Saturday, December 09, 2006

Written 12/09/2006

Conflicting Statements about Demand for "Reuse Quality" Water

At the same time that Oconee County officials were telling citizens the County rarely will discharge treated sewage water from the County's Rocky Branch plant into Barber Creek because the County expects such strong demand for reuse water from customers in the County, they were telling state officials just the opposite.

In filing the application for the permit to begin discharging treated sewage water into Barber Creek, Oconee County rejected a "No Discharge Alternative," saying it could not rely on the demand for the discharge water and needed to be allowed to put the water into the Creek.

The County even expressed doubt that customers ever would be willing to accept reuse quality water.

I’ve filed two open records requests and asked specifically for evidence of contracts the County had signed or even discussed with reuse customers. I was provided no evidence any such contracts even record of discussion exist.

Despite this, Gary Dodd, Oconee County Utility Department director, and Chris Thomas, assistant director, have continued to reassure residents who live along Barber Creek that the County will only infrequently discharge treated sewage water from its Rocky Branch plant into Barber Creek.

In an article in the September 7 issue of The Oconee Leader, Mr. Thomas is quoted as saying:

"There’s a chance we would discharge some into the creek, but not on any regular basis, and it would be a slow release over a 24-hour period," Thomas is quoted as saying. "We’re not going to open up a gate and let 1 million gallons" into the Creek.

The draft permit, however, would allow the County to discharge exactly that amount–1 million gallons of water per day, into Barber Creek. The County could release that amount every day once the plant is in operation. The County also has discussed expanding the plant to 4 MGD of discharge at some point in the future.

County officials have acknowledged they will be most likely to discharge into the creek in periods of heavy rains, when there will be little demand for reuse quality water and when the County’s spray fields will be unable to handle discharge. Of course, that is when the creek will be high and prone to flooding, and extra water from the sewage plant will only increase the water volume.

The EPD has refused to consider the issue of water volume in drafting the permit for Oconee County for its Rocky Branch plant. That permit is still under review and will be the subject of a public hearing at 7 p.m. on December 12 in the Oconee County Civic Center on Hog Mountain road.

At a March 14, 2006, hearing on the expansion of the Rocky Branch plant, the County estimated that 1 MGD of discharge would amount to less than an inch of increase in the height of water flowing down the creek–in a dry period. The increase in height would be less when the creek is flooding, the officials said, since the water would already be outside its banks!

The County officials seemed to think that was reassuring, but adding any water to a flooded creek only increases flooding.

In December of 2005, as part of the application for the permit to discharge into Barber Creek, Oconee County completed an Antidegradtion Review. Such a review is designed to show what is being done to prevent degradation of state waters.

In seeking to expand the Rocky Branch plant, one option is termed No Discharge, meaning that no water from the treatment plant would be discharged into any state water. Oconee County rejected this option, stating that the county has "just recently" begun putting into place a system of distribution of nonpotable reuse water.

"It will probably be a number of years before there is enough infrastructure and customers to use a substantial quantity of reuse water produced at the proposed facility," according to the Antidegradation Review produced for Rocky Branch.

Even when the reuse market exists, according to the report, "it is foreseen that some of these applications (e.g. turf irrigation) will experience short-term drops in demand due to rain and other weather conditions." For this reason, the County said, it needs a discharge permit.

Oconee County officials have talked frequently about large-scale users, such as golf courses and parks, of its reuse quality water. But in the Antidegradation Review, the County says these are not likely to develop:

"(I)t is questionable whether or not potential large-scale users would be willing to accept a water supply at reuse standards vs. drinking water standards. In addition, the pattern of land use projected for Oconee County through 2015 and 2025 preclude the development of such water users...(I)t is clear that development in Oconee County, and the resulting increase in wastewater flows to Rocky Branch WRF (Water Reclamation Facility), will come before substantial demands for reuse water are realized. Therefore, urban reuse is not considered to be an acceptable NDA (No Discharge Alternative) for this project."

Oconee County specified in another document it produced for the application process, Rocky Branch WRF Environmental Information Document, that it proposed to treat sewage at the Rocky Branch plant to "water reuse standards as outlined in EPD’s Guidelines for Water Reclamation for Urban Water Reuse."

That document is in the Library (5/3/06 entry) of the Friends of Barber Creek web site, The document discusses possible use of reuse quality water and 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."

Oconee County passed an ordinance in March of 2005 stipulating that reuse water should NOT be used for the following: "drinking, food preparation, hand washing, automobile washing, or irrigation of fruits and vegetables."

Despite this classification, Utility Department Director Dodd was quoted in The Oconee Enterprise on September 21, 2006 as saying:

"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."

This is another example of conflicting statements from government officials about Rocky Branch sewage treatment plant, or, as the County prefers, Water Reclamation Facility.

In an open records request I filed with Mr. Dodd on February 24, 2006, I stated:

"Pursuant to the Georgia Open Records Law (O.C.G.A § 50-18-70 et seq.) (the "Law"), you are hereby requested to make available for review and copying all files, records and other documents in your possessions that refer, reflect or relate to reuse of water from the Rocky Branch Waste Treatment Facility or any other waste treatment facility in Oconee County."

Mr. Dodd provided no evidence that any company or organization has actually discussed using water from the treatment plant.

I filed the following request on August 11, 2006:

"Pursuant to the Georgia Open Records Law (O.C.G.A § 50-18-70 et seq.) (the "Law"), you are hereby requested to make available for review and copying all files, records and other documents in your possessions that refer, reflect or relate to the County’s request for a permit to discharge wastewater from the Rocky Branch Waste Treatment Plant into Barber Creek and that were produced after February 24, 2006."

It also did not produce any written evidence of any discussion with any potential user of water from the Rocky Branch plant.