Sonoma County Water Agency
404 Aviation Blvd.
Santa Rosa, CA 95403-9019
Email: jchurch@scwa.ca.gov
Attention Jeff Church
Dear Mr. Church:
Introduction….The following comments are written on behalf of Russian River Watershed Protection Committee (RRWPC) by Brenda Adelman and concern the recent proposal by your agency on behalf of the Occidental County Sanitation District. We strongly protest the adequacy of the Initial Study and the Negative Declaration for Occidental County Sanitation District’s Wastewater Transport Compliance Project. Because of the highly controversial nature of this proposed project and its many unaddressed potential environmental and health and safety impacts, we believe that a full environmental impact report is necessary and that information presented in the Initial Study is grossly inadequate for determining the impacts of this project.
Since issues concerning neighborhood problems with the RRCSD transfer station were well covered by speakers at the community meeting in Monte Rio on February 16th, we will not attempt to cover that topic in our comments here, except to say that we support their concerns. We also will not discuss inadequacies of existing facilities at the Occidental County Sanitation District; but will leave that task to local citizens who are more familiar with the system. As for alternative projects, we would request further consideration of Ann Maurice’s proposal and also the possibility of utilizing Aho site for community septic system as described by Pete Lescure at meeting. Certainly, there must be other potential solutions to consider.
It is folly to consider trucking raw sewage on seriously compromised roads for long distances to a treatment plant that is severely constrained possibly causes river pollution because of infrastructural inadequacies.
We will address the following major concerns in our comments, although not necessarily in order shown here:
• Some recommended alternatives to include in a full DEIR
• Trucking and traffic impacts need mitigation:
o health and safety issues with the trucking route
o roads and environmental conditions of trucking project
o true costs of trucking project
o potential impacts to fish in Dutch Bill Creek
• Impacts on RRCSD
o Infrastructure impacts on RRCSD
o potential environmental impacts on RRCSD Treatment Plant
o Potential cost impacts to RRCSD ratepayers
• Road infrastructure and other impacts
o Monte Rio Bridge built in 1930’s and badly in need of repair
o details needed concerning transfer operation from RRCSD to Airport
RRCSD regionalization attempts, history, and pathogen problems….
RRWPC has been tracking issues regarding the Russian River County Sanitation District (RRCSD) since 1978, two years before our group’s incorporation. We have been particularly active since 1995 on the Occidental wastewater issue, when SCWA made a push to convert RRCSD into a regional facility serving Occidental, Camp Meeker, and Monte Rio, in addition to Guerneville and Rio Nido. (Monte Rio actively rejected hooking up to RRCSD when system was initially planned in the mid-1970’s.) Proponents of regionalization wanted to connect Forestville and Hacienda areas as well. Around the year 2000, SCWA developed an EIR on a project that would run two separate 10-12 mile pipelines from RRCSD to the Graton area in order to provide irrigation expansion area for 2600 connections. This was a strong indicator of their regionalization goals.
There were strong citizen objections to regionalization back in 1996 when Supervisor Carpenter was still Fifth District Supervisor. Many felt expanded urbanization in West County would result. That was seen as unacceptable in our fragile environment. We attended most of the Occidental and Camp Meeker meetings on wastewater issues in the intervening years since then and are concerned that this trucking of the wastewater is a ‘foot in the door’ for regionalizing a treatment plant that has spills and breakdowns almost every time there is a flood over 34’.
RRCSD’s treatment facility has inadequate storage in winter and inadequate irrigation area in summer and should have no added capacity use until these infrastructure needs are resolved. (Ironically, the Regional Board is very concerned about Russian River pathogens, and one of the first impaired areas they designated was 2/3 of the already sewered area between Guerneville and Monte Rio. We guess that they assume leakage from RRCSD that supports the impairment designation. Yet SCWA wants to add Occidental’s raw sewage to RRCSD and apparently Regional Board supports that plan. Later this year the Regional Board will move forward on new rules that will include new septic requirements which they believe are polluting the river. In any case, this is all the more reason why all impacts to RRCSD must be studied in a full EIR that mitigates anticipated problems. We also question range of loadings by OCSD (below) that also needs to be fully addressed.
