March 2011
River friends:
For many years RRWPC has been submitting comments to the State Water Board and the Regional Board expressing concerns about their Water Recycling Policy that allows “incidental runoff” by wastewater irrigators. In the State’s development of the Policy a few years ago, the legalization of incidental runoff caused the greatest controversy. A committee representing many interests was appointed to negotiate the controversy, and they compromised by agreeing to establish a “blue ribbon” scientific panel to determine how to monitor the unregulated chemicals, including personal care products and pharmaceuticals, etc., also referred to as “chemicals of emerging concern” (CECs).
These chemicals have a strong potential for getting into the waterways through wastewater irrigation runoff. (Tertiary treated wastewater does not remove all contaminants.) it has been well documented that they can cause potential birth defects, cancer, endocrine disruption, etc. in humans and wildlife. The special committee did not even consider impacts on wildlife.
The recent preliminary findings of the scientific panel are that no additional monitoring of unregulated contaminants is necessary for urban irrigation projects. (Monitoring is only regulated for approximately 150 constituents. Many thousands are not regulated.)
We question their findings because they did not look at chemical compounds, but only a relatively few select individual constituents. They did not look at synergistic or cumulative effects of multiple exposures of either the same chemical exposure or a range of chemicals. They made no attempt to address impacts from most of the 80,000 chemicals currently being produced.
They did not look at impacts from bioaccumulation in soils, nor the potential for impacting groundwater quality. (They assumed that wastewater would be applied in such a way so as to not seep into groundwater.) They considered, but did not fully address the impacts of these chemicals on infants and young people, elderly people and those with compromised immune systems.
We are extremely concerned that irrigation runoff will also carry other chemicals used to treat the soil and kill the bugs and weeds, such as soil amendments, pesticides and herbicides, off the site and into our impaired and highly utilized waterways. This runoff might occur in the summer when flows are low, assimilation poor, and human contact high, not to mention the prospect of further reductions in Russian River flow imminent as a result of proposed changes to Decision 1610.
To top things off, we have recently learned about a new and very serious issue. (See attachments) Thyroid cancer patients are often given a radio-active “cocktail” to destroy remaining thyroid cancer cells in their blood stream. In Europe patients having these cocktails remain in isolation in hospitals for several days while they are “radio active” and until the material fully leaves their system. This was also done in the United States at least through the 1970’s, if not longer. It appears that the insurance companies lobbied to change this rule in the 1990’s because of the high cost.
Patients normally remained in almost full isolation for about three days. All body fluids, all water the patient came in contact with, including toilet and bath water, all food utensils and all materials in the room were placed into protected storage for about 50 years, the time it would take to de-contaminate the material. Nothing left the room without being checked by a geiger counter and anything contaminated went into long term storage. The attached letter goes into further detail. (RRWPC/Basin Plan Amend/2-15-11) I can personally attest to this practice.
Currently, people are either sent home or go to hotels. Their water waste is flushed into the sewer system. We have never seen this issue addressed and it is not even addressed in the Markey letter to the Atomic Energy Commission included above. Representative Markey was primarily concerned about the risk to public health by allowing people to reside in hotels and motels until the radiation wears off, thereby exposing large numbers of the public to excessive radiation. As far as we know, nobody addressed the impacts to the environment from flushing radio-active waste.
In the meantime, the State authorized the Water Recycling Policy and our local Regional Water Board included the authorization of “low threat” discharges, including incidental runoff as part of their new Storm Water Permit. They also authorized a Basin Plan Amendment that allowed for this practice to occur locally. Throughout the process, we pleaded for better definition of how incidental runoff would be regulated. We believe that it is far too vague. In effect, this new policy allows summer discharge under certain circumstances into a waterway that is already highly impaired for nutrients, other conventional pollutants and who knows what else?
Dr. Dave Smith, Managing Director of the WateReuse California (and 25 year consultant to the City of Santa Rosa) provided comments to support the Regional Board’s approval of this policy and the amendment. He also played a lead role in setting up the committee and its agenda at the State level. At Regional Board meetings on this issue, he was called on to speak after RRWPC comments were complete and he minimized, if not dismissed every one of our concerns to the Board. Not one Regional Board member expressed any support for any of the concerns we raised.
Incidental runoff is very loosely defined in the new regulations and policy. In the Healdsburg permit it relies on self reporting by the irrigator (up to 1000 gallons on ag parcels in Healdsburg’s NPDES permit). Healdsburg worked hard and successfully to loosen up the new provisions, since vineyard owners were saying that they will not take the water if they have to follow all the regulations.
The Basin Plan Amendment is very vague and somewhat ambiguous about what will happen if a spill should occur. Supposedly the irrigator is responsible to report runoff to the permit holder (for example, the City of Healdsburg), who then is responsible to report to the Regional Board. This Policy does not apply to ag irrigation, but the ability to self-report up to 1000 gallons is a hint of how the policy will be defined.
We are particularly concerned that the Regional Board has been losing manpower who cannot be replaced and they will be relying on the dischargers to provide the critical resources needed to regulate these activities (and others as well). The fox will be in charge of the chicken house and potential for abuse of this program, to the detriment of water quality, will be of great concern.
The Basin Plan Amendment waited for State Board approval for over a year. They finally noticed a comment period that happened at almost the same time as the Estuary Project (Did someone plan it that way?). We were unable to get notices out because we were afraid the public would get confused if we tried to cover two issues. Comments were due two days after the due date for the Estuary Project. We managed to get the attached letter in, but could not solicit other letters. They acknowledged that they received our letter, but no one responded to our comments.
Now there is a State Board meeting on this on Amendment approval on March 15th. We don’t know if we can attend and we think it is a slam dunk anyway. The State is determined to spread this WASTEwater far and wide! I hate to sound pessimistic, but I don’t think we stand a chance on this one. I just wanted to inform you of this issue. We will continue to track this and ask your help by reporting to us ANY over-irrigation you see this summer time. (rrwpc@comcast.net) Potable water is not supposed to be over-irrigated either. Any wet spots on sidewalks and streets are not allowed. Ponding on landscape is not allowed. If you can take a picture, please do. Also note the exact date, time, and location. We will be watching! If you want to pick a spot to watch on a regular basis, we will try to set that up. We have found pictures of polluting activities to be enormously effective is getting them to stop the practice. Please help us.
Finally, we have attached a series of definitions of the Precautionary Principle and references that supports the idea that polluting activities should not be allowed until they are proven fully safe, NOT allowed until they are proved fully unsafe, as it is done now!
Forgive the length of this email. We felt this was important material to spread around. Forgive duplications also and please pass on to friends and other interested parties.
Sincerely,
Brenda Adelman