Cayucos May Seek to Remain at Existing WWTP — to the Detriment of Morro Bay
By Richard E.T. Sadowski
The City of Morro Bay and the Cayucos Sanitary District (CSD) currently share a wastewater treatment facility located on Atascadero Road in Morro Bay under their Joint Powers Agreement (JPA). The two entities had been working together to develop a new, modern facility to replace the current one. However, a technical memorandum might be considering backing out of the partnership and might attempt to continue treatment of its sewage at the existing Atascadero Road Wastewater Treatment Plant (WWTP) in Morro Bay.
Remaining at the current WWTP is one of three alternatives proposed for the CSD by Water Systems Consulting, Inc. The other two alternatives are building a separate plant in Cayucos, or working with the City of Morro Bay and the California Men's Colony (CMC) to develop a joint facility at the CMC. The consultants say that for the CSD, remaining at the current Atascadero Road WWTP would be the least expensive alternative.
The suggestion that remaining at the existing facility is even an option has raised some major concerns in Morro Bay. The California Coastal Commission (CCC) rejected the Atascadero Road site for construction of a new sewage treatment facility for a variety of reasons that include major risks of flooding and tsunamis. If the plant were damaged and could not operate, Morro Bay would likely suffer most of the negative effects of the resulting sewage spills. Other concerns that have been raised include negative impacts from continued use of the existing ocean outfall, and the possibility that a recently-proposed plant maintenance and repair plan for the existing WWTP could mean that Morro Bay residents would be subsidizing Cayucos's bid to keep its wastewater treatment operation there, to the detriment of Morro Bay.
An Early Warning Sign?
The CSD appears to have been considering this option for a while. Back in August, 2012, CSD and Morro Bay City staff wrote a letter rebutting a CCC staff report that called for building the new WWTP inland. The letter, titled "Comments and Corrections to the CCC Staff Report regarding the City of Morro Bay and Cayucos Sanitary District Wastewater Treatment Plant Upgrade" was dated August 3, 2012 and signed by Morro Bay City Manger Andrea Lueker and CSD District Manager Rick Koon.
One of the statements in the letter is: "It appears that the CCC staff may not be aware of the fact that if one agency (either Morro Bay or Cayucos) were to move from the existing site, the other agency has a real chance at meeting the requirements of the Settlement Agreement and bowing out of our existing operating agreement, drastically increasing costs for both agencies. No Coastal Development Permit (CDP) would likely be required for this action. If one or the other agencies elects not to proceed with a project at the Righetti site, the current Waste Water Treatment Facilities could remain on the existing site indefinitely. There are significant policy and legal considerations that would be involved in reaching outside of our City Boundary purchasing a property, potentially rezoning it, and determining and resolving the potential Local Coastal Plan (LCP) considerations of both jurisdictions."
At that time, the CSD and Morro Bay City staffs obviously believed that for either agency to remain in the existing plant would result in "drastically increasing costs" for both agencies. Yet, the Technical Memorandum by Water Consulting Systems, Inc. does not mention this concern and states that remaining in the existing plant is the CSD's lowest-cost alternative.
The allegation that one agency could remain at the existing WWTP without getting a CDP may be debatable – something not discussed in the Technical Memorandum. It has been clearly stated by management of the existing WWTP that the plant needs a lot of "repair and maintenance" to keep it operating. Some of that work might well fall within the Section 30106 of the Coastal Act's definition of "development" which says, "Development" means, on land, in or under water, the placement or erection of any solid material or structure; discharge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste; grading, removing, dredging, mining, or extraction of any materials; change in the density or intensity of use of land, including, but not limited to, subdivision pursuant to the Subdivision Map Act (commencing with Section 66410 of the Government Code), and any other division of land, including lot splits, except where the land division is brought about in connection with the purchase of such land by a public agency for public recreational use; change in the intensity of use of water, or of access thereto; construction, reconstruction, demolition, or alteration of the size of any structure, including any facility of any private, public, or municipal utility; and the removal or harvesting of major vegetation other than for agricultural purposes, kelp harvesting, and timber operations which are in accordance with a timber harvesting plan submitted pursuant to the provisions of the Z'berg-Nejedly Forest Practice Act of 1973 (commencing with Section 4511)."
Reliance on 2007 Facility Master Plan to Develop Costs
The consultants may have relied on bad data. The Technical Memorandum says that in determining the costs for the CSD to remain in the current WWTP, heavy reliance was placed on the 2007 Facility Master Plan (FMP) that was developed for the old, failed WWTP project.
