This mailer attempts to weave a wastewater story with numerous threads together into a single tale. Over the last ten years you have read about many of these threads separately, so none will be unfamiliar. It is of especial importance to those who rely on a septic system to treat waste, but should also concern those on central sewer, such as the Russian River County Sanitation District (RRCSD). Read on and let us know what you think.
Thread 1: Imminent approval of two new regulatory documents…..The governor of California signed AB 885 into law on Sept. 27, 2000, calling for the development of new regulations for siting, repairing, and replacing Onsite Wastewater Treatment Systems (OWTS).Since that time, AB 885 has suffered through many ups and downs, huge controversies both locally and statewide. At long last, the following two regulations are about to be authorized for the Russian River Watershed:
On May 21, 2019, the Sonoma County Board of Supervisors will consider approval of the new Onsite Wastewater Treatment System Regulations and Technical Standards (Enter: Revised OWTS Manual into your computer search engine for documents). This document encompasses new regulations covering the siting, installation, and maintenance of septic systems and is meant to protect surface and ground water resources from bacterial contamination. If you are living with a system that does not meet current standards, and you need a building permit that expands capacity of your structure, you will be required to also upgrade your septic system to meet the new requirements. Cesspools and redwood boxes will no longer be authorized, but the County will not come on your property uninvited to check, unless a formal complaint is filed. However, at some point you will probably get a letter from the North Coast Regional Board asking you questions about your system.
On August 14th or 15th, 2019, at 8:30 AM at Regional Board Offices (5550 Skylane Blvd. Suite A, Santa Rosa) the North Coast Regional Board will consider authorizing the Draft TMDL (Total Maximum Daily Load) Action Plan for the Russian River Watershed Pathogen Total Maximum Daily Load and Prohibition of the Discharge of Fecal Waste Materials as an amendment to the Water Quality Control Plan for the North Coast Region. This is a complex document that has gone through many iterations over the last ten years. RRWPC plans to write comments and post a sample letter on our website by June 1st (www.rrwpc.org ). You can copy the letter, sign it, and send it in, or write your own. (We just received documents and cannot provide letter in time for this mailer.) Letters are due Monday, June 24th, 2019. Documents can be found at Regional Board’s website: http://www.waterboards.ca.gov/northcoast/water_issues/programs/tmdls/russian_river
Thread 2: Plan of Study for Monte Rio & Villa Grande Wastewater Treatment Project….Implementing these new regulations will be a formidable task for Regional Board staff as they work closely with Sonoma County Well and Septic Division to devise protocols for a smooth process. Their plan is to initially focus on Monte Rio and Ville Grande (in close proximity to each other) to serve as an implementation pilot project. A 9-member citizens committee was established to help with initial planning and implementation of the process and give input from the community perspective. (RRWPC is one of the 9.) Representatives of State and County departments and the Board of Supervisors, responsible for implementation and planning, provide oversight through a technical committee. An ombudsman will be hired soon by the County to facilitate communications, assist with implementation, and educate the public about the new requirements.
It has been anticipated that some community residents may need financial help to make needed improvements. The plan is to develop various options and combinations of allowable septic system remedies and will also include the possibility of hooking up to the central system (RRCSD). Some members of the CAG (Citizens Advisory Group), along with the Inter-Agency Team, are researching funding sources and assisting with loan and grant applications. Sonoma County Water Agency staff wrote a Plan of Study that included project description, stakeholder participation, scope of work, schedule and budget, etc. RRWPC commented on two of the iterations.
A big concern is that many of the sites in the area are environmentally constrained and conventional septic solutions may not be viable in some situations. The Plan offers few details about how this will be resolved. More attention appears to be given to remedies that would support attachment to the central system (RRCSD), while not mentioning that is likely to require hooking up everyone in order to achieve cost efficiencies. Rather they convey that some can hook up to central sewer and some to various septic system arrangements. Since meeting the new requirements is likely to be expensive for this mostly low income community, the big question is how either approach is going to be affordable, and whether grants can be obtained to make it so. Unfortunately, either way, this will is likely to be an expensive proposition for most people. Staff from County and Regional Board insist that no one will lose their homes over this and they will make every effort to accommodate people’s needs. We’ll see….
