Jack McCurdyOctober 2012
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Morro Bay, Cayucos May Have to Go to Prison to Build WWTP

by Jack McCurdy

First Morro Bay and the Cayucos Sanitary District building their own individual new sewage plants got on the table. Now use of the California Men's Colony between San Luis Obispo and Cuesta College to process sewage from Morro Bay and possibly Cayucos is being eyed. And there also appears to be a possibility that the county may step in to operate the Men's Colony sewage plant for Morro Bay and Cayucos and turn it into a county project. How long can all this drag on without penalties from the state? No one is quite sure.

They met together last March 14 for the first time since each had decided separately that they would explore going their own way in pursuing a new state-required wastewater treatment plant, not jointly as their 30-year-old Joint Powers Agreement calls for but to possibly build two plants, one by and for the city of Morro Bay and one by and for the Cayucos Sanitary District.
The chance of the two going their separate ways had been publicly acknowledged since March 1, but the Morro Bay City Council and Cayucos Sanitary District board (CSD) had not met before March 14 with that being known by both sides. The idea was that both Morro Bay and the CSD each might build their own plants in or very close to their confines.

As new and "radical" that idea is, it has very quickly been overshadowed by an even more unconventional option: using the California Men's Colony wastewater treatment plant (WWTP) to process the sewage from Morro Bay and possibly also the CSD. The California Men's Colony (CMC) is located just north of Highway 1 between San Luis Obispo and Cuesta College.

The possibility of converting the CMC sewage plant into a county regional WWTP also has been raised and is now another option under consideration.

The thing that makes the CMC plant attractive for Morro Bay and possibly also Cayucos is that (a) there is believed to be room in its sewage plant for most if not all of the two communities' waste, (2) the CMC wants to share use of its plant in order to offset costs it has to shoulder to operate and maintain the plant for inmates, and (c) it would probably be cheaper than either Morro Bay or Cayucos building their own plant or plants because the CMC plant infrastructure is already there (and only five years old). If it needed to be expanded, that seemingly would cost less than if Morro Bay and Cayucos had to build their own plant or plants.

All this is informed speculation at this point, but hard facts and figures are being developed — Cayucos has hired a consultant, Water Systems Consulting (WSC), to investigate the prospect of using the CMC plant — or building its own separate WWTP — and Morro Bay is seeking a consulting engineer to do the same.

Meantime, a meeting between some Morro Bay City Council members and staff and CMC officials is being explored.

The opportunity for using the CMC WWTP to process MB/CSD waste emanated from an informed county source, and was discussed informally at an Integrated Regional Water Management Plan meeting on March 21 where Larry Barkley, a top engineer from the state Department of Corrections and Rehabilitation, who oversees the CMC plant, told Morro Bay council member Noah Smukler and city public works director Rob Livick that the Department was very interested in exploring use of the plant by Morro Bay and Cayucos to save money for the CMC by sharing expenses of its operation.

It has been estimated that it would likely cost on the order of between $10 million and $15 million to lay a pipe from Morro Bay to the CMC to transport the sewage waste to the CMC plant (the CSD already pipes its waste to Morro Bay where it is processed in the old WWTP on the shore of Estero Bay. So that waste could easily be included with Morro Bay's in the pipe to the CMC — if the CSD were to become part of the plan. (That old plant is planned to be replaced by a new plant, which the California Coastal Commission has required.)

On top of that, it is estimated that a pipe to bring recycled water from the CMC plant to Morro Bay would cost up to another estimated $5 million. (There is no fresh water pipe from Morro Bay to the CSD.) But that cost of building such long pipes would presumably be offset by the savings in using the CMC WWTP rather than Morro Bay or the CSD having to build their own plants, which would presumably amount to tens of millions.