RRCSD capacity issues…
The claim that RRCSD has dry weather flow capacity of 710,000 gpd is something of a myth but for limited exceptions. Supposedly the system can treat up to 3.5 million gallons per day during inclement weather, but when this happens, often problems emerge and spills occur. (In 1995 flows into the treatment plant got as high as 10 million gallons a day and a few years ago on tour at the plant, one of the workers mentioned dealing with flows as high as 8 million gallons a day.) Two notes to me from Regional Board Staff on January 11, 2017 relayed the following about recent problems with this year’s first flood:
Based on the information I received verbally from SCWA staff, they lost PG&E power to the plant on Sunday evening and the emergency generator at the treatment plant kicked on as it was supposed to. That generator powers the treatment plant and the Vacation Beach lift station. At 5:30 a.m. on Monday, the emergency generator failed causing them to completely lose power at the plant and the lift station. Other SSOs were caused when flows to the plant exceeded the wet weather capacity of the plant and water (a combination of sewage, groundwater and lots of flood water) had to be held in the collection system because they physically could not accept all of that water into the plant.
And also: On Monday and Tuesday we received reports from Sonoma County Water Agency staff regarding storm-related issues that resulted in unauthorized discharges. These unauthorized discharges were reported to the Office of Emergency Services OES. Power outages combined with high influent flows due to flooding resulted in discharges of partially treated effluent to land at the plant and sanitary sewer overflows at Vacation Beach and other locations in Guerneville.
It must be noted that these are fairly typical occurrences whenever the river floods, especially since much of the infrastructure is aging and most pumps and other components need to be replaced.
In summer, RRCSD has been known to over-irrigate at times causing wastewater to illegally get into groundwater at irrigation site, for which they have been penalized in the past. The golf course at Northwood was originally designed to take far more wastewater than it actually can and so more has to be applied to the redwood trees near the treatment plant. We heard in the past that the wastewater might be damaging the trees, but don’t know their current status. Also, there had been court battles with the property owner over the trees at one point challenging continued viability of irrigation field, but were apparently resolved. The owner reserved the right to log the trees and the District was paying next to nothing for rent to use the trees for irrigation. We need a full EIR analysis and audit of RRCSD’s irrigation system and how Occidental’s wastewater would be applied without causing any environmental problems. On average, RRCSD summer flows rarely go over 450,000 gpd, giving the impression that there is plenty of summer capacity. Awhile back, their discharge permit limited them to 500,000 gpd. For some reason that was lifted but an update of the situation is needed if OCSD is allowed to use our system.
About 15 years ago there was a proposal to run a pipeline down Bohemian Hwy. to RRCSD and connect both Occidental and Camp Meeker to the RRCSD. Camp Meeker was the lead agency on that project and ultimately turned it down. There were many environmental concerns expressed, including geological concerns, (please review the record for more information) but the main issue that caused its demise was the $22-million-dollar price tag. That denial came about the same time that Monte Rio gave up their 12-year pursuit of a system for their local community, primarily for the same reason and the same amount, $22 million. We agree that the price was exorbitant and needed to be turned down.
We know that the DEIR on that Occidental/Camp Meeker project failed to adequately evaluate impacts associated with adding flows to RRCSD. (We enclose comments on the DEIR from our attorney at the time. Many of the issues she addressed and questions she raised are relevant to the issues we bring up for this trucking project.) According to DEIR anticipated flows from both Occidental and Camp Meeker would run around 70,000 gallons a day, but we are being told in the Initial Study for the Trucking Project that Occidental alone has dry weather flow of 17,000 gallons a day. Something doesn’t match here.
Since Occidental has about 1/3 fewer hook ups (Occ. 283 and CM about 425) as Camp Meeker, we assume their dry weather flow would run about 46,000 gpd on average, if that 70,000 gpd number is correct. A DEIR on trucking project needs to fully address this flow issue and the impacts it would cause to the RRCSD. In fact, in contrast to these numbers, the 17,000 makes no sense. If we divide 17,000 by 283 hookups, that comes to 60 gallons a day. How would that be possible when average use, even when people conserve, is about 100 gallons a day or more? Also, averages are often deceptive. We do know there could be as many as 15 truck loads a day to transport in winter; assuming 4000 gallons per truck load, that comes to about 60,000 gallons on some days. So would the flow range go from 17,000 to 60,000, with the latter number including inflow and infiltration? Anyway, we are just raising the question and expect that a full DEIR would provide the answer.
