RRWPC ADDENDUM on Waste Discharge Requirements and Master Reclamation Permit for the City of SR Subregional Water Reclamation System, Sonoma County, July 22, 2013

July 22, 2013

Matt St. John: Executive Officer

North Coast Regional Water Quality Control Board

5550 Skylane Blvd. #A

Santa Rosa, CA 95403

Attention: Charles Reed

Delivered by Email: CReed@waterboards.ca.gov


Waste Discharge Requirements and Master Reclamation Permit for the City of Santa Rosa Subregional Water Reclamation System:  Sonoma County

ORDER NO. R1-2013-0001

NPDES NO. CA0022764

WDID NO. 1B830990SON

Dear Mr. St. John, Mr. Reed, Chair Noren and Regional Board Members:

Enclosed are a few additional comments in consideration of some new information I just obtained from staff.  These included technical and monitoring reports in response to Order 13267 (b).  This Order addressed two complaints about over-irrigation at Sonoma State and Rohnert Park wastewater irrigation areas.  RRWPC had filed complaint concerning Rohnert Park’s over irrigation.  (The two documents responding to Order 13267 are added here as #8 and #9.)

Our main comments, recently submitted today, focused on our concerns about extensive over-irrigation of wastewater on Rohnert Park properties, the large number of repeat offenders, the lack of detail in their reporting,  inadequate oversight, and overall seeming lack of concern for preventing discharges into our streams in the summer time.  Some of the worst nutrient pollution in the Laguna is west of Rohnert Park.  There is so much care lately to develop a nutrient offset program for winter discharges, but inadequate attention (we believe) to the nutrient contributions resulting from these overflows.  In light of the severe nutrient pollution in the Laguna and to some extent in the Russian River, it behooves you to take a strong stand on this issue of over-irrigation.

One of our major concerns is the frequency of monitoring.  One of the documents included was this response was daily monitoring reports for a two week period.  My comments on the revised permit emphasized the need for more frequent monitoring than every two weeks or monthly, as suggested in the revised permit.

Here are results:  (gallons lost were not noted in report)

8-27-09:  6 incidents noted

8-28-09:  11 incidents noted

8-29-09:  8 incidents noted

8-30-09: 7 incidents noted:  no report on 4 sites

8-31-09:  12 incidents noted

9-1-09:  9 incidents noted

9-2-09:  9 incidents noted:  noted leak on one which was scheduled to repair ‘SOON’

9-3-09:  11 incidents noted

9-4-09: 12 incidents noted

9-5-09:  9 incidents noted: no report on 8 properties

9-6-09:  8 incidents noted

9-7-09: 11 incidents noted

9-8-09: 8 incidents noted

9-9-09: 8 incidents noted: no report on 5 properties

Most of these incidents above noted water on curb, gutter, driveway.  Many are areas we emphasized in our comments. (Redwood Creek Apartments was found to have runoff on 10 of those 14 days.  Roberts Lake Park was over-irrigating on 11 of 14 days, but on one day there was no report.  And Mountain Shadows Apartments were over-irrigating on 8 days with no report on one of 14 days.

This is the difficulty of urban irrigation and it needs to be more effectively addressed.  It appears as though Rohnert Park has not been serious enough about dealing with this problem.  I have heard Darren Jenkins say recently that Rohnert Park ‘minimizes’ their runoff.  When no details are given, it’s hard to know what this means.

The contract says little about how the system will be managed to prevent runoff.  RP’s guidelines to satisfy the safe use of recycled water is one page long and contains only 12 items starting with the statement that “Runoff of reclaimed water and spray shall be minimized.”  They did nothing to stress the importance of this requirement and gave no details how to do it.  (document attached).

Without going into extensive detail, these documents prove (in our eyes anyway) that Rohnert Park has a long way to go in managing their system to show concern for the environment.  In the 14 days monitored above, there were 129 overflow instances reported. If this were extrapolated for the whole summer, we are talking about very significant numbers.  Someone needs to give RP the message that it can’t continue this way and I hope this permit will be strengthened to do just that.

Sincerely,   Brenda Adelman