RRWPC Letter to State Water Board, February 16, 2015

Concerning ITEM # 9: Feb. 17, 2015 Agenda

I am writing on behalf of Russian River Watershed Protection Committee (RRWPC).  As you may recall we have submitted numerous past comments on Recycled Water Policy and Amendment and related actions by both your board and the North Coast Regional Board with especial concern regarding endocrine disruption.  We are sorry to enter these so late, but we have been dealing with several deadlines in the last two weeks along with a death in the family, and hope you will find time to look this over before the item is covered tomorrow afternoon.  We will try to keep comments brief and to the point.

Most of our comments are in response to the staff document entitled: RECYCLED WATER RESEARCH NEEDS UPDATE including agenda and write ups of the workshop that took place to address that topic.  In looking at the attendance list, I did not notice anyone from the north coast region.  Was that intentional or an oversight?  Since this is a topic the North Coast Regional Board is concerned about and who will be working with the San Francisco Estuary Institute on toxicity studies, I would hope any future meetings on the topic would include scientists from our region as well.

LOW DOSE EFFECTS DEARTH OF INFORMATION:  I would first like to point out that there has been a dearth of information on low dose impacts of endocrine disrupting toxic chemicals considered by your Scientific Panel on CEC’s and your staff, from what I can tell.  While the phrase, ‘more needs to be researched and studied about CEC’s’ is often included, there is NEVER any specific reference to what IS known on the topic, as far as I can tell.  I have put together a sample list of referrals that I implore your Panel and staff to consider.  I call special attention to the CHEMTrust item on the second page referring to Overview of Key Scientific Statements on Endocrine Disrupting Chemicals 1991-2013.  This includes many statements by scientific groups worldwide agreeing with the low dose effect described in many of the documents.  Several of the listed documents provide hundreds of references to studies that have been conducted by these scientists and that I believe have all or mostly been peer reviewed.  Yet I have seen almost nothing in State Board documents about this phenomenon.  We also highly recommend you address studies in Vandenberg, L.N., et al., Hormones and endocrine disrupting chemicals: low dose effects and non-monotonic dose responses listed in our references.

UNTESTED AND UNREGULATED TOXINS:  I also provide you with an article downloaded just today on the fact that many toxins on the market have not been tested in the US, even while banned in Europe.  And yet,  the document put together by staff for the Workshop with the goal of identifying the greatest research need around reuse seems to prefer focus on public acceptance of these practices.  Direct potable reuse, with no barriers in place was of particular concern to many of the workshop participants.  By a 2-1 margin, participants felt that assessment of chemical risks needed more research attention than study of microbes.  We fully concur with this assessment since almost nothing has been done on the latter.

SURROGATES: We have significant concerns about surrogates selection needing to be representative of the wide range of chemicals with low dose effects TO BOTH HUMANS AND AQUATIC LIFE.  Please see Linda Sheehan’s comments to the State Board in letter submitted on  July 3, 2012.  We do not have expertise to make surrogate recommendations, but urge staff to consider and address low dose issues raised in references we provide here.  At the very least, surrogates should be representative and adequate.  This document focuses way too much on human health and says only a little regarding environmental health including need for phosphorus removal and adequate protection

MULTIPLE BARRIER VS PUBLIC ACCEPTANCE:  Under no circumstances should multiple barriers for direct potable reuse (DPR) be diminished or traded in exchange and/or in place of public acceptance and the public relations necessary to bring about acceptance of DPR.  Furthermore, people need to be apprised of the risks of increased discharges of RO Concentrate into ocean.  There is more and more information coming out about the harm coming about in the ocean as a result of human use and abuse.  Many of the unregulated toxins we are concerns about are concentrated in the sludge (concentrate) remains from highest treatment technologies.    Also, Phosphorus removal is just as important as denitrification,  (latter mentioned on page 12 under facility design) but doesn’t seem to be considered.

IRRIGATION WITH TERTIARY WASTEWATER:  Risks not considered at all, although if low dose exposure risks were considered, it would need to be.

NEED FOR NEW OR ALTERNATIVE RISK ASSESSMENT ANALYSIS:  Conventional risk assessment doesn’t address low dose exposure impacts on pregnant women, especially in regard to developmental harm to fetus.  This circumstance needs to be addressed (excellent resource is TEDX website on reference list).


CONSIDERATION OF DROUGHT:  It appears as though drought impacts are not considered. (Perhaps this condition is alluded to in the text in regard to computer models and I may have missed the intent.) When drought occurs, conservation is stepped up considerably and there is less wastewater available to use for reuse.  How will this water balance (or lack of it) be addressed?  Also, it seems as though greatly stepped up conservation is far more cost effective that construction of extensive and expensive infrastructure to utilize the wastewater that might not be there.

PARTIAL SUPPORT FOR IDENTIFIED PRIORITIES: RRWPC supports priorities as listed here (pg. 14) but feels they do not go far enough.  There needs to be a full identification and ranking of those chemicals with the more dire impacts to humans and wildlife in highly sensitive circumstances such as pregnancy, childhood, compromised immune systems, old age, etc.

ANTI DEGRADATION: if low flow and higher concentrations of toxins creates a degraded condition in waterways, how can requirements of Anti-Deg be fulfilled?  It seems like an impossible task.  Language is included that seems to hint that engineering solutions would be available, but we wonder what those might be under the circumstances?  What is meant by an ‘integrated framework’ (pg. 14) for considering all Beneficial Uses?

Goals mentioned on page 15 are barely the tip of the iceberg and far more sophisticated analysis of the problem is needed.  We suggest that a group such as Collaborative on Health and the Environment (CHE) out of Bolinas be consulted about getting involved in workshops on the topic of endocrine disruption with appropriate health professionals, water experts, educated citizens, etc.  Also, San Francisco Medical Society has published a lot of information on the topic in their monthly journal.  Recently we heard a discussion on toxins and ocean health.  They have a broad range of knowledge represented in their organizations.  Also the San Francisco Bay Institute and the Bodega Marine Lab have many scientists knowledgeable about these issues who might want to be involved in workshops dealing with these issues.

We agree that there is a need to change the entire paradigm of recycled water issues and how they are communicated.  Our only concern is that some may be thinking about a disingenuous public relations campaign that only tells part of the story.  The truth is that toxins are everywhere and we don’t have a handle on what to do about them without causing dire and profound human health and environmental impacts.  Furthermore, massive die offs of species is occurring and we don’t have a handle on what is causing this; we don’t know the role unregulated toxins that pervade our daily lives are doing harm to many species and to our environment and to our own relevance as a species.