The memorandum says, "Additionally, the MBCSD as it sits today has the potential to experience flooding during storm events that are less than the 100 year flood. In order to advance this alternative, a detailed analysis of the processes, facilities and the impact of flooding would need to be developed. WSC has used the same $2,500,000 place holder, adjusted to 2013 dollars, to review, design, and flood proof this site as was included in the 2007 Facility Master Plan Report (6)." The cited 2007 study was done by Carollo Engineers.
The fact that the consultants used the 2007 FMP data is a concern, because the 2007 version of the FMP did not adequately address flooding issues and was later heavily amended for that reason. In 2009, a flood hazard study for the Atascadero Road site was completed. The flood hazard study findings indicated that the existing WWTP facility was at high risk of flood damage, and would have to be demolished and replaced with a new one. This meant that the 2007 FMP had to be redone. A new version was subsequently issued.
The 2010 amended FMP says, "After review of various alternatives to mitigate the potential flooding, relocation of the WWTP facilities was recommended." In other words, there was a reason they did not fix/upgrade the current plant in place and decided a new plant had to be built. There is no good way to deal with the flooding risks at the existing plant. This would seem to indicate that the 2007 FMP's cost estimates for flood mitigation cannot be relied upon.
Were the CSD to rely upon unrealistic cost figures, and upon an unrealistic expectation that flood risks at the existing plant could be satisfactorily dealt with, it might make the wrong decision regarding its wastewater treatment options. This could result in unnecessary and excessive delays and costs for both the CSD and Morro Bay.
Another Major Cost Issue – Sewage Conveyance Infrastructure
Cayucos' sewage is conveyed through Morro Bay from its northern boundary to the plant on Atascadero Road. There is one trunk line used by Cayucos only, and a second shared trunk line that carries both Cayucos and Morro Bay sewage to the plant. Both run under Main Street.
The Technical Memorandum says, "it was assumed that no conveyance infrastructure improvements would be required."This appears to be a major error. It is likely that the CSD would have to replace its dedicated Main Street trunk line if it wanted to keep its sewage treatment operation at the existing WWTP.
The CSD trunk line that runs under Main Street in Morro Bay has been a source of problems for years. There have been sewage spills, and North Morro Bay residents have complained for years about hydrogen sulfide gas odors coming from manholes attached to the Cayucos-only line. In addition to polluting the air near the manholes, the hydrogen sulfide gas is known to have seriously eroded the concrete in some of the manhole structures attached to the Cayucos dedicated line. This could mean that the line itself has also been damaged and thus could be leaking. These problems will only continue to worsen over time, to the detriment of Morro Bay while, to the CSD, they are essentially "out of sight, out of mind."
Trunk line capacity is a critical issue that the CSD must address. The dedicated Cayucos line was installed in the early 1980's and does not have sufficient capacity to handle sewage under all conditions. It surcharges (exceeds capacity) during severe wet weather events. In addition, it is possible that development in Cayucos will also result in future increases in sewage flows. This would further exacerbate the current capacity issues
Surcharging has been an ongoing problem for some time. During heavy rains, water enters the dilapidated Cayucos sewer system through cracks and holes in the lines and greatly increases the volume of effluent in the pipes. By the time it reaches the dedicated trunk line that runs through Morro Bay, the system simply does not have sufficient capacity to handle the volume.
The capacity problem has been particularly noticeable at the manhole on North Main Street at Island Street. This is the last manhole prior to the point here the CSD's dedicated line is diverted under Alva Paul Creek. Due to the sewage volume and the actions of the pumps at CSD lift station #5, the manhole cover at Island and Main Streets has, on many occasions, literally been lifted up and thrown into the street.
One "solution" implemented by the CSD and the City of Morro Bay was to bolt down the manhole covers. A second "solution" that the CSD and Morro Bay use to address the surcharging issue is to divert flow from the CSD dedicated trunk line to the shared trunk line via a valve manifold located at Yerba Buena and North Main Street. That second "solution" is critical to preventing sewage spills.
However, if Cayucos were to treat its sewage at the existing plant, while Morro Bays treated its sewage at a new facility, the two agencies could no longer share a Main Street trunk line because their sewage flows would be going to different facilities. That would mean that Cayucos would be left with just its own dedicated trunk line, which does not have sufficient capacity.
All of this appears to mean that Cayucos would have to upgrade to a larger trunk line. Within the Coastal Zone, replacement of an underground pipe with a larger one requires a CDP – thus bringing the CCC into the picture.
Therefore, it appears there may be very significant conveyance infrastructure costs and permitting issues associated with any CSD attempt to remain at the current WWTP.
