RRWPC Report: Santa Rosa Wastewater Irrigation Runoff, February 10, 2012

RRWPC Discovers Possible Irrigated Wastewater Runoff on Stony Point Road from Santa Rosa’s recycled irrigation project

February 10, 2012

Over the last several years, RRWPC provided extensive comments to the State Water Resources Control Board (SWRCB) and the North Coast Regional Board (RB1) on the issue of “incidental” runoff of irrigated wastewater. We ennumerated our concerns regarding the State’s Recycled Water Policy (adopted 5-14-09), the Statewide General Permit for Landscape Irrigation Uses of Municipal Recycled Water (7-09), the Regional Board’s MS4 Permit (Municipal Separate Storm Sewer System Storm Water Permit) (7-23-09), and the Basin Plan Amendment for “Low Threat Discharges” (10-1-09) where the recycled water issue was addressed. We provided testimony before both boards on numerous occasions, along with discussing our concerns with staff.

Why is RRWPC so concerned?
Treated wastewater and potable water generally look and smell exactly alike. Unless specific signs are placed nearby, there are no warnings to tell people where that water has been. While only highly treated wastewater would be used, nevertheless treatment processes are sometimes imperfect and unreliable. Furthermore, there are many unregulated and/or seldom monitored toxins such as endocrine disruptors and other toxins, including pesticides and herbicides, organic chemicals, heavy metals, nutrients, and much more. These have been demonstrated in numerous studies to have significant negative impacts on humans and wildlife. We have especial concern for children who may play on lawns irrigated with wastewater.

(Signs are supposed to be placed in public irrigated areas informing people about the use of wastewater. The one sign we saw on our photo shoot in Santa Rosa had been saturated with the wastewater and was barely readable. We saw no signs on the grass or public areas where this is commonly used and where people are likely to congregate.)

(For an excellent source of information about endocrine disruptors and public health effects go to TEDX. Or you can get the list of the possible 870 endocrine disrupting chemicals with documented scientific studies showing effects on endocrine system at: tedxlist@endocrinedisruption.org These toxins impact many of our organ systems and can attack reproduction, fetal development, nervous sytems and behavior, immune and metabolic systems, liver, bones, other glands and tissues. We also recommend viewing the video of Theo Colborn talking about the male predicament. This video explains the decrease of male sperm over time and other possible reproductive health impacts on future generations.

Finally, there is a article in the recent Mother Jones magazine (January/February 2012) called the “Frog of War”, page 44. This is the story of atrazine, and the studies of well known scientist, Tyrone Hayes. Dr. Haye’s vast research chronicle the sexual alterations to frogs whereby trace amounts of atrazine (top-selling herbicide) cause changes in the biological sex of the species. Frogs are the “canary in the mine” so to speak.

In addition to unidentified constituents in the wastewater, the irrigation runoff often carries toxic chemicals and soil amendments into the drainage system from treated landscapes. Most of this occurs in the summer time, when creek flows are low, recreational use is high, and toxins tend to bio-concentrate, while chemicals interact with one another and may bio-magnify their effects. (Irrigation applications are supposed to be applied only in amounts that can be utilized by the plants so as to avoid runoff. Therefore cold weather applications, such as ones we discovered recently, should not be allowed.)

In Santa Rosa’s case recently, runoff was seen entering the storm drain system, probably exacerbating existing nutrient problems in the Laguna, which is currently listed as impaired for nitrogen, phosphorus, dissolved oxygen, temperature, sediments, and mercury. (The Basin Plan Amendment allowing “incidental runoff” should NOT have been approved BEFORE completion of the Laguna TMDL process.)

It is common for people to allow runoff during lawn watering. Even when they are educated to irrigate responsibly, it is human nature to take short cuts when no one is looking. It is difficult to follow all the rules inherent in a recycled water program. While the State acknowledged the problem and included language in their Policy to supposedly address the issue, nevertheless, both the State and Regional Boards failed to designate a specific definition of the term “incidental runoff”. Do they limit runoff to 10 gallons, 100 gallons, or 1000 or more gallons? No one knows, and the result now is that Santa Rosa city staff and consultants are claiming that any amount of runoff is “incidental”.

