The Number Is 1,136.

On page 164 of a 213-page engineering report prepared for Onondaga County, in a table titled “Projected Water Quality Based Effluent Limits for Discharge to the Oneida River,” the engineers list a single line: Perfluorooctane Sulfonic Acid (PFOS) — 1,136 µg/L.

That number is the projected effluent concentration of PFOS that the new industrial wastewater treatment plant will be designed to discharge into the Oneida River. It is measured in micrograms per liter. Converted to the units used in federal drinking water standards, it is 1,136,000 nanograms per liter.

The EPA’s Maximum Contaminant Level for PFOS in drinking water, finalized on April 10, 2024, and still in effect today, is 4.0 nanograms per liter.

This is the design basis. This is what the engineers are working toward. This is the permit the County is asking DEC to issue.

The Oneida River flows into the Oswego River. The Oswego River flows into Lake Ontario. Roughly 1.5 miles downstream of the permitted outfall is the OCWA and City of Oswego shared drinking water intake that serves more than 500,000 Central New Yorkers. Millions more downstream drink Lake Ontario and St. Lawrence River water.

The Design Basis Is “Micron Stated.”

Page 1-9 of the same report, in the Definition of the Problem section, lists fourteen wastewater constituents the engineers used to size the plant. Most of them carry the phrase “Values provided by Micron” or “based on information captured in models developed by FTD solutions for Micron.”

The PFAS entry reads, in full:

That is the entire treatment plan. Micron stated. That is the foundation.

Biological treatment does not destroy PFAS. It has never destroyed PFAS. The EPA has never recognized biological treatment as a PFAS destruction technology. What biological treatment does to PFAS is concentrate it — some into the effluent, some into the sludge. The sludge from Oak Orchard is trucked to Metro Syracuse, where the County planned to dry it and sell it as agricultural fertilizer.

The design is “we believe Micron.” The treatment plan is “biology.” The projected effluent limit is 1,136 µg/L of PFOS alone.

The Document the County Stamped Confidential.

The report is titled “Oak Orchard Industrial Wastewater Treatment Plant and Water Reclamation Facility — Conceptual Design Engineering Report,” prepared by Brown and Caldwell for the Onondaga County Department of Water Environment Protection, dated November 11, 2025, signed and sealed by Matthew John Marko, PE, New York License No. 76324.

On two of its 213 pages — the first page of the Executive Summary and the first page of Section 3 — the document is stamped:

Public Officers Law § 87(2)(c) is New York’s FOIL exemption for trade secrets. Section 87(2)(d) is the exemption for records whose disclosure would impair an imminent contract award.

The County is asserting, in writing, that this document is legally shielded from Freedom of Information Law requests — twice over. Residents cannot demand it. Journalists cannot demand it. Commenters on the draft SPDES permit cannot demand it.

Except the County has been hosting the document, in full, on its own public web server since November 2025:

No login. No FOIL. No redaction. Indexed by Google. Linked from the County’s own “Public Review Documents” page for the Oak Orchard project. As of April 22, 2026 — the day we are posting this — the file is still live at that URL. Anyone with a web browser can download it.

One of these two things is wrong. Either the document is legitimately FOIL-exempt, and the County posted confidential trade-secret material to a public-facing server by mistake — a mistake that has sat there for five months. Or the document is not legitimately FOIL-exempt, and the County is applying FOIL-exemption stamps to records that do not qualify, chilling public records requests by anyone who does not happen to know the URL.

There is no third option.

What We Did. What We Are Doing.

We downloaded the document from the County’s public server. We archived the URL at the Internet Archive’s Wayback Machine. We verified the file’s authenticity: its Bluebeam metadata (created November 10, 2025, 22:47 UTC), its 213-page count, its Brown and Caldwell logo, the signed professional engineer seal on its cover. We read it.

We are now hosting the full document in our Document Library. We are doing this because public records about a projected 30.8-million-gallon-per-day discharge into drinking water for 500,000+ Central New Yorkers should not sit behind a stamp that tells the public they have no right to see them — especially when the document is already public, and especially when the record shows a projected PFOS effluent concentration of 1,136 µg/L.

The Carollo Engineers RFAI response of November 7, 2025, which we also host, already established that the final SPDES permit as drafted contains no enforceable PFAS discharge limits. This document shows what the engineers are designing toward in the absence of those limits.

The County has not denied any of this. The County has not corrected any of this. The County has stamped it confidential.

We are posting it.

Caveats, Stated Plainly.

The 1,136 µg/L value is a projected Water Quality Based Effluent Limit (WQBEL), not a finalized permit limit. The report itself notes that the underlying CORMIX dilution modeling is not yet complete, that background instream concentrations are still under investigation, and that — in the engineers’ own words — “not all parameters listed below will be limited in the SPDES Permit; only parameters that exhibit a reasonable potential to exceed instream standards will be given a WQBEL.”

PFOS — with a federal drinking water MCL of 4.0 ng/L and a Maximum Contaminant Level Goal of zero — will almost certainly trigger that threshold. But the final permit limit, whenever it is issued, may differ.

What cannot differ is this: 1,136 µg/L is the number the engineers are designing toward, today. It is in the engineering report of record. It is 284,000 times the federal drinking water limit. And the County stamped the document that contains it “confidential.”