Also, the cost of laying a recycled water pipe might be avoided if the plant's processed water were discharged directly into Chorro Creek near the plant. The Creek flows downward to Morro Bay and feeds the aquifers from which Morro Bay's wells would again begin drawing their water downstream from the CMC. That water drawn from the aquifers by Morro Bay would be sterilized as such and would provide Morro Bay with a major new supply of invaluable water. Coastal Commission staff reports for the past three years have strongly recommended developing access to well water from aquifers rejuvenated by recycled water from a new WWTP. 

The volume of recycled water that the CMC plant might produce would have to be very large, under Coastal Commission and regional board standards. As such, that volume could be a "life saver" for Morro Bay if the state water supplies, which Morro Bay now depends on, were interrupted by a natural disaster like an earthquake or phased out by the state, which reportedly is likely down the road. And it could result in a significant savings in the cost of water not only for the city but for individual residents because state water is very expensive.

There are no reliable and well-developed estimates of what a new WWTP plant to jointly serve Morro Bay and the CSD would cost, but with consulting engineers — one for Morro Bay and one for CSD — soon to begin work on future WWTP plan prospects, such figures should be forthcoming in short order to determine how use of the CMC would compare.

At the February 14 Joint Powers Agreement (JPA) meeting, CSD board president Robert Enns led off by saying, "Both sides (Morro Bay and the Cayucos CSD) are looking for alternatives to a 'peaker' plant. We also are doing it with the city (separately). The CSD is looking for themselves. Hopefully, a joint plant will fit for both sides." (What Enns meant by "peaker plant" is not known; Morro Bay city staff were not sure. CSD staff members were not available to clarify.)

Former Council member Carla Borchard told the Council and CSD board at that JPA meeting that the Righetti site (off of Highway 41 east of Morro Bay) "is not reasonable." That site was cited as the best of those reviewed for a new plant by the Coastal Commission staff. She did not say why.

At the JPA meeting, Bruce Keogh, WWTP division manager for Morro Bay, said some members of the City Council and its staff as well as some CSD board members and their staff had met with some members of the Regional Water Quality Control Board (RWQCB) staff, which oversees operations of the WWTP, and discussed how soon Morro Bay and/or the CSD must build a new plant. Keogh reported that the board staff said the plant's operating permit expires on February 14, 2014, and Morro Bay and the CSD must submit an application for a new NPDES (National Pollution Discharge Elimination System) permit by next September 1.

The board staff also stated that either a full secondary permit with interim effluent limits or a full secondary permit with a time schedule or cease and desist order would be the NPDES permit issued. (A cease and desist order is a legal mechanism for the RWQCB to use to enforce a time schedule for an upgrade or to fix problems at a WWTP, Keogh said.  It can carry a monetary penalty for not meeting certain milestones for a project, he said.)

There has been serious concern among city staff that because it may take as long as seven to ten years from this point to develop a new WWTP, monetary penalties might be levied by the regional board. Keogh said the regional board indicated that it might be able to extend the time schedule or cease and desist order for up to five years to protect Morro Bay and the CSD from monetary penalties. 

Keogh reported the following: the next NPDES permit (full secondary with interim limits) will be issued for a five-year period (all NPDES permits are renewed every five years) and will protect the Morro Bay and the CSD from penalties for not meeting full secondary treatment requirements.  If the project is not completed within the next five-year period, the Morro Bay will need to apply for a full secondary permit.  That full secondary permit would mean minimum mandatory penalties would be imposed if full secondary requirements were not met.  The RWQCB could extend the cease and desist order or time schedule for the second five-year period (the full secondary permit period) and protect the Morro Bay and the CSD from fines. In essence, it could allow Morro Bay and the CSD a 10-year window for completing the project without penalties.

Livick said the Morro Bay Council has approved a general time schedule for approval of a new WWTP site.

Enns said at its last meeting, the CSD board agreed to hire the WSC to explore alternatives for a CSD WWTP. He said a CSD committee, composed of himself and new board member Dan Lloyd, would meet with the WSC staff on March 19 about developing plans for a new CSD WWTP. It will be closed to the public, he added.

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