The State’s Recycled Water Policy
Control of incidental runoff.

Incidental runoff is defined as unintended small amounts of runoff from recycled water use areas, such as unintended, minimal over-spray from sprinklers that escapes the recycled water use area. Water leaving a recycled water use area is not considered incidental if it is part of the facility design, if it is due to excessive application, if it is due to intentional overflow or application, or if it is due to negligence…. the project shall include, but is not limited to, the following practices:

(1) Implementation of an operations and management plan that may apply to multiple sites and provides for detection of leaks, (for example, from broken sprinkler heads), and correction either within 72 hours of learning of the runoff, or prior to the release of 1,000 gallons, whichever occurs first,
(2) Proper design and aim of sprinkler heads,
(3) Refraining from application during precipitation events, etc……

The North Coast Basin Plan provides a similar definition, but also admits: “Due to the unplanned nature of incidental discharges, this category of non-storm water discharges poses a slightly greater risk to water quality due to the potential for higher levels of pollutants and less opportunity to control the rate, volume, and timing of the discharge.” Yet they don’t describe the additional risk and continue to leave questions about what they are referring to. Even worse, they don’t explain why this is not a violation of the Clean Water Act, which carefully regulates all waste discharges.

RRWPC and many others had consistently requested that the term “incidental” be numerically defined. It never was, and is now up for speculation. Nevertheless, the photos taken by RRWPC between December 14, 2011 and January 9, 2012, illustrate the on-going and non-incidental nature of the runoff. (We include a few photos with this email. There are 65 all together from 5 dates. Contact Brenda at rrwpc@comcast.com if you want access to more of the photos.

We might also add that the State, unable to fix its water supply problem in the Delta and other parts of the State, is resorting to toilet to tap measures to beef up the water supply. Over the years, the lexicon of wastewater has moved through numerous transformations. When we started this work in the early 1980’s, wastewater was treated sewage. The common terminology then moved to treated wastewater, or simply wastewater. Wastewater then became recycled water and now it’s been “cleaned up” to be simply irrigated water, even though the final product is essentially the same.

Santa Rosa’s Recycled Water Project
For many years, the City of Santa Rosa had been planning a recycled water pilot project on Stony Point Rd. between West College Ave. and Highway 12. Last year they completed the project and hooked up most of the City properties, business parks, public service buildings, shopping centers, and apartment complexes in that area.

(We do not know exactly which properties are NOT hooked up, so some of our pictures may be of potable water rather than wastewater. None the less, over-irrigating with potable water is illegal also per the North Coast Basin Plan, due to chemicals in the water. Furthermore, the runoff may carry toxins applied to the landscape into the stormdrains and waterways.)

To assure the State they would be in full compliance with the Policy, the MS4 Permit and the Basin Plan Amendment, the City authored a 106 page document called the “Recycled Water User’s Guide”. This guide is reader friendly with lots of pictures and good advice. The document explained that the hookup requires a City of Santa Rosa Use Permit and that specific design and installation requirements apply, including the posting of signs announcing the use of recycled water.

We cite one page here to give a sample of the detailed requirements for administering the system:
Annual Self Inspection Report and regular monitoring
…..To assure full compliance with the rules and regulations governing the use of recycled water, regular monitoring of any recycled water system is necessary. For irrigation systems, weekly or twice-monthly inspection is recommended. inspection should include site observation for the following types of situations:
1. is there evidence of recycled water runoff from the site? if so note location and nature of the problem.
2. is there evidence of recycled water ponding, and/or evidence of mosquitoes breeding within the irrigation area due to ponded water?
3. are warning signs, tags, stickers, and above ground pipe markings properly posted to inform the public that irrigation water is recycled water, which is not suitable for drinking?
4. is there evidence of leaks or breaks in the irrigation system piping, or tubing?
5. is there evidence of broken or otherwise faulty drip irrigation system emitters or spray irrigation sprinklers?

