RRWPC Comments, October 23, 2016: Feasibility of Developing Uniform Water Recycling Criteria for Direct Potable Reuse

The purpose of this letter is to provide comments on the Report to the Legislature on the Feasibility of Developing Uniform Water Recycling Criteria for Direct Potable Reuse and  recommendations from expert and advisory panels on that topic.  We appreciate the opportunity to comment on this report.

RRWPC Background….Russian River Watershed Protection Committee (RRWPC) is a nonprofit, public benefit corporation founded in 1980.  For about the last eight years, we have been tracking and commenting on the issue of wastewater reuse (specifically regarding tertiary wastewater irrigation) to both your Board and the Regional Water Quality Control Board. During that time, RRWPC has submitted comments and attachments on the Recycled Water Policy and the Policy Amendment, the General Waste Discharge Requirements for Landscape Irrigation Users of Municipal Recycled Water (General Permit), the General Order for Recycled Water Use (2014 and 2016), The North Coast Basin Plan Amendment for Recycled Water Use, etc.  We include via link RRWPC Comments and Attachments on the General Order for Recycled Water Use (2016) for this record: http://www.waterboards.ca.gov/drinking_water/certlic/drinkingwater/comments/general_order/  )

RRWPC represents hundreds of lower Russian River residents, property and business owners, recreationists, etc. who are concerned about water quality and flows, along with clean drinking water, in the lower Russian River, one of the most popular summer vacation destinations of the Bay Area. For years, our area was the recipient of Santa Rosa’s treated wastewater discharges into our river.  For fifteen years we battled this problem and they ultimately built a 40-mile pipeline to take their wastewater to the Geysers steam fields.  This has sensitized our community to the problems of allowing toxic materials into our waterways and we are deeply concerned about DPR.

We are concerned that little is known about the toxic substances in our river and we have always wondered what unregulated remnant toxins enter the river through other wastewater discharges, agricultural and irrigation runoff.  While the SWAMP program has been conducting some tests on river toxicity, we have not seen any results as yet.  The specter of DPR may be enough to drive people to the bottle, the water bottle that is, as some urban water districts promote, “Take it from the tap”.

We are aware that the purpose of these comments is to address the feasibility of developing water recycling criteria for DPR to inform the Legislature, and that it is highly unlikely that DPR would become a reality for Northern California anytime soon. We are nonetheless very concerned about the prospect of having statewide regulations developed at this time for direct potable reuse. While we do not claim to be experts in the field of wastewater technology, especially at its highest level of constituent removal, we do know enough about some of the vulnerabilities and issues connected with this possibility that we wish to have our concerns about public health and background information about endocrine disruption entered into the record.

DPR may be infeasible…..What we do know is that, if done with full consideration of all potential health risks, making the adaptations needed for DPR will be very expensive, may involve higher energy use and potentially increased carbon releases (contrary to current goals to reduce carbon emissions).  As with all infrastructure projects, it will ultimately be subject to human failure (with associated higher risk to the public), natural disaster, deterioration with age, not to mention unknown environmental side effects of the technology that may be difficult and expensive to address. These documents provided far more detail on the technical toxin removal aspects of DPR, but left the critical and complex health risk analyses to some vague future studies.

Our growing concerns about endocrine disruption impacts, sometimes caused by the chemical soup of unregulated chemicals bought together by wastewater treatment processes, motivate us to keep commenting on this issue.  A woman acquaintance from Santa Cruz, Jude Todd PhD, has authorized me to submit her 27-page analysis of the issue, written to address reuse in the Santa Cruz area and attached to this submission.  We share many of the same concerns and I am grateful for her input.

Dr. Todd has comprehensively detailed the issues with wastewater reuse and CECs with specific focus on endocrine disruption. (Attachment #1) She also addresses indirect potable reuse on page 13 of her document, expressing significant concerns about the very limited monitoring of only six constituents out of the many thousand toxins of concern. On page 14 she makes the astute observation that,

Generally speaking, regulatory toxicologists are not on the same page with endocrinologists, developmental biologists, molecular biologists, geneticists, epidemiologists, and other independent scientists who understand how endocrine disruptors and other CECs impact living organisms. As Andrea Gore, editor of Endocrinology, puts it, “There are fundamental differences between regulatory toxicologists and what I refer to as ‘people who understand the endocrine science.’” (qtd. in Brown and Grossman 2015)”.

