RRWPC Complaints to North Coast Water Quality Control Board, 6/3/19

RRWPC Complaints to North Coast Water Quality Control Board

Regarding (#1):  Four day manhole surge in Russian River County Sanitation District on Orchard Ave. near Vacation Beach Pump Station and repetitive nature of this spill and also surging manhole on Riverside Ave. next to Main Pump Station

(Note: Attachments to this complaint do not include documents sent between SCWA and Regional Board, or where copies were sent to both agencies from a third party, but I can make them available if requested.)

Regarding (#2):  RRCSD’s illegal 7-day discharge of tertiary wastewater (5-20-19 to 5-27-19) during ‘no discharge’ season

Introduction:  The very essence of the regulatory and enforcement mandates of the North Coast Regional Water Board is to protect our water resources for all beneficial uses.  Great lengths are necessary to maintain fishable, swimable, and drinkable water resources while also protecting aquatic life and the natural environment within our watersheds.  If one were to ignore and/or excuse violations or simply throw up one’s hands in frustration in the face of powerful natural forces, it would not be compatible with this mission or according to law.  Neither should the focus be exclusively on punitive measures, but rather taking effective steps to prevent future manhole overflows should be the ultimate goal.

We submit this combined complaint knowing that we may not have all facts necessary for those of you who must decide on whether to take enforcement action against the Sonoma County Water Agency as managers of the Russian River County Sanitation District (RRCSD) for what appears to be a four-day surging manhole of raw sewage, of taking too many days to clean up the toxic mess it left for neighbors to be exposed to, of allowing repeated episodes to occur every time there is a major flood in approximately the last ten years, and in general, not managing the system in a way that addresses some critical failings.  We have no desire to chastise any one individual however; we are aware of the complex task our very difficult system presents, and the somewhat extraordinary circumstances in which overflows occurred, but we believe that more needs to be done to address these issues.  We hope this challenge will result in a detailed analysis of why these events keep occurring and what can be done to stop and/or mitigate them.

Furthermore, we are very concerned that the Regional Board, in conjunction with the County of Sonoma and Sonoma County Water Agency,  may have intentions to hook Monte Rio and Villa Grande to the RRCSD.  We have seen evidence leading us to conclude that such hookups are being seriously considered.

We maintain that this should not be contemplated before all problems (including those of the collection system) within the RRCSD are fully addressed.  This should also include analysis of and provisions for the anticipated impacts of climate change.

In addition to these concerns, we recently learned that a six-plus day wastewater discharge at RRCSD was quietly occurring (May 20th  at 4:00 PM to May 27th at 8:43 AM) after May 14th, a  date when discharge prohibitions are in place.  Claiming that the ponds were almost full and wet weather still in the forecast (Actually, almost no rain occurred after the 20th and we wonder who was forecasting it?), and the ground too saturated for irrigation (true), the District gave notice that discharge would begin at 1600 hours on May 20th.  While it had rained May 19th (part of the reported 3” of rain at the Treatment Plant), there has been almost no rain since then and we’re not sure significant wet weather was in the forecast when discharge commenced.  We will have some further thoughts about how this might be addressed.

Additionally, we believe unusual weather events this year may be part of the global warming crisis that is more frequently occurring in real time.  We request that staff address this issue as it might affect RRCSD, and require appropriate planning (in revised discharge permit) for expected extreme events.  We ask that the revised permit provide contingencies and a rigorous prioritized plan for dealing with these emergencies.

Finally, we would like to restate the following discharge prohibitions in the District’s NPDES Permit:

III.E. 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.  (The Vacation Beach SSO falls within the definition of “nuisance”)

The permit also states,

The discharge of treated wastewater form the Facility to the Russian River or its tributaries is prohibited during the period May 15 through September 30 of each year.”

And the proposed Action Plan for Russian River TMDL states on page 7, “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: (2) Comply with all fecal waste/pathogen-related provisions of an applicable NPDES permit.”   This language couldn’t be more clear!  These requirements were violated in both the SSO spill at Vacation Beach and the illegal discharge of treated wastewater after May 14th.  We request that Regional Board officials require that the problems be fully addressed and penalties levied to prevent reoccurrence.

Our goal in all this is to hopefully instigate changes that prevent these incidents from occurring in the future.  So far, the only change suggested to prevent raw sewage from surging up through manhole on Orchard Ave. (that we are aware of) was to devise a way to redirect fecal material towards the river so it won’t infiltrate neighbors’ yards.  When we met on site, Mike Thompson suggested an approach to send sewage sludge away from houses and toward the river.  We interpreted this to mean that he has no solution for the surging manhole whenever the river comes up.  This is very troubling.  On top of providing requirements to analyze constituents (at least priority and conventional pollutants in the soil in front of Esa’s and nearby houses, and have toxic soil removed,  (and similarly for the Children’s Park next to pump station where her daughter loves to play), the revised permit should address this situation. (Shouldn’t managers of the system be responsible for all cleanup needed as a result of manhole surges? To do anything else is to effectively undermine current and/or future bacterial standards.  I am sure that raw sewage can be counted on to contain pathogens, and permanent measures must be taken to stop it from regularly surging out of manholes.)

