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CSPA supports regionalization reclamation, recycling and conservation for wastewater treatment but foresees problems
January 6, 2009 -- In responding to the Central Valley Regional Quality Control Board's proposal for regionalization , CSPA's Executive Director, Bill Jennings stated, "While CSPA is highly supportive of regionalization, reclamation, recycling and conservation, the Board should be aware of potential downsides..." CSPA is concerned that the proposal is duplicative of long-existing requirements and will further stress the Regional Board’s existing limited staff resources," a staff that is almost a decade behind in on identified and much needed Basin Plan modifications that are likely to be far more consequential in water quality protection.
Of critical concern are policies in the resolution that are lacking in requirements for water discharge and water conservation. CSPA's response points out that, "Water conservation also equates to a higher strength wastewater. Water conservation reduces the hydraulic flows to wastewater treatment plants and produces a stronger organic strength wastestream.
CSPA warns that, "Increased use of recycled municipal and industrial wastewaters should carry a note of caution. There are more than twenty-six million organic and inorganic constituents, of which nearly nine million are commercially available. Some eight hundred thousand are produced in high volume. Less than one percent are inventoried or regulated by government bodies worldwide. From a water quality perspective, we regulate only about two hundred of them. Most, of these “Constituents of Emerging Concern” (CECs) including frequently used pharmaceuticals, household products and industrial chemicals are not on the regulatory radar screen. Many of these constituents are toxic in low concentration. Others are variously classified as carcinogens, endocrine disruptors, immune suppressors and reproductive and developmental toxins."
CSPA notes that, "Regionalization in itself does not assure that a higher level of treatment or reliability will be provided. We also note that several communities have employed the goal of regionalization as a smokescreen to delay, by many years, crucially needed facility upgrades necessary for water quality protection."
Wastewater Treatment Plants