monitor receiving rivers extensively, especially with bioassessment methods: Index of Community Integrity for fish, Index of Biotic Integrity for macroinvertebrates, modified index, and Qualitative Habitat Evaluation Index.
· Level of control and service should not be lower than 12 months/1 year.
· Do not base planning on lowering of Water Quality Standards.
The summary mentions evaluation based on bacterial and chemical parameters, the introduction mentions improvements of chemical and biological water quality. Water quality evaluation should explicitly include biological monitoring and assessment. Neither chemical nor biological water quality standards should be lowered or degraded. In fact, if water quality is so improved, perhaps the water quality standards should be upgraded.
1.2.3 Page 1-1: The initial sizing is for a one year storm event. Sizing and level of service will ideally protect from even larger precipitation and will not be reduced below the 12 month level.
2.1 Page 2-1: Biological monitoring of fish and macroinvertebrate populations is important to fully assess water quality. If it is not being done by DOSD, it should be started immediately. Other sewer districts do their own biological monitoring, e.g. Northeast Regional Sewer District near Cleveland.
Tables 3-1 and 3-2:
· Does each sewershed have an overflow associated with it?
· What is the time unit for Total overflow volume: measurement, day, year?
· Are all 31 permitted CSOs and any unpermitted ones included in the 29 listed sewersheds?
· It was stated publicly by DOSD at the Aug. 31 meeting that Whittier Street is responsible for 90% of CSO discharge. The overflow volume and peak rate do not reflect that, unless other sewersheds outfall at the Whittier Street tanks.
3.2.3 Page 3-5: It is noted that 11 CSO discharge points are significant. Provide more information on numbers of occurrences per year and total volume.
Chapter 3: Review of possible CSO Control and Treatment Technologies
· The sizing data in Tables 3-1 is based on App. B, C, and D: see comments below. It certainly does not support the contention that Whittier Street is responsible for 90% of CSO discharge. Data in the Appendices is surprisingly sparse.
· Complete separation of sanitary and storm water would stop CSO discharges.
· Redirection of upstream sanitary and storage does not stop CSO discharges.
· Simply relocating CSO discharges to other places is an unacceptable solution.
· Stormwater should be mitigated in all scenarios and not directly discharged.
· Stormwater storage facilities must be cleaned and maintained. The Alum Creek tanks are an example how storage capacity is lost through build-up of debris.
· Planning through TIA and LTCP should not be based on lowering of water quality goals.
Chapter 3 discusses eleven technologies, although only ten are evaluated in the matrices.
-Complete sewer separation: scored fairly high
building new sanitary sewers in the CSS area
-Sanitary Sewer Redirection from Existing CSS:
redirects sanitary inflow upstream away from the CSS in new connecting sanitary sewers; CSO outfall continue in the CSS
-Storm Inflow Redirection Within Existing CSS: scored highly
construct new storm drainage in CSS, but appears to allow continued CSOs
-Separate Storm Inflow Storage (Upstream) of CSS
leaves the CSS and outfalls; stores large volumes of stormwater before entering
-Upstream Storage of Combined Sewage: scored highly
CSO discharge points remain, storage built upstream
Off-Line like Alum Creek Standy Storage Tanks or
On-Line like storage in OSIS pipe upstream of Whittier Street
-Downstream Storage of CS: scored highly
CSO discharges points remain, storage built downstream of regulators
-Consolidation or Relocation of Existing CSO Discharge Points: scored highly
bring discharge points together, most are close
Relocation means relocating discharges to less sensitive areas of the streams
-Floatable Removal for Existing CSOs
-Primary Treatment Facilities for Existing CSOs
-Advanced Primary Treatment
Facilities built near CSO outfalls where possible, many do not have space
-Peak Flow Biological Treatment at WWTP
Not discussed much and not evaluated in matrices
We support elimination of CSO discharges. Complete separation of sanitary and storm water would accomplish that goal. That is our preferred alternative.
Leaving the CSO system and outfall discharges allows untreated sanitary sewage to continue to be discharged. Consolidation and relocation do not solve the problem. In-line storage in big pipes also does not solve the problem and may be as costly as a new sanitary system. Off-line tanks do not solve the problem, and in fact will not help at all if they are not maintained (example, Alum Creek storm tanks).
Although the document only discusses roof leaders, the greatest volume of storm water comes from roads and impervious surfaces. Stormwater from roads is probably the biggest component of runoff and has the most contaminants. Even if separated, storm water needs to be handled so that it does not degrade water quality.
Planning should not be based on lowering of water quality standards.
Chapter 4: Screening of CSO Treatment Technologies
· The qualitative technology rating matrices would be more believable and persuasive if there was some variation in the scoring.
· Evaluations would benefit from greater loadings of environmental parameters.
· Include Peak Flow Bacterial Treatment in rating matrices from page 4-17 on.
All 29 of the technology rating matrices are so similar they are almost the same, leading to the appearance of a predetermined outcome. It is clear that the technologies preferred by the consultant and/or client DOSD are: stormwater inflow redirection & in-line storage.
Chapter 5: Possibly Viable Alternatives
We will submit more detailed comments on the specific technology alternatives.
· The attachments from the CSO Consent Order should include the list of CSOs in Attachment B. The TIA Appendix now has only a map, and no CSO list.
· Although the text on p. 3-3 and 3-6 states that the charts are based on information from January 2000 to February of 2004, the data is sparse. More data input is needed.
· Each chart should state over how long data was taken and how many readings were used.
· Why are there only 18 charts when there are 31 CSO points?
· The text p. 3-3 and 3-6 states that these charts are likely at or above a one year event. What is this supposition based on?
· The data on which these charts are based is too sparse.
· Each chart should state over how long data was taken and how many readings.
· Why only 18 charts?
· Why are these charts “likely” at or above a one year event? Based on what?
· This data is from September 2003 through May 2004. Why such a short time?
· The text on page 3-3 and 3-6 says that volume was estimated. There needs to be explanation and clarification.
This data appears to supplement locations missing from Appendix A. That should be clarified.