Saturday, July 18, 2015

Sewer Separation Dispute

In the controversy over the proposed sewer separation project, which has been going on for four months now, no one opposed to the project has ever suggested that dumping untreated sanitary waste into the river was not a bad thing. Rather their position has been that the remedy being proposed will make the situation worse than it is right now. Still proponents of the project, chief among them DPW superintendent Rob Perry, in defending the proposal, keep going back to the horrors of dumping untreated waste from the sanitary sewer system into North Bay and ultimately into the Hudson River.

In the packet of documents distributed to the aldermen at the informal meeting on Monday--the meeting that had to be canceled because there wasn't a quorum--was a communication from Perry consisting of a hard copy of an article that appeared on Huffington Post two years ago ("Antibiotic-Resistant Bacteria Found in Hudson River") and a report on the sewage that spilled into North Bay from the waste water treatment plant, during combined sewer overflow events, between March 9 and June 22 of this year.

Meanwhile, Timothy O'Connor, the sewer separation project's most vocal opponent, published on a graphic comparison of the amount of contaminants currently being released into North Bay during CSO events and the contaminants that would be released into North Bay if the proposed project is implemented. With O'Connor's permission, Gossips reproduces that graphic here. Each red square represents a ton of contaminants.



  1. If we are going argue this issue we should get clear on something. I find the O'conner chart very misleading. On the left we have 2.5 tons of raw, untreated sewage. On the right we have 66 tons of street dirt in 240 million gallons of rain water, not exactly "the same contaminants annually". It's like comparing apples to rotten,biocontaminated mice.

    1. Ed, the graphic is not misleading.

      The two contaminants are identical. I know that Biochemical Oxygen Demand is more offensive when it's in fecal form, but it makes no difference. There isn't even any way to distinguish them. BOD is BOD.

      Same for TSS.

      Apples and apples, if you like. The measures are identical.

      Also, you're in error if you think that the 2.5 tons to the left is raw sewage. It is called "combined" overflow for a reason, because it is highly diluted with the rainwater that caused the overflow.

      You can see this reflected in the new numbers on the DPW's chart.

      Normally, raw wastewater has BOD rates of 110 mg/l (the newly published NYS average cited by Delaware Engineering).

      In the chart above, you see that the number is down to 54 mg/l for BOD in the combined overflow.

    2. Ed, I wanted to say that I'm really glad you made those remarks. If you're preparing to doubt people's integrity, however, you're looking to the wrong party.

      City officials are working very hard to cloud the waters, so to speak, along with the jittery assistance of the Delaware Engineers.

      I explained that BOD is BOD, and it comes from many sources including sewage. The City's position is that BOD is only sewage, which is not only incorrect, it's next to impossible to determine short of genetic sequencing.

      That's why we ARE comparing apples and apples, and not apples and oranges.

      Look again at the new chart in this post, which I'm certain is the source of your "apples and oranges" comment.

      Whoever made the chart knew enough about the figures to know what they meant. They knew their subject concerned mixed, or "combined" wastewater, the reason for the combined overflow being the rain event which also dilutes the sanitary component of the mix.

      Yet at the bottom of the chart where the mixed weights of contaminants in both runoff and sanitary waste are tallied, the description of the total is "Pounds of Sewage."

      That's not just misleading. Whoever made this chart was dishonest. I suggest saving your skepticism for those with proven credibility problems.

      I agree with you whole-heartedly that we must be perfectly clear about these issues before making such a momentous decision. (The Environmental Assessment Form is designed to educate, which is probably why the attempt to complete it was abandoned.) I've been having people over to my house explaining this stuff, and re-doing the equations with them.

      The public is doing a better job than the City, which never completed the equations for the other half of the comparison. Their strength is manipulation, and not enlightenment.

      Why did the public and the Common Council only learn the details of the current separation plan in mid-December 2014? That was when the principal documents were made available by the City, even though the public was supposed to involved in the sewer planning for years, all through development of the City's Long Term Control Plan for CSOs.

      If people are confused about this very complex subject, then it's no wonder.

      Our collective ire should be directed at the people who brought us to this circumstance, but I imagine these same individuals are readying themselves to call the shots on Tuesday. We must stand up to them with facts, because the facts do not favor this project.

    3. Because I mentioned "dilution" several times on this page, I didn't want anyone to think that the above graphic has anything to do with dilution.

      Dilution was mentioned only to expose the dishonesty of the creator of the City's new chart. (The word will be turned against us next!)

      The graphic's side-by-side visual does not concern concentrations of pollutants, but amounts. Weights are weights, no matter how concentrated or diluted the vehicle.

      The red blocks represent single and half-tons of "BOD," a measure of food available to naturally-occurring microorganisms who consume oxygen according to the food amounts.

      The BOD number is the amount of available food - a single measurement that makes no distinction between "kinds" of BOD.

      Because the origin of the food is irrelevant, the above graphic presents a perfect equivalence: apples to apples. Anyone who says otherwise is lying.

      The same rule applies to the other contaminant that's depicted in the graphic, Total Suspended Solids. The graphic depicts the total weight of TSS, not the concentration.

      Available food is only one kind of pollutant. As a result of the proposed massive increase in TSS, the North Bay will become increasingly turbid, as well as oxygen-depleted.

      This is such a concern that "turbidity" is listed as a specific hazard in the Impact Assessment and Habitat Impairment sections of North Bay's Significant Habitat Rating Form (NYSDOS).

      Sunlight-dependent aquatic plants in the vegetated shallows likely control the North Bay's entire ecosystem:

      "Water clarity probably controls the size, thickness, and perhaps species composition of the plant beds [of the vegetated shallows], which in turn must affect the animal community, water flow, oxygen dynamics, and so on" (David Strayer of the Cary Institute of Ecosystem Studies, "The Hudson Primer," 2012, pp. 118, 119).

