Summary of Russian River Watershed Pathogen Action Plan, 6/12/2019

Important statements in Action Plan for Russian River Watershed pathogen total Maximum Daily Load (TMDL):   SUMMARY


This Action Plan applies to the entire watershed    (RWRPC comments in smaller font)

  • Summarizes findings relative to assessment of disease causing organisms (pathogens)
  • Describes Program of Implementation intended to:
    • control fecal waste pollution,
    • achieve bacteria water quality objectives
    • water contact recreation (REC-1) is a beneficial use: need to protect public health
  • To accomplish this goal:
    • Action Plan includes Fecal Waste Discharge Prohibition that applies to all surface waters of the Russian River Watershed (overly broad application?)
    • Achieve compliance with prohibition by:
      • Preventing discharge of fecal waste
      • Complying with relevant NPDES Permit, WDRs, or waiver of WDRs,
      • Through Regional Board’s implementation of MOUs and
      • Development & implementation of non-dairy livestock program
    • Geographic area where special provisions of Onsite Wastewater Treatment Systems (OWTS) are limited to those areas identified as impaired, and polluted, based on assessment of ambient water quality data.


REC-1 is a year-round beneficial use of the Russian River Watershed.  Statewide bacteria objectives for the protection of REC-1 are established using E. coli fecal indicator bacteria for freshwater and enterococci fecal indicator bacteria for saline water. (In order to demonstrate pathogens in lower river in summer, they mostly turn to bacteroides to demonstrate need for program.  They also assume the need to protect contact recreation during the worst storms in the dead of winter.)

  • Sub-watershed defined as polluted and impaired if:
    • Data exceeded the statewide bacteria objective for E. coli in fresh water or enterococcus in saline water
    • Data exceeded U.S. EPA criteria for enterococci in fresh water and there was a public health advisory anytime since 2012
    • (most of the lower river is in the impaired area as defined on a map but we have not seen statewide bacteria objective exceeded in summer during those years)


Sources of Fecal Waste (E. coli, enterococci, Bacteroides)

  • Higher in surface waters in wet weather periods (storm water runoff)
  • Indicator bacteria significantly higher in developed areas at all times (sewered & non-sewered)

(But are they exceedances?  No category studied for developed land in forest area which is likely to be much less polluted, especially in summer.  Monte Rio, Guerneville, Villa Grande have pretty dense vegetation)

  • FIB (Fecal indicator bacteria) concentrations correlate with parcel density in areas with OWTS and
  • Higher concentrations of both Bacteroides & E. coli bacteria are associated with periods of high use at beach recreational areas
  • These studies indicate widespread presence of fecal waste sources within the Russian River Watershed
  • Sources of human fecal waste:
    • Treated wastewater to surface water + discharge from holding ponds
    • Untreated sewage from Sanitary Sewer Systems
    • Wastewater from perc ponds & through spray irrigation runoff
    • Runoff from land application of biosolids & storage areas
    • Runoff from water recycling projects
    • Runoff from sites receiving discharges of waste to land
    • OWTS: large & small, commercial and domestic
    • Recreational water use and users
    • Homeless and illegal camping
    • Storm water to MS4s and areas outside MS4 boundaries


Programs of Implementation:


Numeric Targets: TMDL based on statewide E. coli bacteria objective for protection of REC-1 in fresh water and enterococcus in saline water, given as concentrations

  • coli: six-week rolling geometric means (GM) calculated weekly (<100 cfu/100 mL as a GM and <320 cfu/100mL as a STV)
  • Statistical threshold values (STV) not to be exceeded more than 10% of the time, calculated monthly
  • Enterococci: <30 cfu/100 mL as a GM and < 110 cfu/100 mL as a STV
  • There is no seasonal variation of the TMDL required because the TMDL is set at the maximum allowable concentrations of E. coli and enterococci necessary to protect public health during all times of the year.
  • Graph on page 6 showing wasteload & load allocations/ (did not understand- ask for explanation)


Fecal Waste Discharge Prohibition:


Discharges of waste containing fecal waste material from humans or domestic animals to waters of the state within the Russian River Watershed are prohibited.  Compliance with this prohibition can be achieved in the following manner:

  • Implement adequate treatment and best management practices to prevent the discharge of fecal waste material from humans or domestic animals from entering a water of the state either directly or indirectly as a result of storm water runoff.
  • (five other directions that don’t apply to small residential OWTS)