Although her focus is mostly on wastewater irrigation, the issues Dr. Todd delineates in her paper are every bit as important and relevant to DPR, and perhaps even more so.  She also provides an extensive list of scientific resources that should be of value to your staff and the Legislature.  I urge you to read this important paper.  Can you even consider taking steps to put wastewater into the drinking water supply while ignoring the scientific work of so many experts working in the field of endocrine disruption?

 Need for full disclosure on extent of effort and potential impacts….I’m concerned that Water Board staff and their panels have not defined the extent of the problem of endocrine disruption in the report to the Legislature.   Perhaps the quote immediately above explains why.  In your staff responses to RRWPC comments on the General Order for Recycled Water Use, it states on page 30, “The Science Advisory Panel acknowledged that the science regarding endocrine disrupting chemicals is incomplete, especially regarding mixtures of CECs.”

Rather than acknowledging all the scientific work that has already been done, the Panel mostly ignores the vast amount of research conducted by the many professionals noted above, along with environmental health organizations and publications such as Environmental Health Perspectives, San Francisco Medical Society Journal, Environmental Health News, The Endocrine Society, Environmental Working Group, USGS, and many more noted in our Endocrine Resource List (Attachment #2) in Canada, Europe, and other advanced countries.  While the knowledge in this field continues to evolve, and many more scientific breakthroughs will no doubt occur, it is a travesty to pretend that nothing worthy of note has been accomplished as of this time.  (Our lists could be much longer; resources provided in this letter are the tip of the ice berg.)

Why is there no mention of Dr. John Peterson Myers (Pete Myers), who for 25 years, along with Theo Colborn, Lou Guillette and numerous others, lead the field of endocrine disruption and its effects on human health and wildlife?  Unfortunately, Dr. Colborn died almost two years ago and is greatly missed; but we wonder why has her name or Dr. Myer’s never appeared in any of your documents?  (We attach an obituary of Theo telling of her accomplishments over 25 years (Attachment #3) and a prestigious National Institute of Environmental Health Sciences, (part of NIH) recent award to Dr. Myers (Attachment #4).)

The work of Pete Myers and Theo Colborn resulted in the book, Stolen Future that was published in the mid-90’s.  Subsequently it triggered the release of hundreds of millions of dollars for endocrine research (especially from NIH) which in turn brought forth much of the progress in this field over the years since.  And their names and their work and the studies they generated don’t seem to even be worthy of a mention in any of your documents.  Why is that?  (I again attach my list of references containing these and other quality scientific references. (Attachment #4)

Laura Vandenberg, PhD, who was a lead writer among 12 scientists, including Dr. Colborn and Dr. Myers, had submitted a comment letter on the Recycled Water Policy Amendment stating that there is no safe dose of endocrine disrupting chemicals.  She also emphasized that this is not controversial and that The Endocrine Society, with hundreds of member endocrinologists from around the globe, supports this view completely.  (Attachment #5)  The link to the study, published in March, 2012, and documents about 800 studies on endocrine disruption, is:

The Endocrine Disruption Exchange (TEDX) is Dr. Colborn’s website and contained a concise one-page fact sheet with the important basics on this topic.  I am placing it in the body of this letter because it is so very important to this topic.  (Her website also contains a wealth of information that can be easily understood by most.)

Endocrine Disruption Fact Sheet

The Endocrine Disruption Exchange (TEDX):  www.endocrinedisruption.org     

Nov. 7, 2011

What are endocrine disrupting chemicals?

The endocrine system is involved in every stage of life, including conception, development in the womb and from birth throughout early life, puberty, adulthood and senescence. It does this through control of the other vital systems that orchestrate metabolism, immune function, reproduction, intelligence and behavior, etc.

The endocrine system acts through signaling molecules, including hormones such

as estrogens, androgens, thyroid hormones, and insulin, as well as brain neurotransmitters and immune cytokines (which are also hormones) and other signaling molecules in the body.

How are humans exposed to endocrine disrupting chemicals?

We breathe, eat, drink, and touch EDCs every day. Some can be persistent and remain in the environment for centuries and can build up in the body. Other non-persistent EDCs can be so ubiquitous they are found in nearly every human tested.  EDCs include components of plastics, pesticides, flame retardants, fragrances and more. They are found in our homes, schools and work places, toys, clothing, cosmetics, sunscreens, electronics, furniture, cleaning products, lawn care products, automobiles, building materials, food, and food packaging.

