Sunday, September 24, 2006

Written 9/24/06

Confusion Surrounds County Plans

A resident of a nearby subdivision along Barber Creek relayed to me a comment a neighbor had made to her recently. The comment illustrates how much confusion exists in the community about Oconee County’s plans to expand its Rocky Branch sewage plant and begin dumping treated wastewater into Barber Creek.

My friend said her neighbor argued that the County’s plans actually would be a good thing, because the water from the sewage plant would increase the volume of the stream in the summer when the creek has little water.

In fact, the County says it is unlikely to release water into the Creek during summer or other drought periods. At those times, the County says, it will have lots of customers for its "reuse quality water."

The County will be dumping water into Barber Creek when it cannot sell the water for irrigation. When the creek is full because of heavy rains, the county is going to be most in need of the permit is it seeking from the state Environmental Protection Division (EPD) to discharge treated sewage water into Barber Creek.

In sum, my friend’s neighbor misunderstands one of the prime features of the County’s proposed plans for Barber Creek.

Given the complexity of the issue, the inherent uncertainty about how a nonexistent plant actually will operate, the confusing answers given by some county officials, and the poor coverage given the issue by most of the media, such confusion is not so surprising.

Confusion surrounding the key issue of how sewage plant discharge is monitored illustrates these points. I sent Gary Dodd, director of the Oconee County Utility Department, and his assistant, Chris Thomas, an e-mail message on August 20 of this year asking what monitoring is done at the existing Calls Creek plant, and what monitoring would be done at an expanded Rocky Branch facility. The Rocky Branch facility will use the same design as is used at Calls Creek.

The next day, Mr. Thomas, who generally tries to be helpful, wrote me the following reply:

"Most of the sampling of Calls Creek is voluntary. The EPD does not require us to sample the Creek unless there is a potential problem. We sample the creek to establish base lines and to ensure that our effluent is not having any negative effects on the environment. Also, GA EPD samples creeks that receive effluent periodically. This sampling is unannounced and we seldom hear of the results. If the board (Oconee County Board of Commissioners) approves the upgrade (to the Rocky Branch plant), we will begin sampling Barber Creek in the same manner."

I told Mr. Thomas I’d like to review data the County had on Calls Creek, and he wrote me on August 22 saying he had "contacted the wastewater plant and asked them for any sampling info that they have retained. I will let you know when I get a response."

I’ve never heard any more from Mr. Thomas on the topic.

I have subsequently learned through an open records request that the EPD had 20 samples drawn from Calls Creek in 2004 as part of a state-wide study of water quality. The County’s Calls Creek plant was modified and updated in 1995 and given a permit by the EPD to discharge 0.4 million gallons per day (MGD) of water into Calls Creek. In 2004, the plant’s capacity was expanded to 0.67 MGD.

David Wenner, a water scientist in the Department of Geology at the University of Georgia and an active member of Friends of Barber Creek and of the Upper Oconee Watershed Network (UOWN), took a look at the data for 2004. Here’s David’s response:

"I looked over this data as well as that from UOWN and don't off hand see any real numbers that indicate a problem. The only ones of possible concern are some of the bacteria data. They are high on a couple of dates. Elevated values are often seen following a rain event due to storm water runoff into the creeks ( presume this is the case with these data). This is pretty normal for most streams in the area."

Kathy Methier from the EPD subsequently told me that the County is obligated to do self monitoring and to file a report to the state for each permit it has. So the County must have done this for Calls Creek as well as for the existing Land Application System (LAS) the County operates at Rocky Branch. She said this is called a Discharge Monitoring Report, or DMR.

She said, in addition, the state does independent, unannounced facility monitoring to check on the self monitoring data. This is called a Compliance Sampling Inspection, or CSI. There should be reports for Calls Creek and Rocky Branch as well.

I’ll file an open records request for access to these data shortly.

Such monitoring data are important, because plants do not always operated perfectly. James Holland, Altamaha Riverkeeper, made this observation in response to an e-mail message I sent out about the Rocky Branch plant:

"The state of Georgia is doing a lousy job at maintaining water quality discharges from industrial pipes as well as municipality discharges...Some...examples are the waste water treatment plant for Dublin and Brunswick along with most any small town that uses oxidation ponds to treat sewage."

Another person, who has inside knowledge of the operation of the EPD, said:

"The joke is that almost any kind of sewage treatment plant is permitted, there is little monitoring, there are few penalties for misconduct and in the end,... when spills occur, nobody at the EPD will shut down a plant because effluent will back up if they do that."

A story on the front page of the Metro section of The Atlanta Journal-Constitution on September 15, 2006, underscored the point. South Fulton residents complain that a sewage treatment plant in their neighborhood stinks frequently and, in the view of some, is creating a health hazard.

Unfortunately, the newspapers serving Oconee County have not explored issues of plant operation and not done a good job generally of covering the story of the proposed Rocky Branch expansion.