  2. 1. Biochemical Oxygen Demand (BOD)

    Using the latest DPW figures in the above chart, I calculate the BOD from the mini-drainage basins slated for separation at 3,282 pounds between 4/8 and 6/21/15.

    That number is based on the state average for TSS in stormwater, also called "streetwater runoff," which is 11.5 mg/l.

    Multiply that by 34 million gallons, the amount shed from 222 acres alone, though the actual acreage involved is at least a quarter more.*

    The 2013-2014 average of BOD removed at the treatment plant - following primary, secondary, and disinfection - was 88%.

    That means that 88% of BOD was treated and removed of that initial 3,282 pounds, which comes to 2,888 pounds of BOD captured by the treatment plant from the areas being considered for separation.

    The City's argument is that the 3,282 pounds of BOD in runoff should go directly to the North Bay in order to remedy a situation where 725 pounds of BOD is otherwise discharged to the same water from overflows.

    The ratio based on the new data makes no more sense than the tradeoff in the DPW's previous argument from April.

    The earlier argument was based on annual averages since the treatment plant was upgraded, but the City never calculated the BOD - or any other contaminant - in the runoff from the areas planned for separation.

    The only comparisons that matter AT ALL are the contaminant weights between runoff and that in the combined sewer overflows. Each pollutant in runoff and overflow must be weighed and compared individually. When it comes to contaminants, any other consideration is totally irrational.

    But for all the noise the City is making, so far we've been given a Hobson's choice, a free choice where only one option is offered. That's because only the public has investigated the trade-off, while City officials try their luck with the usual smoke and mirrors.

    To review April's debate which was based on yearly averages, the BOD in the runoff of a quarter of the City's north-side comes to a minimum of 23,000 pounds. Nearly all of that amount of contaminant is now subjected to full treatment.

    As far as BOD is concerned, the only comparison that mattered in the April argument was the 23,000 pounds in the north-side runoff contrasted with the approximately 2,200 pounds of BOD discharged during a dozen overflow events in 2014.

    Which is worse for the North Bay: 2,200 or 23,000 pounds of BOD?

    And please understand that BOD is BOD is BOD. Don't let anyone tell you otherwise.

    *All of our numbers are extremely conservative, as the actual area being drained is close to hundred acres larger than the 5 mini-basins alone. That's because mini-basin 7 now empties into mini-basin 8, and much of that water pours into the basins we're calculating. For today only, we ignored all of this extra water and inflated the City's numbers.

  3. 2. Total Suspended Solids (TSS)

    The same 34,206,253.7 gallons as above (no. 1) is used here, which was the amount shed between 4/8 and 6/21 from the 5 mini-basins slated for sewer separation.

    Between those dates, TSS adds up to 15,555 pounds, which is calculated from the state average of 54.5 mg/l in streetwater runoff. (Nearly the same number given for the amount in the City's new overflow number is due to dilution of the usually twice-higher TSS in raw wastewater).

    Going by the plant's 96.75% treatment rate for TSS, the total amount removed between 4/8 and 6/21 was 15,050 lbs. That's a lot to be removed from the waste stream by our very efficient treatment plant.

    The City argues that discharging 739 lbs of TSS is worse than discharging 15,555 lbs. of the same materials into the North Bay.

    The Federal block grant was won on the premise that water quality in the receiving waters will be improved.

    Now that we see that water quality is going to be degraded as a result of this project, how can we possibly meet the terms of project completion?

    Pretending that a review of the plan can be segmented into its various phases - which is unlawful under the State's Environmental Conservation Law - the City has already acknowledged that a full environmental review is likely before future phases are implemented.

    So back to the issue of project completion, which is practically the only thing the Federal grantor requires, the City's evident plan is to postpone the inevitable bad news which, so far, only the public is willing to analyze.

    If we accept this money and then don't finish the project, that's when the scare-mongering of City officials will actually come true. It will be a long time before Hudson gets another grant.

    On the other hand, if we don't take the money because the negative implications of the plan have finally come to light, then the Fed will be grateful.

    Municipalities not accepting their awards happens all the time. Then we can use the next year (before we reapply for the same grant) to compose a sewer separation plan that makes sense for us.

    Public participation is what the national CSO Control Policy required all along. The current controversy is typical of what happens when the public is improperly excluded.

  4. After reading and trying to understand all of the above, which is quite difficult for me (not great at math), I appreciate the discussion and I do get the point that apples are apples and that the project is indeed going to degrade the North Bay. We don't need that to happen and it makes more sense to postpone the project, until a proper environmental review can be completed. Especially since there was no chance for discussion on the subject since the informal council meeting was postponed last week. Definitely this project should be looked at and explained to the public through a clear lens. The new CAC can help.

  5. Had the council completed the Short Environmental Assessment Form, even that would have helped our understanding immeasurably.

    Because the council promised to complete a Short EAF but then abandoned the idea, a Resolution which is an alternative to the anti-environmental "exemption Resolution" being put to a vote at Tuesday's meeting will enable the council to finish what it began, the 3.5-page Short EAF (it's mostly checkboxes).

    A Short EAF is the absolute minimum we can do to understand the enormous decision the council is about to make based on exactly half of the necessary information.

    Please support the alternative Resolution which is not yet on the council's Agenda. Ask your Aldermen to make sure that the alternative "Short EAF Resolution" gets placed on Tuesday's Agenda.

    At the very least, the Short EAF was always the right course to take. It can still be done if there's a will to do it.