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Re: E-M:/ Plan would let sewage flow into Michigan lakes



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Enviro-Mich message from mshriberg@pirg.org
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Another major problem with the proposed "blending" policy is that it
takes away any incentives for wastewater treatment plants to upgrade
and fully treat sewage.  Right now, blending is allowed in extreme
circumstances, and no one is arguing that we should take this away. 
When compared with no treatment at all during an extreme storm event
(defined as the 25-year, 24-hour storm by MDEQ), of course we would
want blending.  The problem is that EPA is moving to allow blending
to be a more routine strategy.  If this happens, wastewater treatment
plants have no reason to upgrade their treatment capacity and run all
sewage through secondary and tertiary treatment, and thus better
protect environmental and public health.

I'm not sure where Fred is coming up with data on the safety of
blending.  From the MSU study, "the risks associated with swimming in
waters receiving the blended flows were found to be 100 times greater
than if the wastewater were fully treated."

And, finally, even if the water meets Michigan's standards, these
standards are based on e.coli and fecal coliforms and may not
adequately protect public health.  Disease organisms such as
Cryptosporidium are resistant to the chlorination which effectively
reduces e.coli and fecal coliforms, and thus require secondary
treatment to be effectively reduced, regardless of the standards.

- Mike
------------------------------
Mike Shriberg, Ph.D.
Great Lakes Advocate
PIRGIM
103 E. Liberty Street, Suite 202
Ann Arbor, MI 48103
mshriberg@pirg.org
734-662-6597