Detailed basis of the complaint (manhole surges):

Esa’s Timeline:  Esa Parr Day contacted me via email for the first time regarding a surging manhole right near her house on March 6, 2019.  Esa and I had known each other casually for quite a long time, since her father had been on RRWPC’s Board of Directors for many years, but we were not in regular contact up to this point.  After the initial email, we had a series of emails back and forth that included details of the spill, pictures, contacts she had made looking for help, etc.  She eventually developed a time line which we include with this document. (Attachment #  )

Facts of situation per Esa’s Timeline: (Attachment #1)

Esa was a firsthand witness to the following:

Tuesday, February 26th:

  • On Tuesday, February 26th, at approximately 1:00 PM, Esa saw raw sewage flowing from a manhole located on Orchard Ave. at Beach St. Sonoma County Water Agency (SCWA) had already been to the site and set up a 8½” x 11” sign that read “Raw Sewage May be Present”, several orange cones, and a line of sandbags set up to divert the raw sewage toward homes and into Isa’s next door neighbor’s private drain for his back yard, which drains into all 3 backyards behind their homes.
  • At 3:34 PM she received a Mandatory Evacuation text from SOCOPSA ORG. In the following hours, the river rose and surrounded her home. (At 8:00 PM the river was approximately 34’.)  She rushed to prepare for the event, as her personal circumstances required that their family wait out the flood in their house.

Wednesday, February 27th:

  • On Wednesday, February 27th, at 3:00 AM the river rose into the second floor of Esa’s home. The river was at approximately 41.5’ at that point.  The river kept rising all day and hit its peak around 10:00 PM when it crested at 45.38’

Thursday, February 28, 2019:

  • On Thursday, February 28, 2019, the river had flooded the entire neighborhood. (At 8:00 AM it was down to about 43’.)  That evening around 8:00 PM it went down to flood stage at 32.4’.

Friday, March 1, 2019:

  • On Friday morning around 8:00 AM, March 1, 2019, the river receded to about 25’ and Esa and her family were able to see the ground and street again. When they walked out on the street, they again saw raw sewage flowing from the manhole and the road was covered in sewage sludge mud. Esa took pictures of the sludge filled road (see timeline document).  She was surprised to see that the raw sewage was still overflowing  and the thick layer of greasy mud was all over the street around the manhole.
  • The access road to their home, Neeley Rd. was open that afternoon and a woman from PRMD who works with the Well and Septic Department, came to their neighborhood. Esa and her husband spoke with the woman about the raw sewage flowing in the street.  The woman said she would report it when she gets back to the office.
  • See Timeline for pictures of event as it occurred on her street. (pictures have dates)
  • As Esa started to clean up around 3:00 PM, she noticed SCWA’s cones in her yard. Apparently SCWA had already been out and had put up new cones and signage at the sewer overflow area and left the old ones in her yard.
  • Later that afternoon, Esa’s neighbor, Nick Shebal posted photos on Facebook and included his own description of the incident and asking Lynda Hopkins for cleanup help. Lynda told him that the  Water Agency is on it and will send crews to clean it up.  (We have many pictures with dates taken by Nick that we will include.) Attachment #2

Saturday, March 2, 2019:

  • On Saturday, March 2, 2019, on her way to work, Esa stopped to take a photo of the street. Again she saw raw sewage still flowing from the manhole, toward the drain and over the  sewage covered street upon which her car tires drive.
  • Another neighbor posted a comment on Facebook and picture that showed a man digging around the manhole. He thought that person was cleaning things up, but later posted that no one showed up to do it.  I surmise that the man at the manhole was doing something else.  Esa says there are more correspondence and pictures posted on Facebook.  (I think it’s included among Nick’s photos that Esa sent me and attached here.)

Tuesday, March 5, 2019:

  • Esa reports that sandbags and signage had been removed but street was not cleaned. It had been raining for days so that made it a sewage muck/sludge mess that cars drove through many times.
  • Esa said her neighbor had feces in his garage. No clean up at site by SCWA as yet.  Esa called SCWA and was connected to Barry Dugan, who said he thought it had been cleaned up already.  Barry said he would have to talk to more people in order to get it done.  Esa sent copy of email with pictures and a message to Lynda Hopkins also.
  • My notes about this date based on Esa’s emails to me:
  • Esa sent email to Barry Dugan on 3-5-19 around 10 PM with cc to Lynda and mentions a phone conversation with him earlier in the day. (Attachment #3 )
  • She states that one photo was taken Sat. 3-2 after flood receded below flood stage. 2nd photo of same location following day, March 3rd, still covered in sewage. (2 photos sent: Attachment #4) Sewage was still overflowing manhole at this point and sludge still covering street.  Esa asks to have street cleaned up and sanitized immediately.  Esa alludes to prior spills over last few years during high flows when river comes near street (2006, 2014, 2017)  This time was much worse and raw sewage got into homes.  River water was flowing over sewage coming from pipe. Sign stating ‘raw sewage may be present’ was up on barrier (picture taken 3-2: attachment #4)

