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HomeMy WebLinkAboutReso - CC - 025-1971RESOLUTION N0. 25-71 ENDORSING AND SUPPORTING THE STATEMENT OF THE SAN MATEO COUNTY WATER QUALITY CONTROL ADVISORY COMMITTEE ON THE PRELIMINARY INTERIM WATER QUALITY MANAGEMENT PLAN, SAN FRANCISCO BAY BASIN, CALIFORNIA WATER QUALITY CONTROL BOARD BE IT RESOLVED, by the Council of the City of Burlingame, California That the statements of the San Mateo County Water Quality Control Advisory Committee adopted on April 28, 1971, and attached hereto and made a part hereof are endorsed and supported. yo I, Herbert K. White, City Clerk of the City of Burlingame, do hereby certify that the foregdng resolution was introduced at a regular meeting of the City Council held on the 3rd day of May 1971, and adopted there- after by the following vote: AYES: Councilmen Amstrup,Crosby,Johnson,Mangini,Martin NOES: Councilmen None Absent Councilmen None City ULerk D R A F T _ Ikl� 'ti `Z ppry 1I STATEMENT BY SAN MATEO COUNTY WATER QUALITY CONTROLCADVISORY--COi,4ITTEE on (PROPOSED) INTERIM WATER QUALITY MANAGEMENT PLAN - SAN FRANCISCO BAY BIS IN Beneficial Water Uses and Water Quality Objectives (To be presented at the public hearing thereon, May 11, 1971) In regard to this matter, we would speak to two fundamental concerns; (I) the proposed prohibition of all waste discharge to the San Francisco Bay System and, (II) the proposed numerical restrictions on Coliform Organisms. (I) PROHIBITION OF ALL WASTE DISCHARGE TO BAY SYSTEM While we are fully supportive of the basic principles set forth in Section I, the Introduction statement of the proposed Interim Water Quality Management Plan, particularly in respect to the emphasis placed upon the underlying objective to view wastewater as a re- source and to develop a management program to conserve and bene- ficially use this resource, we are compelled to question whether the proposed prohibition of all waste discharge to the Bay System in reality serves this objective, but rather, may in fact serve to defeat this worthy purpose. We base this question on the follow- ing observations: 1. While speaking eloquently in respect to the potential for, and feasibility of, wastewater reclamation and reuse, pre- sumably made possible by reason of modern technology, the rationale presented in support of the proposed prohibitions of discharge on the otherhand seems to undermine any such confidence in present and future technology to the point essentially of despair. In otherwords, it appears that the proposed objective in respect to discharge prohibition is based upon the assumption that whereas it will be technologically feasible to provide a level of wastewater treatment sufficient to permit nearly total reuse for beneficial purposes, the same reclaimable wastewater will be of such questionable low quality that it cannot be safely discharged to the waters of the San Francisco Bay. DR A F T Page 2 (STATEMENT BY SAN MATEO COUNTY WATER QUALITY CONTROL ADVISORY COMMITTEE) It appears to us that there is a basic underlying incon- sistency on this point, a "confidence gap." It is our opinion that both present and more certainly dm - `proved technology in the future will provide the means whereby wastewater.may be treated reliably, and economically to the point where it is both reusable and may be discharged to the waters of San Francisco Bay without adverse effects. We believe that the foregoing supports the case against a stated intention to prohibit future waste discharge to the Bay System. 2,- Further justification of the proposed ultimate prohibition of all wastewater discharges to the Bay System appears to be.pro- vided by the tacit assumption that there will in fact be a market for essentially all reclaimable wastewater within a .'specific period of time in the foreseeable future and there will, therefore, be no need to discharge any reclaimable waste- water to the Bay system at any time. While there is no doubt that there will be an increasing mar- ket for reclaimed wastewater, particularly in numerous local areas throughout the Bay area for purposes of landscape irri- gation and possibly a more significant use at specific areas in the Santa Clara and Napa Vallies, nevertheless, we have seen no evidence on which to conclude that there will be a vast market for reclaimed wastewater much sooner than the turn of the century, a conclusion which appears to have been reached by the framers of the San Francisco Bay -Delta Water Quality Control Program. But in any case, it is generally accepted as essential fact that a pre -requisite of any waste- water reclamation and reuse system is a parallel system of disposal to account for (a) disposal of the non -reclaimable fraction of any wastewater (b) disposal during periods of peak wet -weather flows"corresponding to periods of minimum reclaimed water demand. DRAFT _ Page 3 (STATEMENT BY SAN .ATEO COUNTY WATER QUALITY CU..IROL ADVISORY COMMITTEE) It appears quite obvious, therefore, in the face of (a) a prohibition of all wastewater discharge to the Bay.System while at the same time recognizing that (b) there is only a limited market for reclaimed wastewater in the foresee- able future coaupled with the need for disposal of non- . reclaimables°�(c) the necessity for immediate facility im- provements to meet present discharge requirements, Bay area dischargers are faced with really one remaining alternative, massive transport and discharge to the Ocean, as recommended. in the San Francisco Bay -Delta Water Quality Control Program as Phase 2, a step which we.believe to be counterproductive to efforts toward increased treatment for purposes of reclama- tion to meet a gradually increasing reuse market while at the same time affording maximum protection to the waters (Bay or Ocean) receiving waste discharge beyond that used for recla- mation. In otherwords, expenditure of great sums of money to effect a vast export system to the Ocean will so significantly add to the further costs for reclamation as to price reclaimed "out of the market" and at least, inhibit realization of the reuse objective. We believe that the foregoing further supports the case against -a statedintention to prohibit future waste discharge to the Bay system. 