Formerly discarded options should be reexamined….
The Occidental community is in a bind, as they face a punishing Order to Cease and Desist discharges into Dutch Bill Creek and also need to upgrade to tertiary treatment, or they will face very significant fines. It is a small community and adequate funds are an issue. Yet finding a solution to their problem has been an issue for the last 22 years or more and many of the attempted projects were ill-advised from the start, while what seemed to us viable solutions were deemed unacceptable for other reasons.
At the community meeting held on February 16th at the Monte Rio Community Center, there were numerous suggestions proposed. One was a program mentioned in the historical summary involving a community septic on the Aho property. Water Agency staff indicated that there was inadequate capacity on that property. I had attended the meeting where a Regional Board employee (long gone from the agency) insisted the field would not have the appropriate capacity. I remember the situation clearly, and believed that he misspoke, in that, Regional Board staff are not supposed to dictate the means of compliance.
At the time, Pete Lescure disagreed with the Regional Board staffer’s conclusion, along with Bob Rawson, both familiar with the proposal and the site and each having expert qualifications. (Pete was in attendance and spoke at the Thursday night meeting.) If the site might still be available, we believe the proposal should be revisited and reevaluated in light of the current situation. If still considered inadequate, why can’t the Aho site be used in conjunction with some other that in combination would give adequate capacity? It would seem far more advantageous to keep wastewater disposal close to home. The EPA reported to Congress about that time stating that situations like Occidental’s are far better served by small community solutions rather than large regional treatment plants with all the expensive pipes and pump stations, etc. (I located document on web but it was not possible to copy it. Exact Title is: “Response to Congress on Use of Decentralized Wastewater Treatment Systems 1997”.
I recently came across a summary of the analysis of Aho site capacity to serve as a leach field. (attached) There was some disagreement about the viability of site. While I can’t access this information now, I was active on this issue at the time and description in the notes sounds very familiar. Brelje and Race and Questa were all involved in testing two parts of the site. Regional Board signed off on their findings which included a small increase in application amounts to be needed during heavy rain periods. Ted Walker of PRMD agreed and signed off also. In fact, he thought both Camp Meeker and Occidental could utilize the site.
Then Regional Board changed their minds and I believe that later Walker backed off as well. At the time, we felt Regional Board’s decisiveness on this issue was inappropriate as they are not supposed to determine the means of compliance. We never heard a good reason for why they changed their minds. We assume they did not agree with analyses, even though they had done so in the beginning. Yet they seem to have no problem with this proposal to add OCSD waste to RRCSD while simultaneously considering the river running by treatment plant as impaired for pathogens. It was and is all very strange.
Initial Study Fails to examine transport issues….
So far this year, we have had back to back storms, including three floods in one year with probably more to come, and a federal government now filled with many people who do not believe in global warming. In the meantime, after almost ten years of relative and actual drought, people this year have been literally inundated with heavy rains and three relatively minor floods. They had forgotten the flood of 1986, (almost exactly 30 years ago as I write this) that was about 12’ higher than any we have had so far this year. One might also wonder if three or more floods in a season might be just as damaging as one big one, having caused large amounts of erosion and hillside slippage. It is essential that a DEIR be written to address these worst-case scenarios because lately, the worst case has been happening more and more. We might also mention that the hillside at the back of the treatment plant is very fragile and has been subject to major slides in the past. What would happen if both RRCSD and OCSD lose service at the same time because of this?
Transport system management during high flows and bad roads…..
This Study says virtually nothing about how the transport system will be managed during heavy rain and flood circumstances. The Initial Study merely states that during inclement weather trucks will go a different route to Airport Treatment Plant when RRCSD cannot take effluent. The report says nothing about triggers for making that determination, or how the trucks will be routed (if possible) when downed trees and branches, flooded roads, landslides, and more are in the way. What will happen when they can’t access either facility? How much pollution will occur in Occidental area if they can’t get the sewage out?