Recycled Wastewater Runoff Pictures and Report
On December 5, 2011 at 10:30 AM I was coming out of a meeting at 35 Stony Point (SR Service Center) and saw about 6-8 irrigation sprinklers irrigating the lawn directly across Stony Point Rd. at the back of the Finley Center. All sprinklers were fairly close to the street and one of them was pointed towards the street. It is our belief that wastewater was going into the street and probably into the storm drain. I could not stop to take photos. I had no way of knowing how long it had been going on or when it stopped. I believe that site is irrigated with wastewater.

Two days later I attended a City of Santa Rosa meeting where I informed Santa Rosa staff of what I saw. They denied it was wastewater irrigation and stated something about PG&E boxes being flushed out. A few days later, I also informed Regional Board Staff of what I saw.

Wastewater Irrigation Runoff Photographs
Santa Rosa’s Pilot Recycled Water Project was constructed along Stony Point Road between West College and Highway 12. I visited the area between 8 and 9:30 AM on December 13th and 21st and January 4th, 6th, and 9th. The temperature was between 32 and 40 degrees at all of those times. I didn’t get many pictures on Dec. 21st because it had been drizzling a little and it was hard to differentiate runoff. On a few mornings, you could see frost on the grass. At no time did I ever see the sprinklers going again, but I did photograph plenty of evidence of irrigation runoff. On the way to and from the Stony Point Rd. area, I looked to see if irrigation was occuring on other city streets. I saw no evidence of irrigation runoff anywhere else. The sites I photographed included:
1. City Bus Stop at corner of West College and Stony Point Rd.
2. Front sidewalk & street (W. College) of Finley Community Center (no evidence of runoff in parking lot)
3. Stony Point Lake (front and back) including 100, 110, and 120 Stony Point addresses.
4. West Ninth Bus Stop (by Pizza Hut, very near Stony Point Rd.)
5. Back of Finley Community Center
6. Stony Creek Apartments (150 Stony Creek Rd.)
In addition, I had seen runoff at the apartment complex directly across the street from Oliver’s Market, but could not find a safe parking spot to take pictures. The site of each photo is identified with the number corresponding to the location number described above. SITES 3 AND 4 ARE RIGHT ACROSS THE STREET FROM SANTA ROSA’S UTILITIES BUILDING!

Most locations photographed each of the dates we went out were repeat offenders. It is especially telling to note the sign at the City’s main bus stop informing the public about the wastewater project. The sign was probably up less than six months and was already badly damaged from wastewater exposure. Parked cars in front of the Stony Creek Apartments were regularly sprayed and saturated by what I believe is wastewater. Bus stop benches were saturated with wastewater. Furthermore, I included many photos of wastewater going down the street a long way (next to curb) and going down the drainage opening leading into the creek.

Brenda Adelman
(707) 869-0410

Dave Smith, of Merritt Smith Consulting, has worn many hats for the City of Santa Rosa over the last 25 years, including water and wastewater master planning, CEQA compliance, financial analysis, project permitting, water resource planning and operations, watershed assessment, reservoir management, point and nonpoint source discharge effects studies, laboratory and field toxicity effluent toxicity characterization, wildlife risk assessment, and fisheries studies. He has played a central role as instigator of the following changes affecting the Russian River over the years:

After the big spill of 1985 and the big flood of 1986, Dave was part of the team that helped the City upgrade the treatment system to “advanced secondary” in exchange for lowering discharge requirements by the Regional Board. His continual assurances that no environmental harm would result from increased discharges was a tune played throughout all of his contractual work, no matter what evidence was presented to the contrary.

He played a lead role through four major project proposals that focused on greatly increased wastewater discharges into the Russian River, wanting to increase discharges up to 26 million gallons a day, even while the treatment plant was only producing 15 mgd. The 1997 EIR, completed as the three fish species were being listed by the Feds as threatened, was 24 volumes and cost at least $16 million dollars, with a significant amount of that going to Dr. Smith and his firm.

