Submitted by Jeff Williams
I am Jeff Williams. I have been a water professional since 1974. Since then, I have obtained seven college degrees and have held a water license in two states and a wastewater license in five states including a California V Wastewater License.
I am a real, true environmentalist. I am not an amateur or a pseudo-environmentalist. I am 100% opposed to the proposed primary effluent solution which is an embarrassment to my profession. Those who claim only pseudo-enviro groups are the only ones opposed to the proposed solutions is a 100% untrue statement! I am proof of that!
The proposed stake holder’s solution is not compliant with the Clean Water Act (CWA) which states that, ‘all municipal sewage plants, Public Owned Treatment Works (PTOW), are required to meet secondary treatment standards.’
The proposed solution actually requires a Congressional Waiver to implement as it does not comply with the CWA requirement of meeting secondary treatment standards.
The proposed solution does not take a Congressional Bill to allow government agencies to work together to implement as it requires only a Congressional Waiver.
What does take a Congressional Bill to allow government agencies to work together is a real NPDES solution that allows the entire Tijuana River to be treated to secondary treatment standards and sell the water to the depleted Baja Wine Aquifer in Baja Mexico.
That real NPDES solution emphasizing the lack of attention to the health of the Navy SEALs and selling the NPDES treated water to Mexico to recover costs has been presented to Senator Dianne Feinstein’s San Diego Office District Director and Assistant Field Representative on April 25, 2019. It requires government agencies to work together to implement. Congressional Representatives introduced that bill on April 30, 2019.
I spent from October 2018 through April of 2019 writing a master plan to clean up the Tijuana River to NPDES quality on my own time. The design was from my experience to which, I not only redesigned bad engineering that is continually being implemented, I redesigned the primary treatment tank where it has no moving parts and is actually a biological process. I asked Dave Schlesinger to peer review it in February 2019 to which he approved the design. Dave accompanied me to my presentation on April 25, 2019 with Senator Dianne Feinstein’s San Diego staff.
The stake holder solution is not only non-NPDES compliant, but:
- The proposed catch basin design having the infrastructure in the Tijuana River will be buried in trash after the first major rainfall and be rendered useless.
- Primary and advance primary effluent is still raw sewage that has only been treated by two hours of gravity. If you introduce a raw sewage flow into a bucket that takes two hours to overflow the bucket, it is still raw sewage. In technical terms, that is primary treatment.
- It does not solve the health problems imposed on those who live, work and play in the Tijuana River Valley. I personally knew someone who in 1978 went scuba diving in non-disinfected secondary treated wastewater to inspect the mechanical collection system and got every lymph gland in his body infected. Primary sewage is raw sewage and an extreme health issue for the Navy SEALs.
- It is a proposal of those who have never treated a drop of water or wastewater in their life.
- A $408M, 163 mgd primary treatment for using 12 days a year is a waste of money and cement. There is no mention of sludge handling facilities and that anaerobic and aerobic digestion are not an option.
I am aware that you were working with the City of San Diego during the Aqua2000 project which proved the same technology can not only comply with NPDES standards (US Bureau of Water Reclamation) but, the CA Department of Health Services for treating river water to comply with drinking standards.
I was the only City employee that actually worked full time on a day-to-day basis of that project at the San Pasqual WWTP.
I know that the City of San Diego has known how to retrofit the Pt. Loma WWTP to comply with secondary treatment standards since July of 2000. San Diego has ignored the results of the research project.
I know that if a City water main breaks and flows into the Tijuana River, it requires a state spill report to be filed with the RWQCB. I’ve had to personally do that.
This is raw sewage you are permitting to be discharged into the ocean.
Jeff Williams – Oceanside, CA