Most Serious Impacts of Plant Failure Would Likely Affect Morro Bay More Than Cayucos
The most significant potential health and economic impacts of any natural disaster or mechanical failure impacting the Atascadero Road plant would likely fall on Morro Bay. If a flood or tsunami event made the Atascadero Road facility inoperable, sewage spills would result in contamination of the Morro Bay's beaches. There could also be contamination along the roadway along Main Street in North Morro Bay. This is because sewage coming from Cayucos could potentially overflow out of manholes into the street.
Impacts on Cayucos would likely be far less. The sewage travels a considerable ways from Cayucos to Morro Bay in a "gravity line" and then, at the north end of Morro Bay, the CSD lift station pumps the sewage into the Main Street trunk lines. In the event of plant failure, Cayucos sewage would continue flowing down the gravity line, away from Cayucos and toward Morro Bay.
Continued Use of the Outfall
Environmental groups, including the Surfrider Foundation, oppose continued use of the outfall, which deposits treated sewage into the ocean about ¼ mile offshore. In case of equipment failure, partially- or un-treated sewage goes into the ocean. Those opposed to the outfall's continued use also cite the risks associated with "emerging contaminants." Those are chemicals which are suspected to be dangerous for humans and wildlife, but which are not yet regulated.
Although continued use of the outfall has been contemplated with other alternatives, including a joint Morro Bay-Cayucos facility, a new, innovative plant design might allow elimination of the outfall that currently deposits treated sewage into the ocean. Were Cayucos to remain using the current WWTP location, the outfall could not be eliminated.
Because of the location of the plant and the outfall, most of its actual and potential impacts fall on Morro Bay.
Are Morro Bay Residents Being Asked to Subsidize Cayucos' Plans?
The existing plant is not in good condition. It will not run for long without significant renovation. Any money spent on renovation before Morro Bay moves to a new facility could help support Cayucos in a bid to keep its own wastewater treatment operation at the existing WWTP. Thus, Morro Bay residents would be, in effect, subsidizing the CSD's plans to the detriment of their own interests.
At the February 14, 2013, JPA meeting, the CSD Board and Morro Bay City Council discussed a proposed Major Maintenance and Repair Plan (MMRP) that staff had recommended for the existing WWTP. The staff report said, "One of the original driving forces behind the upgrade has been that the plant is nearing the end of its useful life and needs to be rehabilitated and modernized. The plant will need to be maintained during the upgrade process, as the plant will have to remain functional and in compliance until the new plant is constructed, operational, and in compliance with at least full secondary treatment discharge permit requirements. This presents a potential challenge in determining the budget allocations for maintenance, repairs, and replacement of critical equipment and structures required to keep the existing plant in compliance with the NPDES discharge permit. The existing law that requires $3,000/day minimum mandatory penalties for each violation of the NPDES permit is a strong incentive to remain in compliance, as the penalty amounts can rapidly increase for any extended period of non-compliance."
Aside from the subsidy issue, there is another important question associated with this proposed MMRP. Just what is the difference between repair and development? The staff report said that the existing plant "is nearing the end of its useful life and needs to be rehabilitated and modernized." This sounds like a lot more than just "maintenance" or "repair."
Could some of the planned "maintenance and repair" fall under the CCC's definition of "development?" In the eyes of the CCC, "development" includes "construction, reconstruction, demolition, or alteration of the size of any structure, including any facility of any private, public, or municipal utility."
Thus, it appears that the MMRP might potentially be used not only as a means to have Morro Bay subsidize the CSD's plans, but as a means of avoiding applying for legally-required Coastal Development Permits. It seems unlikely that the CCC would allow such permits for the facility at the Atascadero Road site without careful scrutiny. The CCC has made it clear that it wants the City and the CSD to move their wastewater treatment facilities inland as soon as possible.
What does the Future Hold?
What actions Morro Bay residents and their elected officials may take in response to the serious issues associated with a possible Cayucos bid to remain at the existing WWTP remain to be seen. However, it seems unlikely that it will be possible for the CSD to remain at the current WWTP.
Meanwhile, Morro Bay continues to move forward with the Water Reclamation Facility (WRF) project. Stakeholder interviews were held on July 24 and 25, and the first public workshop is scheduled for Aug. 15. Potential treatment options and plant sites are being explored. Residents can follow the status of the project on the City web site.
Richard E.T. Sadowski was an employee for the Cayucos Sanitary District between February, 2002, and November, 2004. He is a mechanical engineer by profession and a certified wastewater collection operator. (See his previous article on the WWTP issue.)
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