Implementation actions for onsite wastewater treatment systems (OWTS)

  • Section 3.2 of OWTS Policy allows Regional Board to approve individual Local Agency Management Programs (LAMPs) allowing local agencies to provide alternative minimum standards to those specified in the OWTS Policy. These are managed in Sonoma County through Permit Sonoma (formerly PRMD) and were recently approved by the Board of Supervisors for the entire County.
  • Permit Sonoma (the local agency for Sonoma County) reviews development proposals that rely on individual OWTS for domestic waste treatment and disposal. Staff also review permit applications and project plans for OWTS repairs & upgrades and issue repair  permits as necessary in accordance with local policies (as they appear in recently updated OWTS Manual).
  • To ensure compliance with local regulations and technical standards for OWTS, local staff also conduct inspections at the time of OWTS construction and in response to complaints and reports of OWTS failures.
  • For OWTS utilizing supplemental treatment components or enhanced effluent dispersal systems, inspections of the OWTS by County staff and/or a service provider and self-monitoring requirements imposed on OWTS owners.



Advanced Protection Management Program (APMP) for OWTS:

(Fancy wording for OWTS Management of properties in TMDL designated area)


  • Policy established through special requirements in LAMP (described earlier)
  • Ensure that OWTS in the RR (Russian River) Watershed are properly sited, designed, operated, and maintained to provide adequate removal of pathogenic organisms, comply with the Fecal Waste Discharge Prohibition and attain numeric targets, waste load allocations and load allocations.
  • Provide framework for identifying and upgrading existing OWTS that are failing, substandard, or in need of repair and establish minimum inspection requirements to ensure proper operation and maintenance of OWTS within the boundaries of the APMP.
  • Establish minimum requirements for OWTS that are fair, affordable, and implementable, while at the same time, meeting the objectives for the TMDL, which is to return the RR Watershed to consistent compliance with bacterial water quality objectives.


Most of the above language is taken right from their Action Plan (3rd link down):  The Staff Report is over 300 pages but the Action Plan is only 17.  We have summarized key points in Action Plan.  Here are relevant documents:

Basis (Action Plan):

The likelihood that surface water will be adversely impacted by OWTS is increased significantly in areas with a high density of OWTS, particularly those areas with small parcel sizes and where there is a high percentage of existing OWTS that predate adopted local standards for the design and siting of OWTS.

(RRWPC is concerned that studies conducted by the Regional Board did not consider the role of large trees and the forest environment in mitigating discharge of pathogenic waste into the environment, especially in the summer time.  Most of the time, the pathogen identified by the State as the pollutant of concern, E. coli, is not present in excessive amounts in the summer time in fresh water segments of the lower RR.  RRWPC believes that the giant trees absorb most of that waste product accounting for their voluminous and healthy shape.)


The APMP applies to any OWTS located on a parcel that is partially or fully contained within APMP Boundary. Owners of existing, new and replacement OWTS that are located outside the boundaries of the APMP are not subject to its requirements, but must still comply with relevant OWTS requirements, LAMP, etc.

APMP applies to OWTS, defined as individual disposal systems, community collection and disposal systems, and alternative collection and disposal systems that use subsurface disposal and do not include graywater systems.



Geographic Area:

The APMP boundary  is defined as parcels that are at least partially within 600 linear feet from centerline in horizontal map direction on either side of blueline streams depicted on the USGS topographic map and parcels within 200 linear feet of centerline of certain waterways.  (see text for more detailed description)