How do endocrine disrupting chemicals affect our health?

A vast body of scientific literature exists on the health impacts of some EDCs, while for others there is very little research. Laboratory studies and human epidemiological studies confirm that EDCs have a wide array of effects on the body. Effects of EDCs have been found in animals at tissue concentrations below those measured in humans. In the US, the cost of treating health conditions for which EDC exposure is implicated is over $1 trillion a year.

What distinguishes EDCs from other chemicals of concern?

Dose: a central feature of endocrine disruption is that effects are found using very low chemical concentrations. Effects of EDCs at very low concentrations can be different from effects of the same chemical at higher concentrations.

Timing: there are many periods of vulnerability during which exposure to EDCs can be particularly harmful. The most well studied critical periods are prenatal and early postnatal development. Effects of early life exposure may not manifest until much later in life. Effects in one generation may be transmitted to future generations through mechanisms involved in programming gene activity, referred to as epigenetic changes.

Endocrine disrupting chemicals (EDCs) interfere with hormone signaling in a variety of ways depending on the chemical and the hormone system. Biomonitoring of chemicals in human blood and urine has shown that 100% of the people tested have EDCs in their bodies. EDCs have been implicated in neurological diseases, reproductive disorders, thyroid dysfunction, immune and metabolic disorders and more. Traditional approaches to determining safe exposure levels (for example, chemical risk assessments) do not work with EDCs. (emphasis added)

The low dose problem……Chemical risk assessment has always assumed that “…the dose makes the poison.” Over-simplifed, high doses are considered bad and low doses generally good and toxic risk levels are expected to correspond.  But all of that is turned on its head with endocrine disruption.  Dr. Pete Myers, along with Wendy Hessler define it well in their article, “Does the dose make the poison?” http://www.ourstolenfuture.org/newscience/lowdose/2007/2007-0525nmdrc.html  They explain that sometimes they see effects at low doses that they don’t see with large and that is counter intuitive to most scientists conducting risk assessments.  The authors express concern that this anomaly sometimes leads to health standards that are too weak.

Dr. Myers explains, “In standard toxicology, as the dose increases, so does the effect. Conversely as dose decreases, so does its impact. This relationship is called a monotonic dose-response curve because effects are either increasing or decreasing…. Non-monotonic curves, in contrast, change direction. Over part of the curve, response increases with dose, while over another portion it decreases as dose increases…. While toxicologists have traditionally assumed that the dose makes the poison, endocrinologists –scientists who study the action of hormones– have long known that hormones can have different effects at different doses.

Marla Cone, Editor in Chief of Environmental Health News explains the low dose effect this way: http://www.environmentalhealthnews.org/ehs/news/2012/low-doses-big-effects  (see article)

With chronic diseases, risk is difficult to define….Can anyone identify specific cases where wastewater is known to have caused a specific cancer incidence or that of any other chronic disease?  The truth is, when it comes to chronic conditions, generally people may suspect a cause, but can seldom definitely and specifically point to the precise time and place an illness was initiated.  And perhaps that is why Public Health Departments focus on pathogenic illness and seldom, if ever, address more mysterious, but common problems.

Dr. Todd quotes Linda Birnbaum, toxicologist in charge of the National Toxicology Program and the National Institute of Environmental Health Services that, “…an ED is anything that affects the synthesis of a hormone, the breakdown of a hormone or how the hormone functions.”  And then she continues…

We used to think it had to bind with a hormone receptor but endocrine disruptors can perturb hormone action at other stages in the process” (qtd. in Borrell 2012, emphasis added). Such perturbations in hormone function can have wide-ranging impacts on our bodies. As the Environmental Working Group, an independent health research organization, explains:  There is no end to the tricks that endocrine disruptors can play on our bodies: increasing production of certain hormones; decreasing production of others; imitating hormones; turning one hormone into another; interfering with hormone signaling; telling cells to die prematurely; competing with essential nutrients; binding to essential hormones; accumulating in organs that produce hormones. (Environmental Working Group 2013)

 Given this list of ways that EDs can stymie our normal bodily functions, we can begin to see how they can precipitate childhood leukemia and other cancers, allergies, asthma and other respiratory problems, genital malformations in baby boys, early puberty in girls, ADHD, diminished IQ, autism, obesity, diabetes, cardio-pulmonary diseases, immune-system dysfunction, and Parkinsonism; evidence is mounting that endocrine disruptors may also play a role in development of Alzheimer’s disease and other mental illnesses.”