3. We are concerned about the lack of precise acknowledgement of the nature and proposed disposition of so called, "non reclaim- able" wastes. It is assumed that inasmuch as all wastes are included in the proposed intention to prohibit discharge to the Bay System that some other point of discharge would have to be found for the "non -reclaimable" wastes, and by impli- cation, this too would seem to be the Ocean as was further recommended in the San Francisco Bay -Delta Water Quality Con- trol Program. D R A F T Page 4 (STATEMENT BY SAN MATEO COUNTY WATER QUALITY CONTROL ADVISORY. COMMITTEE) The question at this point must arise that if the "non -reclaimable" wastes are accepted as being of such an undesirable nature that they cannot be discharged to the Bay System without adverse re- sults, then for the same reason should they not be excluded from the Ocean? This concern has added import as a result of increasing scientific opinion that the Ocean embodies an eco- system which may be considerably more sensitive to environmen- tal change resulting from such events as man-made waste dis- charge than heretofore thought, and in fact is probably much more sensitive than the Bay System countering the argument that the vast dilution capability of the Ocean makes the Ocean the ideal solution to pollution. It is our opinion, therefore, that so called "non -reclaimable" wastes must be provided sufficient treatment and so controlled at the source that its final characteristics are such that they will not cause adverse effects to a receiving body of water, be it the San Francisco Bay System, or the Pacific Ocean and under such circumstances a prohibition of discharge to the Bay System would not be justified. 4. We are concerned that a stated intent to -adopt a prohibition of all waste discharge to the San Francisco Bay system will greatly inhibit the efforts and unduly restrict consideration of alternatives including those toward reclamation now being considered as essential parts of the several sub -regional en- gineering studies, studies which in most instances will be considerably more comprehensive than that afforded by the San Francisco Bay -Delta Water Quality Control Program upon which the proposed objectives, including prohibitions appear to be based. While a subregional engineering plan covering San Mateo County has not commenced, it is anticipated that such a plan will be authorized and begun soon. As part of this comprehensive DRAFT Page 5 (STATEMENT BY SAN MATEO COUNTY WATER QUALITY CONTROL ADVISORY COMMITTEE) study a thorough evaluation of the ability of the Ocean along the San.Mateo County shoreline to accept and assimilate treated wastewater will be made, as well as a corresponding evaluation of San Mateo Bayshore waters, and also reclamation potential. Accepting the realities that the reclamation and reuse poten- tial in San Mateo County is limited during the foreseeable future, in the face of a known intention to prohibit San Mateo County wastewater discharge to the waters of the Bay, then the proposed comprehensive engineering study is essentially limited to one alternative, Ocean disposal. We do not believe that the proposed study program should be so limited; rather, we believe that the public's interest will be served only if there is full freedom to evaluate the bene- fits and costs of all alternative of treatment, disposal, and reclamation and combinations thereof. We believe that the foregoing factor, which is assumed to be similarly relevant to other sub -regional areas, further sup- ports the case against a stated intention to prohibit future waste discharge to the Bay System. II COLIFORM ORGANISMS We believe that the proposed dilution/quality standards for Coliform Organisms as set forth in Section III of the proposed "Interim 16 Plan" are unduly restrictive and should be modified to be consistent with the proposed restrictions of discharge to locations other than near shore. In the absence of modification, we believe that the proposed objectives could unnecessarily result in very costly and excessive Bay outfall and diffuser systems with corresponding decrease in flexibility to alter the systems to meet the needs resulting from future changed conditions. DRAFT Page 6 (STATEMENT BY SAN ._ PEO COUNTY WATER, QUALITY CO! OL ADVISORY COMMITTEE) We do not disagree with the rationale presented in support of the proposed bacterial quality objectives. However, it appears to us that the proposed prohibition of "Any sewage bearing wastewater, regardless of degree of treatment any place within 200 feet offshore from the extreme low water line" practically eliminates the conditions of discharge "into.the confined waters of a creek or embaymentwhere it will receive limited dilution" the condition upon which the very restrictive and probably impractical pro- posed'bacterial quality standards are based. In otherwords, accepting