The Banner-Herald mostly has ignored the story. The Oconee Leader ran one very good story in its September 7 issue. The Oconee Enterprise has consistently gotten the story wrong.

The Enterprise front-page story on September 21, 2006, was clearly the worst piece of reporting on the topic. It contained the following quote from Oconee County Utility Department Director Gary Dodd about the quality of the water to be discharged from the plant:

"You wouldn’t want to drink it (the water from the proposed Rocky Branch plant) because of the implications, but we are planning dual water lines in new subdivisions that want them, ‘grey’ water suitable for lawns, washing cars and dogs and such benign uses."

Mr. Dodd and the Enterprise reporter should know quite well that the Oconee County ordinance on use of "reuse quality" water recommends against precisely the kinds of uses he was discussing. That ordinance, passed in March of 2005, stipulates that reuse water should NOT be used for the following: "drinking, food preparation, hand washing, automobile washing, or irrigation of fruits and vegetables." The ordinance, available on the county’s web site, is based on state standards for use of the water.

The state standards on use of "reuse quality" water are available on the EPD website and in the Library (5/3/06 entry) on the Friends of Barber Creek web site, The state documents specifically recommends against any use that brings the water in contact with the skin. The document, on page 13, gives the following guideline for use of the water:

"The customer shall not allow reclaimed water to be used for consumption (human or animal), interconnecting with another water source, sprinkling of edible crops (gardens), body contact recreation, filling of swimming pools, or sharing a common reclaimed service between properties."

The Enterprise article of September 21 also is in error about the nature of the proposed changes for the sewage plant on Rocky Branch Road. The article says that the current Land Application System (LAS) "will be expanded to treat one millions-per-day of reuse quality water." Actually, the current LAS treatment facility is going to be eliminated, and a new plant will be built, if the County gets its permit.

The County currently has a permit to dispose of 0.4 MGD of water at the existing Rocky Branch facility by spraying it on hayfields on the site. The County will retain its current ability to spray water on the hayfields. When the fields are wet due to heavy rains, however, the water will go into Barber Creek, unless some other customer wants the water. That is unlikely to be the case, of course, since these other customers also will not need irrigation water at that time.

The County has no permit to dump treated sewage water into Barber Creek at present. That, rather than the LAS, is what the permit is all about.

The Enterprise also allowed Mr. Dodd to counter argue the recommendation of the consulting firm it hired, Jordan Jones & Goulding (JJ&G), to develop a Wastewater System Master Plan for Oconee County. JJ&G, an engineering and consulting firm based in Atlanta and with offices around the country, recommended phasing out the Rocky Branch and Calls Creek plants over time in favor of a plant on the larger Middle Oconee River.

According to Mr. Dodd, as quoted in the Enterprise, JJ&G made a mistake in not knowing that the state would not grant a permit for a plant on the Middle Oconee River. Yet the County has continued to use JJ&G, most recently for permitting to draw water from the Oconee River for the planned new reservoir on Barnett Shoals Road. The Enterprise did not point out this inconsistency, or ask Mr. Dodd to explain.

There is good reason to doubt Mr. Dodd’s assertion about the EPD’s unwillingness to grant a permit for the Middle Oconee. In a meeting I had with Mr. Dodd on March 22, he claimed that the EPD would not grant a permit for the Apalachee River. Jeffrey Larson, manager of the Permitting, Compliance and Enforcement Program at EPD, wrote to me on August 18, 2006, saying that EPD "has no policy or strategy for not issuing discharge permits to the Apalachee River."

The Enterprise, which has a history of challenging authority in the County, seems to think its job in this case is to promote the County’s plans for sewage treatment rather than ask questions about them. In this way, the paper’s coverage is very close to that of Ms. Kate McDaniel who runs the web site, A Positive Vision for Oconee County. At least Ms. McDaniel does not claim she is providing objective coverage of the issue.

The issue before the county is complex. The County has promised developers sewage treatment capacity it does not have. The County also has no agreed upon plan for how to develop that capacity. It has refused to hold open discussions on the two drafts of a Wastewater System Master Plan prepared for it by JJ&G.

In other words, the County is flying in the dark. It is hardly surprising that citizens in the County are confused about what is being proposed and its consequences.

On September 16, while walking my dog along Barber Creek behind my house, he and I spotted an otter swimming upstream. It has been several years since I’ve seen otter in the creek, and I was pleased to see one again. River otters eat a variety of fish and shellfish, as well as small land mammals and birds. It suggests to me the creek still has some life in it, despite all the development in the County and the poor protection it has been given from stormwater runoff by the County.

The County’s plans for sewage treatment are a potential threat to that otter. How serious the threat is in difficult to know. What I do know is that the otter cannot ask the County and the state to discuss all the options and be clear about them. So we have to do that.