Finally, April, 2016 issue of Environmental Health Perspectives, (#6) Linda S. Birnbaum et.al. state in the article, “Informing 21st Century Risk Assessments with 21st-Century Science, “The majority of regulatory frameworks guide risk assessment from the perspective of a single chemical or single component of a project formulation and often do not account for multiple chemical exposures and mixtures.  Furthermore, most chemical risk assessments of potential human health effects rely on testing in animal models using exposures that are typically higher than those experienced by humans.  This testing model requires the assessor to extrapolate to lower doses and across species, and it provides limited consideration of variability within species.  All of these factors undermine confidence that current risk assessments are protective of human health, particularly for the most vulnerable individuals, communities, and life stages.”

 Conservation slipping as reuse grows extensively….With all this, we wish to acknowledge the State’s legitimate concerns about developing adequate water supplies under all scenarios for the entire state.  First and foremost, the emphasis on conservation needs to be continually emphasized.  Unfortunately, many California areas have significantly increased water use in the last year after winter rain eased the drought.  In our area, water contractors are now up to about half way between 2013 use and 2015 conservation accomplishments.  Local contractors are relieved that they can now get more income from water sales and they point to our full three-year reservoir as an adequate supply (Lake Sonoma).

For instance, Sonoma County Water Agency contractors’ water sales in July, August, September of 2015 were 9371.1 acre feet, and in 2016, they were 11,204.6 AF.  This was almost a 20% increase.  In an article entitled ‘Weaker water conservation numbers prompt fears that California is going back to its old bad habits’ author Matt Steven (The Times 10-15-16)  (Attachment #7) states that, “Californians’ water conservation slipped for the third consecutive month in August, prompting new alarm from regulators about whether relaxed water restrictions may be causing residents to revert to old habits as the state enters its sixth year of severe drought.”  Isn’t full time conservation a much cheaper and healthier route to increasing water supplies than encouraging big infrastructure projects that grow old, they fail, and massive pollution results, as is happening now with water pipes leaching lead?

Wouldn’t it be cheaper and healthier in the long run to charge much more for water and build less infrastructure (including wastewater treatment plants)?  Is it possible that users may come to appreciate it more and treat it with more respect?  To constantly advocate for more growth is slow but steady suicide where drinking water is concerned.

While not wanting to explore another issue in greater detail, something must be done about the wanton use of water in many agricultural areas.  It is said that 80% of California’s water is used by agriculture, yet regulations of that use have been minimal or non-existent.  The passage of the new SGMA groundwater law will help, and we hope serious management of our dwindling resource occurs, although we won’t hold our breath.  What good does it do if we have adequate almonds to eat and no clean or even less clean water to drink?  (Calling attention to the crop that it is said uses one gallon per nut to grow.)

Public perception and DPR…The City of Santa Rosa has changed the name of their Water and Wastewater Utilities Department to Water Department, to convey to the public that all water is the same, but the reverse of that famous quote, “A rose by any other name would smell as sweet….”, if true, belies their intention.

Some of the State’s Advisory Committee meeting notes on this issue expressed a big concern about public perception of DPR.  The group spent time focusing on messaging and emphasizing that the wastewater would be purified and totally safe to drink.  Public opinion consultants were hired and surveys were taken regarding public perception of augmenting water supplies with ‘purified’ wastewater.  When those surveyed were told that it was done in other places and that no one got sick from it, they thought it must be okay.  Of course, no one mentioned the difficulties of assessing causes of chronic illnesses and the inability to prove that no one got sick.

It’s unclear how one would really determine the complete safety of drinking water that contains treated wastewater, even when highly treated.  Of course no scientific studies have been conducted to test cause and effect ratios of toxic exposure in relation to human disease, nor will they be.  Reliance on epidemiological studies are the norm where appropriate, but it is unlikely one can be found that replicates the conditions that will be utilized for DPR.  Public health departments have great expertise assessing and controlling pathogens, and many precautions have been effectively imposed to prevent many acute diseases and illnesses.

But when it comes to chronic diseases such as cancer, developmental problems such as autism, neurological and reproductive birth defects, and many other health problems that are associated with exposures to endocrine disrupting chemicals, little is known about the exact pathway of disease in terms of lifestyle, toxic exposure, heredity, etc. that lead to initiation of the condition and/or illness, although more and more studies link toxic exposures to these and many other adverse health conditions.