He helped justify elimination of the 1000 cfs flow requirement before winter discharges could commence;

He helped persuade the Regional Board to increase discharge limits for the City from 1% to 5% and sustained compliance measurements 12 miles downstream (Hacienda) until 2006;

He helped fight the listing of phosphorus on the 303(d) list in the Laguna, convincing the State Board rescinding the recommended listing of the Regional Board, but whose decision was then overturned by the EPA in 2002;

He developed fish studies in Santa Rosa Creek “proving” that fish swam through wastewater (ignoring the fact that they mostly migrated through the high flows when dilution was greatest) and concluded, because they spawned, that wastewater discharges caused no harm to the fish;

He helped the City (unsuccessfully) challenge the legality of the ruling by the Regional Board that discharges must have no net increase of nutrients into the creek;

And now Dave is working with Dave Richardson, another long time consultant for the City of Santa Rosa, on the Regional Salt and Nutrient Study required by the State Board in order for the City to continue their Recycled Water Program. Dave has convinced the Regional Board that Santa Rosa’s copper and other pollutant discharges are not a problem for the fish, and will no doubt continue to look for ways to demonstrate that nutrients in Santa Rosa’s wastewater will not exacerbate that impairment in the Laguna. He is fighting for wide mixing zones for wastewater pollutants and we have been informed that he is now attempting to get the Regional Board to eliminate the concept of “incidental runoff” from the City’s new permit coming up the end of this year;

Dr. Dave (as he is frequently called) also played a role in helping to influence the findings of the State Scientific Panel alleging that there is no need for monitoring tertiarily treated wastewater for endocrine disrupting chemicals before irrigation occurs.

The list could go on….

But Dave wears another hat as Managing Director of WateReUse California, and the interview sent around at the beginning of February includes some of the following ideas.

10 Minutes with Dave Smith
This interview began with the following introduction:
“Dave Smith, Ph.D., serves as the managing director of WateReuse California. He recently sat down with Cindy Paulson, senior vice president at Brown and Caldwell, to talk about how the organization has evolved, where it’s headed and the challenges both it and the industry face. This interview is available exclusively to BC Water News readers……”

In Dave’s own words, we quote the following:
WateReuse California has 180 members and about 10 are water or wastewater utilities involved in water recycling, responsible for 85 percent to 90 percent of recycling in the state. We provide legislative and regulatory advocacy and educational opportunities for our members.

Our first priority is groundwater recharge regulations. We break the issues into three major issues — travel time, dilution and treatment technology, essentially relating the first two to the level of treatment. We also want to push forward on the feasibility of direct potable reuse. Finally, we want to initiate a California statutory rewrite process – taking all statutes related to water recycling and consolidating them into one code. In its current form of multiple codes, it is difficult to understand and comply. One suggested reform would redefine recycled water as a resource rather than a waste.

Localized water supply development is key. That 3.5MAF of wastewater is a huge resource just waiting to be tapped. This is why we need reuse regulations that are more flexible to enable a broader array of options.

For those that we can measure, recycled wastewater is not the primary source of this class of contaminants. Treatment technologies are effective in removing endocrine disruptors. Human exposures due to other pathways, like food and inhalation, are orders of magnitude higher than water. Humans are challenged to put risk into perspective. Simple things you do everyday, like taking a receipt from a gas pump, provides much greater exposure.

(Note: We urge you to visit the TEDX website above for instruction as to all the harm evidenced in hundreds of scientific studies regarding exposure to endocrine disruptors. Also, Dr. Smith refers to human harm here, but fails to address the significant harm to wildlife and aquatic life, often far more sensitive to its effects. Water quality, by law, must be protected to serve all life forms.)

Salt and nutrient management planning shouldn’t reside in a recycled water policy. It implies that recycled water is the reason that we need to do such planning, but there are so many other salt and nutrient sources. (Note: wastewater is a major contributor!)

You can draw your own conclusion as to the safety of allowing wastewater to be fully irrigated in the summer time and whether you trust it to be done in a way that will not affect our creeks and streams, summer recreation, the health of all species that call the Russian River home, and more. Santa Rosa will be getting a new discharge permit by the end of the year, and it’s bound to be at least 100 pages of requirements for discharging wastewater. We believe the requirements for “incidental” runoff should be even more stringent for summer discharge because the likelihood of harm is much greater.