March 31, 2005

                                                                                                Central Ohio Sierra Club

                                                                                                36 W. Gay St, Ste. 314

                                                                                                Columbus, OH  43215

Division of Sewerage and Drainage

Public Information Office; 910 Dublin Road; Columbus OH  43215

DOSD@columbus.gov

 

COMMENTS ON PRESENTATION FROM PROJECT CLEAN RIVERS PUBLIC MEETING #2 MARCH 2, 2005

 

GENERAL COMMENTS

 

Technical documents to comment on are lacking.

Meaningful review and feedback are limited when specific documents are not accessible.  Drafts of the Long Term Control Plan (LTCP) and the System Evaluation Capacity Assurance Plan (SECAP) should be available, in hard copy and on the web.  There is not enough information in the March 2 Powerpoint presentation.

 

There must be ongoing public information, input, and involvement.

Because the underlying technical information is lacking at this time, continuing opportunities for public review, input, and involvement are essential.  We suggest:

            Create a central repository for document access and information requests.

Important technical reports, maps, and planning documents must be available and accessible.  It would benefit the public, interested parties, and the Utilities Department itself to have an archives section.  It could also be the center for information requests.

            Continue and expand the effort to post information on the DOSD website.

More information is appearing on the DOSD website.  This effort should be supported and strengthened.  Post data and maps of overflows, basement backups, and bypasses.  Add capital improvement information.  Important planning documents should be posted or summarized with full document availability at a departmental library.  Make public weather data being collected.

            Build consistent, meaningful public participation.

Public involvement and feedback is especially important during planning this year, but the need will not end July 1.  Consistent and meaningful public involvement could include:  continuation of community meetings for capital projects, ongoing public advisory group, soliciting and inclusion of public comments in planning documents, and regular public briefings or meetings.  DOSD can do a better job of including taxpayers in the expensive effort to clean up central Ohio waterways.

 

Collect data that will support goals of eliminating SSOs and surcharge-caused basement backups, as well as minimizing CSOs and plant bypasses.

Data collection efforts should support elimination and reduction of SSOs, basement backups, CSOs and bypasses.  The following data must be be documented and reported:  dates and times of raw sewage discharge occurrences, locations, volumes.  Information should go not just to OEPA, but also on the DOSD website.  Blending emissions should be documented as bypasses. 

 

Set quantifiable goals for elimination of SSOs and surcharge-caused basement backups, and reduction of CSOs and plant bypasses.

Freely available data on dates, volumes, and locations of SSOs, basement backups, CSOs, and bypasses will make it possible to measure progress.  Planning documents can set numeric goals, such as a zero level of SSOs and surcharge-caused basement backups.

 

Wastewater treatment plants should be enhanced and expanded.

The treatment plant proposals only present modeling and a reliance on blending.  Existing capacities are likely limited by solids handling, which is not addressed.  We advocate improving sludge handling options with technologies that will reduce sludge volumes.  We support increasing capacity by adding a new treatment plant and expanding Southerly as much as possible.  Improve biological treatment rather than bypassing it.

 

Treatment alternatives other than blending must be available for peak flow treatment.

High rate treatment is a type of blending, bypassing secondary biological treatment.  It has not been approved by the federal or state government.  We do not support planned reliance on blending, high rate treatment or otherwise.  With blending, many contaminants remain in wastewater, permit limits may be violated, water quality will decline, and solids handling constraints will still limit treatment.  It is not wise to rely on treatment techniques that will degrade water quality and which may not be approved.  Other alternatives must be available.

 

Receiving stream characterization efforts should be improved by integrating existing high-quality data and collecting more information centered around discharge points.

There is plenty of good data that has been collected by government agencies, OEPA, ODNR, or USGS for example.  At the very least, DOSD data should be compatible.  There should be sampling upstream, downstream, and at sites of every CSO outfall, SSO outfall, and treatment plants.  The results presented March 2 are anecdotal and based on insufficient data.

 

There is not sufficient information on Long Term Control Plan CSO control alternatives.