Thread 3: Problematic history of Russian River County Sanitation District (RRCSD)…..For many years, RRWPC has held the view that no new community hookups to RRCSD should be allowed because the susceptibility of failure during major flood events, based on prior experience, is bound to occur, thereby causing non-compliance of their discharge permit. Discharge Prohibition E in RRCSD’s permit states, “Any sanitary sewer overflow (SSO) that results in a discharge of untreated or partially treated wastewater to (a) waters of the State or (b) land that creates a pollution, contamination, or nuisance as defined in Water Code section 13050(m) is prohibited.” (Nuisance as defined fits the definition.) This prohibition can lead to heavy fines if violated.
RRWPC has tracked this project (RRCSD) from the beginning. The system was built in the early 1980’s and hookups began in 1984. There were many cost overruns (30 change orders), lawsuits between contractor and County and I believe subcontractors as well. (They had to redo part of the system with a new engineer because of so many mistakes and inadequate oversight.) They spent an extra $1million to take out underground redwood stumps. They had to re-align the pipe between Rio Nido and Guerneville because it did not meet in the middle. They cut the number of pump stations and lowered pipe slope to cut costs. (Contractor bids had come in much higher than what Federal and State Grant programs had to spend and citizens approved.) It could follow that there are design flaws in our system.
Next October RRCSD ratepayers will be billed $1625 on their property tax bill for sewer services only. Every year the fee goes up an average of 5%. The system is managed and operated by the Sonoma County Water Agency (SCWA). They have told us that it is the most difficult of the eight County systems they manage, including the much larger City of Sonoma system. To give one comparison, our 3300 hookups system has 11 pump stations; Santa Rosa’s 40 mile pipeline up steep mountains (Geyser’s Project) uses five pump stations and Santa Rosa’s average daily flow is 44 times greater than RRCSD, whose rates are also one of the most costly. It must be mentioned however that significant improvements have occurred from RRCSD expenditures, including new disinfection and nutrient removal systems. It’s just that because of environmental constraints and the complexity of the system, it is extremely costly to operate. Furthermore, the aging system is not only in need of pump station and other expensive improvements, but has inadequate storage and irrigation area for even current ratepayers. (If a local entity could run our system, it would probably be much cheaper.)
After many years of draught, this February we had two floods. The first one was mid-month and came to about 36’, four feet over flood stage. Even at that low level, there was a surging manhole at Riverside Dr. next to the Main Pump Station. The overflow volume was estimated at 200,664 gallons. In general however, there was little flooding in the community at that time. Roads remained open and in most cases, flood waters did not inundate structures. We were told that the sewer system, but for the surging manhole, functioned well throughout.
And then came the largest flood in about 22 years on February 27th, almost reaching 46’. We wrote a great deal about this in our March mailer, but several things have happened since that you should know about.
Thread 4: First-hand account from a neighbor of a surging manhole….Esa Day, an RRWPC supporter, lives close to the Vacation Beach Pump Station, the closest station to the treatment plant but about ½ mile away. She first noticed the surging manhole (roughly 200’ from the Pump Station) around 1:00 PM on February 26th (Tuesday) BEFORE the river flooded. (Like the manhole by Riverside Dr., this manhole had been subject to repetitive surging during prior floods.) Esa has three children, the youngest of whom is 2.5 years old and loves to play at the children’s park next to the pump station and near the surging manhole. After the 2017 flood, Russian River Park and Recreation was able to get things cleaned up in a moderate amount of time. This time, the park has been fenced off and unusable since early March. There is apparently a problem with insurance that prevents cleanup.
Concerned for her children’s safety, Esa had talked to many agency people to get help with cleanup of the street and park. She became motivated to take action and wasn’t shy about telling people what it’s like to drive through slimy sewage up and down her street through the used toilet paper and associated waste product (picture brown, round, objects). It took a very long and messy week before the toxic sludge was cleaned up.
Esa and I had two meetings with Water Agency staff both in their office and at the site, with the latter including Supervisor Lynda Hopkins. We also went to the Regional Board meeting and talked to the Board during Public Appearances, and afterwards the staff. I had written a letter to the affected agencies and gotten a 2.5 page response from Grant Davis, General Manager of the Agency. I had met separately with the Executive Officer of the Regional Board and the staff person who writes their discharge permits. RRCSD is due to have their permit reissued this year.