The route mentioned to Airport includes roads that are among the first to flood (Slusser for instance) and are likely unpassable at the very time they are needed most (i.e., 15 truck trips a day rather than four or five) What happens if truck comes to a flooded or otherwise impaired area and has to turn around? We have been told the trucks are 30’ long. How can they manage that on narrow, windy roads with blind corners such as Occidental and Bohemian both have, etc.? What if another large vehicle comes around a sharp, blind corner and meets another large vehicle coming from the other direction? It has happened and a few people have been killed or injured because of it. This is not an imaginary problem.
During the summer, many bicyclists use Bohemian Hwy. Years back, one was killed because a very large truck failed to see him and he had nowhere to go to get out of its way. There are steep drop offs at many parts of the road along Bohemian Hwy. People have been known to drive off the road trying to avoid car coming from the other direction into their lane. There are several very sharp blind curves that would be very hard to negotiate with a 30’ truck carrying 4000 gallons of waste. And Dutch Bill Creek is close to the road for most of the distance. How much damage would one spilled load do to fish in Dutch Bill Creek?
West Sonoma County roads are in horrendous condition. They are pot hole ridden, flooded, littered with tree debris and sometimes branches and occasionally fallen trees. There are landslides all over the place, greatly taxing the County Road Department to keep up with all the damage. I have never seen it this bad and I have lived in the area for 41 years.
Bohemian Highway feels almost like a roller coaster with many inundations. A friend is a registered geologist and strongly believes that parts of the road may be subject to debris flows. It is narrow, has many blind curves, and people have run off the road as it’s not uncommon for vehicles to come around a blind corner partially over the yellow line. There have even been some traffic deaths. There really needs to be a full analysis of traffic and safety considerations and accommodations for road repair both before and during the project.
What happens if RRCSD is not available for discharge? Wouldn’t it be advisable to have a backup discharge point much closer to home, such as Graton? (In fact, Graton should be one of the permanent alternatives to study. I understand they want the wastewater and they are much closer to Occidental. Why have you not studied this option?) Please fully respond to the risks of this situation. It’s not enough to be told that drivers are trained to deal with all situations. We want to know details. It is especially important that these issues be addressed because of the toxicity risk of the truck’s contents and because creeks are immediately parallel to the roads in many situations. A raw sewage spill into Dutch Bill Creek or Green Valley Creek or Atascadero creeks or the Russian River could be a disaster for the fish and completely negate the whole motivation for this project which is to stop polluting salmonid bearing creeks.
This brings to mind another question. I recall going over the bridge near Tyrone Rd. on Bohemian Highway in Monte Rio one year. It felt very unstable and I recall a rapidly beating heart afterwards. I later discovered that the bridge collapsed that day and I could have ended up in the creek. The road was closed for months afterwards. Are all the bridges that would have to be traversed by these trucks be rated for safety (including very small bridges)? Are you currently aware that these very heavy vehicles can always reach their destinations? What impact will those trucks have on that structure and others?
I have also learned that the and needs to be rebuilt. Will Occidental CSD chip in to pay for Monte Rio Bridge structural deficiencies that have been identified? What happens if the 30’ trucks meet with a fire engine or a school bus or some other large vehicle while traversing the bridge? It’s our understanding that accidents there happen frequently. And what will be the impact of these super heavy large trucks on the road surface and structural integrity? I have never seen so many potholes that have opened up this year already. And certainly, the risk of an accident is great and the opportunity for a raw sewage spill into Dutch Bill (or some other creek) is a great possibility in winter. You can kill off the very fish that this project is intending to save. Who pays the damages in that situation? A DEIR needs to examine these issues.
The folks at Oroville Dam knew about structural deficiencies 12 years ago and did nothing because they didn’t want to spend the money. Now they are in a fine fix with 200,000 people under threat of losing their homes, and maybe even their lives, if the dam blows because critical improvements were never made. (Three environmental groups warned them over and over about the problems.)