There is almost no information on new alternatives recommended to manage CSOS.  There needs to be written explanations and maps available.  The recommended alternative should reduce overflows from Whittier Street tanks better than 40%, ideally 70% or more.

 

The Sierra Club supports separation of stormwater from sanitary wastes.

 

There is no acceptable level of SSO discharges.

The presentation seems to aim toward a “10 year level of service” as acceptable.  SSOs are illegal and the goal should be elimination.  Charts computing level of service are based on insufficient information, an assumption of blending, and unexplained data.

 

Management, Operations, and Maintenance progress should be quantified and quantifiable.

Provide broad measures that can quantify and show real system-wide improvement:  how many miles cleaned annually, how many repairs annually, how many complaints by category, e.g.

 

Fats, Oils, and Grease controls can be improved even more than the proposed changes.

All changes should be incorporated into the Columbus City Code.  The already existing limit on discharge of FOG can be made stricter and enforced more aggressively.  Suggested requirements and penalties should be extended beyond Food Service Establishments to any large center of food preparation:  Schools, Hotels, Catering Services, Markets, Bars with food, Grocery Stores, Butchers, Delis, Hospitals and Office Buildings with Cafeterias, e.g.  The definition itself is not clear and probably should be detailed in proposed changes.

 

Specific programs are needed to mitigate rate hike impacts on low income citizens.

 

 


 

SPECIFIC COMMENTS

Page numbers correspond to pages of Powerpoint handout.

 

Introductory Section

1:  Ongoing Wet Weather Efforts

            -Improved operations and maintenance needs quantification for last 7 years.

                        How many miles cleaned annually?

                        How many repairs?

                        How many complaints and what kind of complaints?

2:  Columbus’ Commitment to Improvement

            -What is the basis for cost projections?

                        There have been steadily increasing estimates over the last year.

                        The real cost could turn out to be significantly more, 10 billion?

            -Management, Operations, and Maintenance improvement needs more info.

 

Wastewater Treatment Plant Optimization

3:  Objectives

-Add objectives of enhancing biological capacities of treatment plants, increasing storage capacity at treatment plants through lagoons or holding tanks, improving solids handling, and increasing plant capacity.

 

4:  Comprehensive Evaluation

            -Will the Southerly steady-state model account for seasonal solids fluctuations?

                        More solids in winter because compost and land application slow.

            -The final clarifier capacity is limited by solids handling capability of the digesters at Jackson Pike and the land application/compost/incineration at Southerly.  Even if the clarifier capacity is increased, the system will still be limited by solid handling constraints. 

-Southerly solids handling technologies should be improved:  Land application carries many risks and heavy metals are a concern.  Composting does not work effectively in the winter.  Incineration can have severe emission problems.  Landfilling sludge is expensive and wasteful.  Present sludge handling at Southerly relies on problematic techniques and can only handle a limited amount of solids.  Southerly needs better technology and more of it.  The current analysis is looking only at increasing front end flow-through capacity and not at increasing and improving solids handling.

5:  Main Alternatives Considered

            -These alternatives are not explained in any way and are not clear.

-There needs to be other alternatives considered.  The list as it stands does very little to increase the total flow-through of the facility, which would reduce collection system backups.  Solids handling and disposal will remain constraints that limit the system.  Technologies that could both increase solids handling capabilities and quality include:

                        Ultraviolet treatment

                        Equalization lagoons at Southerly that can store wet weather volumes

                        Digesters at Southerly

                        Non-blending increases in plant capacity, including biological capabilities

                        Constructed wetland treatment

                        Adding a third treatment plant

            -The listed alternatives do not appear to offer anything that will help prevent blending and they may, in fact, be setting the stage for reliance on blending.  The slides on page 5 and 6 do not offer any substantive new alternatives.

6:  Conventional Blending Configuration

            -This primary treatment plus chlorination approach is little better than a CSO with some solids and floatables removed.  The super high chlorination needed for bacterial and pathogen reduction would harm receiving waters at times of low flow.  Other chemical additions like sodium bisulfite can mask chlorine but do not remove it.