  • General Operation & Maintenance
    • Maintain system in good working order, including inspections and pumping of solids as necessary or as required in approved LAMP
  • Basic Operational Inspection
    • All owners of OWTS within APMP shall obtain a basic operational inspection of septic tank, effluent dispersal areas and related appurtenances of OWTS by a qualified professional once ever 5 years.
    • Qualified Professional is one licensed or certified by State of CA agency to design OWTS and practice as professionals for other associated reports as allowed under their license or registration.  Can include registered environmental health specialist, professional engineer, geologist, or qualified soil scientist.
    • Potential triggers for inspections:
      • Pumping of septic
      • Property transaction
      • Issuance of building permit
      • In-field performance verification, etc.
    • Inspection should include:
      • Septic Tank & Pump systems
        • Detections of leaks, cracks, excessive corrosion, root intrusion, odors
        • Presence & proper operation of liquid high-level alarm
        • Assessment of liquid levels in relation to tank outlet
        • Evidence of lack of water tightness
        • Evidence of problems in downstream OWTS components, where they have been installed
        • Proper settings & operation of pumping system where installed
      • Effluent Dispersal Area
        • Evidence of odors or surfacing effluent (e.g., excessive vegetation)
        • Evidence of unequal effluent distribution
        • Observations of inspection ports
      • Corrective Action Process
        • Those not meeting requirements may need to contact applicable agency for permit to repair or replace OWTS or possibly take part in a community septic solution. They must also check with Regional Board waste discharge requirements.
      • Regional Board OWTS Assessment Program
        • Program description
          • Objective of assessment is to identify OWTS that are failing and/or in need of corrective action
          • All OWTS within boundaries of APMP shall be assessed by the Regional Water Board to determine whether the OWTS is failing and in need of corrective action.
          • Assessment may include a desktop assessment or local record review (of prior permits), results of a sanitary survey, public survey, questionnaire, or physical site inspection or evaluation.
          • Information used to ascertain performance of OWTS includes system’s age, approved variances, repair history, monitoring and inspection results, septic tank pumping records, maintenance records, peak hydraulic loading, and record of complaints received.
          • Site assessments must be done by qualified professional.
        • Assessment Program Implementation
          • Regional Board will notify each property owner of the need to submit this assessment information. (The County has property owner lists.) Notification will describe required information and submission

due date.

  • Supplemental Treatment Requirements: This is a section dealing with requirements in specific situations involving repair and replacement of an existing OWTS. See page 12 of the Action Plan.  It also addresses New OWTS when they are 600’ from the top of the bank of protected streams.  Finally it also address situations with seepage pits. There are also several useful definitions on the bottom half of that page.  Table 3 on page 13 gives Minimum conditions for an Exception to Supplemental Treatment Requirements.
  • Planning for community-based OWTS
    • This is an option that allows for a community-based OWTS Management Plan or Onsite Wastewater Authority. The Action Plan makes it clear that the Regional Board Staff would help with this approach, but they would not develop it themselves.  There would have to be an authorized governmental entity willing to take it on.


  • This will be conducted to provide effectiveness of the Action Plan including attainment of bacteria objectives and protection of beneficial uses. The document lists different types of studies that might be required.  They will focus on parcels of high density (not sure how they define that).  The Plan is not clear whether the property owner or the agency will be responsible for the monitoring.


  • For OWTS, the Action Plan established an APMP, which includes an assessment of the adequacy of existing OWTS
  • The requirements under which OWTS in need of major repair or replacement can be upgraded to return them to proper function
  • A requirement that all OWTS with the APMP boundary obtain a basic inspection every 5 years to ensure that the OWTS is functioning as designed and to identify OWTS that are in need of correction action.
  • The Regional Water Board anticipate full attainment of the bacteria water quality objective in 20 years form the effective date of this Action Plan.

Table 4: Implementation Actions for Source Categories– Load/Wasteload Allocation = zero

  • There are two tables (4 & 5) but they look the same. Categories for both include: Fecal Waste Source Category, Implementing Parties (Source) and Implementation Actions & Compliance Dates
  • Here are two examples:
    • (computer has messed up bullet system…please ignore)
    • #1: Existing, new and replacement Onsite Wastewater Treatment Systems (OWTS)

By owners

  • Implementation actions include:
    • At least every 5 years from effective date of TMDL Action Plan (about a year from now), obtain required inspections and reports nad submit to Regional Board Executive Officer, the results of inspections, corrective actions, and other required information
    • No later than 5 years after the effective date of Action Plan, submit information about individual OWTS as required by Regional Board and local management agency.
    • No later that 15 years after effective date of Action Plan, complete all corrective actions required by Regional Board and local agency to comply with Action Plan. This date may be extended to 20 years for OWTS owners participating in planning and construction of community-based wastewater treatment and disposal systems.
  • #2: Recreational Water uses and users
    • Implementation actions include:
      • In accordance with MOU, Sonoma County and CDC, and Regional Board will work with local entities and private parties along RR to address water quality impacts relative to recreational water uses, and to promote the installation and location of sanitary facilities along the Russian River for use by those recreating.