Unregulated toxins are everywhere; they are in our food, our water, our clothing, our furniture and mattresses, our house cleaning and personal care products, our autos, and much more.  And those that get washed into the waste stream to our treatment plants are a toxic stew of pharmaceuticals, industrial and combustion by-products, heavy metals, pesticides, and more.  But even more than that, not only does a vast array exist in the wastewater collection process, and in our households, but much of it actually accumulates in our bodies, and may or may not trigger a disease process.  You see, we all have different vulnerabilities and our stage in life, and our health history may compound the impacts of various exposures.

Environmental Working Group…Recently an article described how clothing particles …. Organophosphate pesticides and PBDE flame retardants, lead and mercury are all found to be prime examples of neuro-developmentally toxic chemicals according to July, 2016 issue of Environmental Health Perspectives Article, “Project TENDR: Targeting Environmental Neuro-Developmental Risks.  (Attachment #8) The TENDR Consensus Statement”.  The project was a call to address the role of common exposures to toxic substances.  They state, “The TENDR authors agree that widespread exposures to toxic chemicals in our air, water, food, soil, and consumer products can increase the risks for cognitive, behavioral, or social impairment, as well as specific neurodevelopmental disorders such as autism and attention deficit hyperactivity disorder (ADHD).”

Further on it states, “Many toxic chemicals can interfere with healthy brain development, some at extremely low levels of exposure.”  Critical windows of development have been identified up through puberty whereby, “….toxic chemical exposures may cause lasting harm to the brain that interferes with a child’s ability to reach his or her full potential.”

Another issue mentioned was that health studies never look at multiple exposures of toxic substances and in fact, multiple exposures are very common in our everyday life.  We seldom use just one chemical to clean our bathrooms, and in fact, almost everything we do on a daily basis brings together multiple toxic exposures at a time.  All of these chemicals that end up going down the drain must be 100% removed from the waste stream at all times if they are to merge with the drinking water supply, even non-toxic chemicals which can combine to form toxic substances, if you are to assure the safety of drinking water.  Further, it behooves you to assure that all vulnerable populations must be protected before you put the treated wastewater into the drinking water supply.

In the expert panel’s Final Report, they state in their recommendations on page 5 of Executive Summary that the Expert Panel, “…. recommends monitoring the literature on potential health risks that could present serious harm to health over short durations of exposure to compounds likely to be present in recycled water.  Of specific concern are chemicals that adversely affect the development of fetuses and children….This activity could be initiated concurrently with the development of DPR regulations and continued as an ongoing effort.”

It is a serious concern of ours that rather than talking about the extensive existing literature on the issue, as we have tried to demonstrate in our comments, that they are going to set up a committee to look at it.  Why have they not been looking at it before producing this report that substantially fails to define the problem?  How can they begin the process of writing DPR regulations before that occurs?

In any case, this effort gives the impression that the State only has a cursory interest in the topic of the impact of chemicals on public health.  It does not feel like a serious effort that should move forward.  First the information should be gathered, and then the regulations can proceed.  Please prioritize the health of Californians before dumping wastewater in the drinking water supply!

Thank you for the opportunity to address this very serious issue.




  1. Jude Todd, PhD, Statement Regarding Use of Recycled Municipal Wastewater in Santa Cruz, Nov. 18, 2015


  1. RRWPC, List of References on Endocrine Disruption, Fall, 2014


  1. Carol F. Kwiatkowski, et. al., Twenty-five years of Endocrine Disruption Science: Remembering Theo Colborn, Environmental Health Perspectives, DOI: 10.1289/EHP746


  1. Environmental Health News staff report, EHN founder honored as environmental health champ, (re Pete Myers), Oct. 10, 2016


  1. Laura Vandenberg, Comment Letter (to State Water Board)-Amendment to Recycled Water Policy, June 27, 2012


  1. Linda S. Birnbaum, et.al. Informing 21st– Century Risk Assessments with 21st-Century Science, Environmental Health Perspectives, April 2016  DOI:10.1289/ehp.1511135


  1. Matt Stevens, Weaker water conservation numbers prompt fears that California is going back to its old bad habits,  LA Times, Oct. 5, 2016


  1. Deborah Bennett, PhD, et.al., Project TENDR: Targeting Environmental Neuro-Developmental Risks. The TENDR Consensus Statement, Environmental Health Perspectives, July, 2016, DOI:10.1289/EHP358