>
>
>
>---- Original Message ----
>From: jamesmec@voyager.net
>To: enviro-mich@great-lakes.net
>Subject: Re: E-M:/ Plan would let sewage flow into Michigan lakes
>Date: Mon, 03 Jan 2005 11:46:41 -0500
>
>>--------------------------------------------------------------------
>-----
>>Enviro-Mich message from James Clift <jamesmec@voyager.net>
>>--------------------------------------------------------------------
>-----
>>
>>My view of the "blending" proposal is slightly more basic. I
>personally 
>>would like to be able to swim in Michigan's lakes, rivers and
>streams 
>>without first thinking about whether it has rained in the past 48
>hours 
>>and what that means I'm swimming with.
>>
>>Where we don't need to build a system that can handle the largest
>storm 
>>of the year - the current system that allows 20-50 billion gallons
>of 
>>undertreated sewage a year into Michigan waterways is unacceptable.
>>
>>For a modest increase in sewage rates, our wastewater systems could
>be 
>>upgraded to drastically reduce sewage discharge into our waters. The
>
>>blending proposal is the "cheap" option of dealing with our sewage
>-- 
>>and shortchanges the Great Lakes.
>>
>>Better public systems, combined with mandatory testing of home
>septic 
>>systems at the time of sale or every ten years would insure all
>Michigan 
>>residents were equally sharing in the responsibility to keep our
>lakes 
>>and rivers clean.
>>
>>Proposal 2, approved by 60% of the voters in 2002, insured funding
>would 
>>be available for low-interest loans to communities to upgrade
>systems. 
>>Its time for Michigan residents to stand up for Michigan water --
>and 
>>put a higher priority on making sure it is safe for drinking,
>swimming, 
>>and supporting fish that are safe to eat.
>>
>>James Clift
>>Michigan Environmental Council
>>
>>
>>
>>
>>
>>
>>
>>fred cowles wrote:
>>
>>>-------------------------------------------------------------------
>------
>>>Enviro-Mich message from fred cowles <fecowles@yahoo.com>
>>>-------------------------------------------------------------------
>------
>>>
>>>This is a response to two comments by Curl and Harris
>>>quoted below.  
>>>
>>>The draft policy would allow mixing of sewage that has
>>>received partial treatment with sewage that has
>>>received full treatment during wet weather periods. 
>>>Typically ?full treatment? means both physical
>>>treatment like screening and sedimentation, and
>>>secondary treatment like activated sludge or fixed
>>>film bioreactors.  ?Partial treatment? would imply
>>>just physical treatment.  ?Filtered? is not usually
>>>used in this context as filtration is normally a
>>>tertiary treatment process that is employed to produce
>>>a very high quality effluent.  The question of
>>>disinfection is one that varies from state to state. 
>>>Michigan requires that all sewage discharges be
>>>disinfected, but many states do not.  
>>>
>>>The draft EPA blending policy would not authorize any
>>>water quality standards violations.  Therefore, in
>>>Michigan, all blended discharges would need to be
>>>disinfected.  Secondly, the policy would not authorize
>>>any effluent limit violations.  
>>>
>>>Effluent limits are determined on the basis of the
>>>more stringent of two criteria.  The first is the
>>>national standard of ?secondary treatment?.  This is
>>>often thought of as ?biological treatment? but in fact
>>>is determined by chemical analysis of a few
>>>parameters, not by the kind of treatment provided. 
>>>The secondary treatment standard is met if the
>>>discharge contains less than 30 mg/l Biochemical
>>>Oxygen Demand (BOD), contains less than 30 mg/l
>>>Suspended Solids, and has a pH in the neutral range (6
>>>to 9).  The standard is more complicated than that and
>>>the details can get very confusing.  The most
>>>important additional requirement for this discussion
>>>is the requirement for 85% removal of influent BOD and
>>>Suspended Solids.  
>>>
>>>The second criterion upon which the effluent limits
>>>are determined is compliance with the state water
>>>quality standards.  In Michigan, this results in the
>>>need for all facilities to remove phosphorus and to
>>>provide disinfection.  In many locations around the
>>>state other effluent limits are needed such as lower
>>>BOD and Suspended Solids limits, limits on Ammonia,
>>>limits on various heavy metals and other toxicants.  
>>>
>>>COD or Chemical Oxygen Demand is seldom used to
>>>describe the quality of domestic sewage.  It is more
>>>appropriate for industrial wastes.  
>>>
>>>Since the draft blending policy requires that both
>>>criteria must be met, environmental protection is
>>>properly assured.  If it is not, then the issue is
>>>adequacy of the water quality standards or the
>>>effluent limits.  So the debate over the policy should
>>>be on the proper interpretation of the secondary
>>>treatment regulation promulgated in the 1970s.  This
>>>gets into the details of how the 85% removal
>>>requirement is calculated and when variances to the
>>>requirement should be approved.  
>>>
>>>In environmental terms one would think that the
>>>quality of a blended effluent would not be as good as
>>>the quality of full treatment.  This would be a hasty
>>>conclusion.  Treatment efficiency declines in wet
>>>weather.  So this remains an open question.  
>>>
>>>I am not taking a position on blending one way or the
>>>other.  I would just like the discussion on the topic
>>>to relate to the real issue and not on emotion.  The
>>>News article was pure emotion.  ?Do you want to drink
>>>raw sewage?? on one side, and ?We can?t afford to
>>>control pollution.? on the other.  
>>>
>>>======== Fred
>>>
>>>
>>>The policy will allow the discharge of filtered and
>>>diluted raw sewage (with no secondary treatment). The
>>>question come down to comparing the discharge of
>>>sewage that has been filtered and given secondary
>>>(biological) treatment and disinfection, and a mixture
>>>of that and sewage that has only been filtered, and
>>>asking whether this is "acceptable" in terms of public
>>>health and environmental concerns. In particular, the 
>>>BOD and COD of the blended discharge will be higher
>>>than fully treated  sewage, while the blended sewage
>>>may or may not (as far as I can tell) be disinfected,
>>>as is the fully treated discharge.  Reading
>>>www.epa.gov/npdes/blending does not answer these
>>>questions as it does not give specific information on
>>>BOD, COD and bacterial standards for fully treated vs
>>>blended discharges.  It would be appreciated if
>>>someone here could address these issues more
>>>explicitly.  --Rane L Curl             
>>>
>>>could you provide some basis for your claims "will not
>>>significantly  improve environmental protection" and
>>>"does not weaken environmental  protections" . . .  
>>>cheers, 
>>>craig k harris 
>>>
>>>
>>>
>>>		
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>>>  
>>>
>>
>>
>>
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>>ENVIRO-MICH:  Internet List and Forum for Michigan Environmental
>>and Conservation Issues and Michigan-based Citizen Action.  
>Archives at
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>>
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