We informed officials that the spill went on for four days, not two as stated on form in the 45 -day report to the State. (It was reported that 336,000 gallons spilled in two days. We don’t know what accounts for the two day difference, but if you double that number, you get a 672,000 gallon spill for four days. In the spill narrative they stated the surging began on Feb. 27th and on the form they stated it began on March 1st) Furthermore, the Water Agency representative admitted workers mistakenly redirected sewage into a neighbor’s yard and then he suggested that they can reconfigure the drainage to go towards the river next time. They said nothing about fixing the problem and stopping this from happening again.
You can guess that redirecting the flow towards the river is exactly the kind of action that would not be allowed either in their current discharge permit or in the new TMDL. In fact, just the opposite. All of the studies indicate that most bacterial contamination gets in the river during winter rains, runoff, and floods. These new regulations are meant to regulate septic systems so that this would no longer happen, or at least be limited. If they believe that the central sewer is a better option, they need to fix all the problems with that system first. And this could be far too expensive for these small communities to bear.
Yet in the letter and emails they wrote, the meetings we had, the concerns I expressed, there was no response to the fact that allowing these spills to continue during a flood, is a violation of their discharge permit. The letter from General Manager Davis was a good letter, telling all about their accomplishments and money spent in improving the RRCSD, and how hard they worked keeping everything running smoothly. Conversations with staff were friendly. Everyone blamed the event on the heavy rain that preceded the event. Yet not one of these people answered our questions: “What specifically is wrong with the system? What can be done to prevent, or at least curtail future illegal manhole surges of raw sewage? Is the Regional Board, author of the permit, going to take regulatory action as the permit requires?” The only response we got was that the spill was uncontrollable because of the flooding river. But that is the justification for requiring septic system upgrades and replacements. What would be the point of making property owners go to huge trouble and expense if the central sewer system does not work any better than septic systems do and fails at the very same time during winter rain events?
The TMDL Action Plan regulating bacterial discharges states: Discharges of waste containing fecal waste material from humans or domestic animals to waters of the state with the Russian River Watershed are prohibited. Compliance with this prohibition can be achieved in the following manner: 2. Comply with all fecal waste/pathogen-related provisions of an applicable NPDES permit.” There is no NPDES permit that allows surging manholes without penalty.
We have numerous reasons to believe that hooking up Monte Rio and Villa Grande to the RRCSD is seen by regulators as a solution to fulfilling the TMDL. During our conversations, the flood was blamed for the surging manholes, but surging also happened during smaller floods and before this flood occurred. We believe the aging system needs major rehabilitation that could be very expensive. Water Agency staff blamed the flood and potential costs and said nothing about fixing the problem. (Would a new pipeline under the river be needed as well as a lot of replacement of pipes to serve structures in the flood plain, about a quarter of the system?)
Thread 5: The larger issue and inadequate response to sewage spills….I believe that people mentioned here are basically good, responsible people. They acknowledged and promised Esa that her concerns about clean up, warning neighbors about flood impacts, the spill and system management during the flood, improving notification issues and warnings, all needed to be and will be addressed. Supervisor Hopkins talked about setting up a committee to produce a brochure of things to do, people to call, information about the sewer and how to avoid over-loading system during floods, etc. People also need to be aware that the flood waters are probably as toxic (or more so) than the sewage. All the chemical products, herbicides and pesticides, medications, paint products, etc. swept away by the flood, combine to form one nasty toxic soup. People should avoid contact with flood waters as much as possible.
Please don’t hesitate to send us your questions…..We know this information is rather complicated. It would be perfectly understandable if you find it confusing. Please send questions to Brenda Adelman at mailing address above or firstname.lastname@example.org I’ll look forward to hearing from you. Although I can’t answer questions about specific properties, I can probably provide ideas about how to get information you need.
Brief update on Fish Flow Project (low flow)….Sonoma County Water Agency announced that they are still working on responses to environmental review comments (mostly the 77 pages worth submitted by the State and Regional Board). There are so many changes required to the document, the y will have to recirculate it for another round of comments. They estimate that recirculation will occur sometime next winter.
RRWPC needs your continued support….RRWPC counts on your continued support to sustain our river protection work. Some of you have not donated for a while. We would love to hear from you so that we know you continue to be interested in receiving our mailers and supporting our work. Any sized donation is appreciated. We rely on six mailers a year for our entire fiscal support. Also, if you sent in a donation in March or April, but did not get a thank you letter, please contact us. Our post office was out of commission for a while, it might have gotten ‘lost in the mail’. Please let us know.