Bohemian Highway and Highway 116 are in slide prone areas. There have been many slides already this year. Luckily, none of them have caused accidents or injuries (that I am aware of). It is important to analyze the likelihood of debris flows and other slides and the areas in which they are likely to occur and/or that have a historical record of occurring.
Use of RRCSD to solve Occidental’s problem may be costly….
We have the impression that SCWA’s focus is on finding any solution to avoid substantial penalties from kicking in, and that at this point, you will do anything that the Regional Board will accept. We surmise that SCWA is willing to accept this because they too, are tired of this whole situation and want to be rid of it. But that logic does not justify the acceptance of a problem-laden proposal such as this one, however, especially since the high risk of a raw sewage spill into a salmonid spawning creek will make the problem much worse.
River flow unpredictability during unstable weather is a given. Localized flooding from creeks are even more of an issue. Furthermore, conditions that make it impossible to utilize RRCSD, may also make it impossible to use Airport because of transport problems. In the last month and a half, there have been three floods and infrastructure problems at both RRCSD and OCSD. In January, RRCSD pumps failed and there were discharges into the river. I know there were capacity and spill problems in February as well, but don’t know the details yet. I also heard Occidental had overflow problems. Who is responsible for the fines and penalties that will result? There have always been problems with RRCSD during floods and yet officials authorized a sewer system in the flood plain (and treatment plant right next to it). We suggest an EIR be written that describes how the trucking project would function under the exact circumstances we have experienced this winter.
The Russian River County Sanitation District News of Spring, 2016, explains part of the problem as follows: “The RRCSD is, by far, the most complicated collection system pipeline network in the County. It takes 11 separate pumping stations to get wastewater from users’ homes and businesses to its treatment plant. These stations represent the harshest working conditions of for electrical and mechanical equipment. These stations require constant maintenance and frequent pump rebuilds, and periodically their high voltage electrical systems must be completely replaced. Over the next decade, the RRCSD will be attempting to rebuild one station a year.” We do know that some of the most serious spills in the system originated from pump station problems. These problems almost always come up in the rainy season and there should be no additional sewage treated until all are repaired.
Furthermore, a spill into Dutch Bill Creek would cause many water quality violations. What would be the cost to Occidental if they had to pay for a cleanup and pollution penalties besides?
We request that some kind of analysis of road impairment circumstances. Sonoma County has been identified as having some of the worst roads in the North Bay area and has had very inadequate funding to bring roads up to standard. It would be important to analyze the levels of repairs necessary on any of the roads traveled and whether the people benefitting from this intense road use would be held fiscally liable for repairs needed that result from that use. This project benefits Occidental only and citizens of Sonoma County should not have to pay for additional road repairs resulting from the intensity of use.
What are the true costs of the trucking project? What are the costs to rate payers of the RRCSD who would have to pay for wear and tear to their treatment plant from this added waste product? There needs to be a complete cost analysis of not only the conversion of the pump station, but also the infrastructure operation and maintenance, disposal costs, equipment costs, capital improvement costs, etc. From time to time RRCSD gets expensive penalties for spills and other problems from the Regional Board.
Occidental should be made to pay a fair share of RRCSD penalties as well. This needs to be spelled out and a budget developed. $180,000 a year doesn’t seem like nearly enough at all. In fact, OCSD ratepayers currently pay about $606,000 a year for service. It seems like OCSD is getting a cheap project on the backs of RRCSD ratepayers. Where is the rest of the money going if they are not using Occidental system? (besides trucking costs) Please give breakdown of how RRCSD fees will be used to contribute to repair and replacement of needed parts and equipment. Finally, don’t you think this project should contribute to County road maintenance and repair since it will have a huge impact over time on road conditions?
All in all, we have made the case for a full EIR. There is much that needs to be studied and this Initial Study is totally inappropriate for the extent and precedent setting use of RRCSD.
Thank you for allowing us to comment on this project.
Brenda Adelman
Attachments to Email:
Comment Letter
Aho Property Capacity Notes from 1-29-08
Ellison Folk CEQA Comments on Occidental/Camp Meeker EIR 8-9-07