6:  Advanced Blending Configuration

            -85% reduction of Total Suspended Solids is not good enough.

            -60% CBOD reduction is certainly not good enough.

            -The high rates of chlorination required will harm receiving waters at low flows.

            -Much more data is necessary to evaluate whether NPDES permit limits will be met.

6:  Blending Evaluation

            -This approach is a guarantee that blending will be used.  There is no plan presented, and there needs to be one, for improving biological treatment capacity and solids handling.

            -There needs to be proof that limits would be met even if blending were used.  In other words, data on peak flow volumes and contaminant concentrations.

            -Serious consideration is needed for alternative technologies that do not rely on blending and will improve both capacity and quality:  ultraviolet, digesters, equalization basins or lagoons, wetland treatment, increased conventional capacity.  Certainly others exist.  What is presented here is a recipe for dependence on blending.

            -Reliance on blending is a risky strategy as this treatment technology may not be sanctioned at the federal or state level.

7:  Status/Next Steps

            -The whole topic of better solids management is ignored. 

-Modeling must consider sludge disposal limitations

 

Receiving Stream Characterization

8:  Sampling Sites 

-Why are there only 4 SSO sites?  Testing is needed in and around SSO outfalls.

- Also need testing of the Scioto upstream of the Dublin Water Plant.

-Comprehensive testing should be done upstream and downstream of all CSO and SSO outfalls, and the treatment plants.

9:  Water Quality Data 

-There is not enough data.  More coverage is needed, of time, events, and better spatial coverage.  The biology reports are only anecdotal; if the biology is improving, then data could support upgrading the aquatic life use attainability designation.

-Testing standards and protocol need to be compatible with OEPA methods.

-Available data from testing or sampling of OEPA, ODNR, or USGS should be utilized.

10-11:  Charts of Bacterial Levels

            -Bacterial levels shown even in the minimal data presented are very high.  There are charts showing levels 100 to 1,000 times the limits.

            -More information is needed to make the specific charts meaningful:  stream flows, weather, upstream industries or community characterization.  Data should be collected over a longer time period with more events.

            -Should expand testing for other parameters:  BOD, ammonia, phosphate, nitrate, e.g.

            -There should be sampling upstream, downstream, and at the site of every CSO outfall, SSO outfall, and treatment plants.

12-13:  Charts of Dissolved Oxygen

            -Need context for data:  river flows, rain events, etc.

            -Need more data over longer time.

13:  What Does This Mean?

            -The results presented here are anecdotal, based on insufficient data.

            -Even with sketchy data, there is clearly an existing bacterial problem.

            -Dissolved oxygen limits are exceeded, even based on sketchy data.

            -There needs to be a more comprehensive effort to gather data:  from existing data sets of OEPA, ODNR, USGS; over a longer period of time with many more precipitation events; with better coverage upstream, downstream, and at discharge points.

 

Development of the Long Term Control Plan

            -Technical documents laying out the recommendations should be available.  There is no publicly available information on the new alternatives that are being presented.

14-15:  Introduction        Good introduction.

16:  Recommended Alternative

-It is not clear that this is a transport and treatment alternative.  A map should be included with more explanation of the alternative.

17:  CSO Interim Requirements

            -There is a bullet point “Increase treatment capacity of wastewater treatment plant by 50 million gallons per day.”  Why is this not mentioned in the treatment plant section?  Which plant will be expanded?  How?  It would not be acceptable to plan on an assumption of blending.

            -40% capture of the annual overflow volume from the Whittier Storm Tanks is not good enough.  The consent order specifies a significant reduction; 50 % is the minimum that would seem acceptable, but 70% or more is desirable.

17:  Collection System Alternative 

-Whittier Street Storm Tank discharges should be strictly monitored, measured and reported.  The new alternatives are not explained:  there needs to be more information and explanation available.

            -The Sierra Club advocates complete separation of storm water from sanitary wastes.