that under the proposed nearshore discharge pro- hibition that all wastewater discharged to the Bay will be well offshore and, hence, analogous to the conditions upon which the bathing water stan- dards of Title 17 of the California Administrative Code is based, then this traditional standard should be adequate. Our concern that this objective should be realistic is enhanced through the knowledge that 100:1 initial dilution even to the deepest waters of the Central Bay will be difficult and probably impractical of achieving except at great expense with no meaningful benefits while at the same time no such high initial dilution will be required in instanced to meet the.previously considered more restrictive objectives in respect to toxi- city and dissolved oxygen. We believe, therefore, that either (a) the water quality objective in re- spect to Coliform Organisms should remain as at present and as set forth in your Board's Resolution No. 803, or (b) the 100:1 dilution factor pro- posed should be changed to read 25:1. Summary I In summary of our combined opinion concerning a proposed future pro- hibition.of waste discharge to the San Francisco Bay System, we would suggest the following: D R A F T Page 7 (STATEMENT BY SAN MATEO COUNTY WATER QUALITY CONTROL ADVISORY COMMITTEE) 1, It appears that the proposed "Interim Plan" prohibition of discharges reflects a combination of, (a) an uncritical ac- ceptance of the unproven theories on toxicity and surmise in respect to nutrients promulgated by the San Francisco Bay -Delta Water Quality Control Program, coupled with; (b) a "confidence gap" relating to present and future technology required to insure wastewater treatment ade- quate to meet the protection needs for both increasingly widespread reuse and San Francisco Bay system discharge. 2. It appears that the proposed "Interim Plan" prohibition of discharges reflects an unfounded assumption that the market for reclaimed wastewater will be sufficient during the fore- seeable future that all "reclaimable" wastewater may be used at all times of the year. 3. It further appears, that recognizing the foregoing assump- tion as being unrealistic, particularly in respect to seasonal periods of wet -weather, the facility plans of subregional and proposed regional studies become dictated and pre -ordained to be export, Ocean disposal systems which is counterproductive and inhibiting to a viable, expanding wastewater reclamation and beneficial reuse program. II In summary of our combined opinion concerning the proposed dilution/ bacterial quality standards, we would suggest the following: DRAF T Page 8 (STATEMENT BY SAN MATEO COUNTY WATER QUALITY CONTROL ADVISORY COMMITTEE) 1. Accepting the objective to eliminate all nearshore and con- fined water waste discharge, then, there appears to be no meaningful basis upon which to require the very high dilution factors to insure dilution prior to nearshore public contact. Recommendations Based upon the foregoing conclusions and other relevant factors involvdd, we hereby respectfully recommend the following: 1. We recommend that the proposed "Interim Water Quality Manage- ment Plan" contain no specific reference to an intent at any time in the future to prohibit all wastewater discharges to the Bay System. 2. We recommend that no further consideration of a prohibition of all wastewater discharge to the Bay System be given until completion of: (a) Present ongoing subregional plans (b) Final Basin Plan (c) Corps of Engineerst Triple "S" Study (d) State of California studies on Waste Dispersion & Assimilating Capacity and Biostimulation and Relative Toxicity. 3. We recommend that the San Francisco Bay Regional Water quality Control Board do adopt a policy statement which would require all sub -regional and regional studies to include alternates. covering not only "central Bay discharge," but also, programs directed toward (a) Ocean disposal and (b) maximum wastewater reclamation and beneficial reuse. 4. We recommend that prior to any further consideration of a pro= hibition of waste discharge to the Bay system the Basin Plan Study include a comprehensive analysis to thoroughly explore, on an area -wide, regional basis, the reclaimed wastewater re- use potential including answers to questions of timing, disposi- J � D R A F T Page 9 (STATEMENT BY SANT MATEO COUNTY WATER QUALITY CONTROL ADVISORY COiMMITTEE) tion of non -reclaimable and seasonal wet -weather flows, all as an integral part of a total water resources management plan. 5. Acceptin at "face value" the proposed "Interim Water Quality Management Plan" references to the imperatives of wastewater reclamation and beneficial reuse and silence on the matter of Ocean disposal, we recommend that the Board do adopt a clear statement of intention to encourage reclamation programs, in- cluding approval of reclamation projects for State and Federal grants and that the Board look for ultimate total wastewater reclamation and that such a statement be entirely apart from any consideration of prohibition of wastewater discharge to the Bay System. 6. Accepting that there will be a prohibition of waste discharge to any embayment, slough, creek or other confined, or shallow water body, we recommend that there be no change in present Board policy objectives to maintain bacterial quality in all waters of the Bay at a level other than that prescribed in Section 7958, Title 17, California Administrative Code for salt water bathing. Statement accompanied by Resolution to support from the following San Mateo County sewering agencies: I I: '