15-20:  CSO Alternatives

-There is simply not enough information to provide the details of the options considered.  New proposals have been generated since the TIA report.  There is no written document, explanation, or maps generally available explaining differences.  Alternative 13, the recommended alternative does not have any additional explanation.

-Are any additional dams being proposed?  Would Alternative 13 river crossing change the grade of the river?  The Sierra Club does not support additional dams.

-What is the proposed “Near Surface Conduit?”  Where does it begin?  Where does it end?  What is connected to it?  What is the purpose?

-Is there any plan to pump effluent north from Jackson Pike to discharge into the river above the treatment plant?

 

System Evaluation and Capacity Assurance Plan

-Technical documents laying out the basis for recommendations should be publicly available.  Interested outside parties have never heard of the Large Scale Systems Strategy Memoranda and certainly do not have a copy.

23:  Priority Areas

-There is a need for public information on these areas:  access to Infiltration and Inflow studies, capital plans, and the drafts of any reports being prepared.  Why was the Dec. 15, 2000 storm used as a basis – what was magnitude or total rainfall and what size event was it?

23:  Recommended LSSS

-There is not enough information or discussion here on the choice of technology for the largest part of the whole wastewater system.  The most crucial part of the consideration is missing.  All that is left is sizing.  This section needs dramatic expansion of information.

            -There is a note of a large pump station at Jackson Pike.  What is the purpose?  What would it be pumping and where?

            -Why does the recommended strategy exclude priority areas?

            -There should be one map showing the SSS recommended installations along with the CSS proposed pipes and facilities.  Also, how they would connect, or not.

24:  Three Step LSSS Process

            -Define an ‘acceptable’ level of overflow.  Since SSOs are illegal, why is any planned level of sanitary sewer overflow acceptable?

25:  Level of Service Cost Basis

            -What flow meter data is being used?  Where were they placed and for how long?  Since there are so many SSO points, it matters what was being monitored. 

            -This chart seems to be based on the assumption of high rate treatment.  There needs to be a planning calculation not based on blending technology.

26:  Charts of Level of Service

            -Were charts based on flow meter readings or simulated flow data?

            -Where were BOD samples taken?  How often?  Dry weather or wet weather overflows? 

            -There needs to be more background information on how the charts were generated.

            -There are not many data points.

28:  MOM Update and Progress

            -Improved operations and maintenance needs quantification for last 7 years.

                        How many miles cleaned annually?

                        How many repairs?

                        How many complaints and what kind of complaints?

 

Update on FOG Program

29:  Proposed New FOG Program

            -All proposed changes should be incorporated into the Columbus City Code.  The language is broad and may affect many parties, who need adequate notice and to be able to access the laws online.         

-The discharge limit in Columbus City Code 1145.25 is 200,000 micrograms per liter.  We suggest lowering the discharge limit to 150,000 micrograms, as other cities have done, and enforcing the standard.

-There are many sources of FOG that may not be covered by the new initiative:  Schools (public and private), Hotels, Catering Services, Markets, Bars that prepare food; Grocery Stores that package meat or food; Butchers; Delis; Hospitals with cafeterias; Office Buildings with cafeterias.  All significant sources of FOG should be included, whether or not they are in the definition of Food Service Establishments.  The definition itself is not clear and probably should be explained in the language of the proposed changes.

-When sewer lines are cleaned, hardened FOG deposits should be kept out of the system permanently by being burned or taken to a biofuel facility.  FOG should not be returned to the system through dumping at the truck waste facility at Berliner.

 

 

Affordability Analysis

            -This should not be just a way to gain more time to eliminate and reduce overflows. 

-Specific programs are needed to mitigate the impact on low-income population, especially renters. 

-This section would benefit from specific programs to help the poor, a justification of costs, and oversight of large expenditures.

- The charts on p. 34 and 37 have no captions and are difficult to understand.

 

 

 

Cyane Gresham
Water Quality Coordinator
Central Ohio Sierra Club
36 West Gay Street; Ste 314
Columbus, OH  43215