Wednesday, March 6, 2019:

  • Esa called County Health Department at approximately 8:00 AM. They told her they only handled restaurants and told her to call PRMD.  Esa again called Barry about cleanup.
  • My notes written on this date as follows (based on emails with Esa):

Esa called Public Health on Mar. 6th  and they told her to call PRMD. PRMD does not deal with central sewer issues.  Public Health should have made calls to SCWA if they could not handle it themselves.  Esa was trying to get help and didn’t know who to call for health report, clean up, enforcement.

  • I sent email to Charles Reed at Regional Board late Wednesday alerting him to spill and sending Esa’s message and pictures. (I had sent message to Patti Corsi at Regional Board about this earlier in the day.  I asked whether SCWA had been notified?  I had gotten message from Patti the morning of March 6th saying she had forwarded my message to Charles that morning.)  Also, I sent email to Esa on 3-6 telling her I forwarded her message to Charles Reed and suggested she call him (included his phone number)
  • Esa responded to me on 3-6 in evening: She said she would contact Charles the next day.  She stated that the spill lasted from Tuesday  afternoon before flood (26th) to Saturday after flood receded (March 2nd).  (If you need any of these emails referred to, we can send.  Patti, Lynda, and Charles should have then however.

Thursday, March 7, 2019:

  • The street still had not been cleaned. (Keep in mind that this is raw sewage.  Esa didn’t contact me until March 6, 2019, and she didn’t know who to call for this help.  In the meantime, she had to keep three children in the house, for fear they would have contact with disease causing waste.

Sunday, March 10, 2019:

  • Charles responded to me the morning of March 10th with the following:

I’m working on an email to you and Esa re SCWA that will include SCWA’s 5-day noncompliance report. However, SCWA’s 5-day report does not contain any information about the SSO. That will be in their 45-day report per the Sanitary Sewer GWDR. Nevertheless, I have some email information on the SSO that I will share in the email.

  • As of Saturday March 16th I had not heard back. (We eventually got the 45 day report.)

Tuesday, March 12, 2019:

  • Esa and friend met with Barry Dugan and David Royall (SCWA staff) at 2:30 PM on this date for over an hour. They discussed protocol, notification, and prevention of raw sewage onto Orchard Ave.  Esa showed them where raw sewage had been diverted toward homes into private drain which empties into Esa’s backyard.
  • After looking in Press Democrat, I didn’t see anything about surging manholes (another surge was taking place at the Main Pump Station but the only information we have on that is the 45 day report. We assume it was a similar situation to the Vacation Beach one.)
  • At one point early on, SCWA staff took samples for total and fecal coliform only. Don’t recall ever seeing a written report but later found out that the results were equal to or greater than 1600 mg/L, which means that levels were probably far greater than 1600 mg/L.


Other subsequent efforts to get information and inspire response to problem…

Meetings and conversations with officials:  (Most of this was a repeat of the information in this complaint.)

  • See entries in daily rundowns through March 12th
  • March 19th:

I met with Cathy Goodwin at Regional Board to look at RRCSD’s SSO Reports (2 hours)

  • April 15th:

I met with Matt and Cathy Goodwin regarding RRCSD spills (1.5 hours)

  • April 16th:

Esa and I met with Mike Thompson and Pam Jeane regarding RRCSD at SCWA offices (2 hours)

  • April 18th:

North Coast Regional Board Meeting: Esa and I attended meeting and gave presentations to Board during Public Appearances.  Board was very interested and had comments and questions. Then we were out in hallway for about a half hour talking to staff about what happened.

  • April 25th:

Esa, Denny O’Leary, Mike Thompson, Lynda Hopkins, and myself met at the Vacation Beach Pump Station and the kid’s park on Orchard (2 hours) to discuss situation and potential remedies on site.  Esa led discussion and spoke of many concerns

May 18th

Esa and I attended RRCSD Tour of the Treatment Plant (2.5 hours)


RRWPC Letter (3-22-19) to: Matt St. John, Charles Reed, Cathleen Goodwin, Lynda Hopkins, Grant Davis, Michael Thompson, Barry Dugan, Bob Coey, Eric Larson, Senator Mike McGuire, Sonoma County Water Coalition

This letter described the surging manhole situation at Vacation Beach from Esa’s perspective and her attempts to bring attention to the situation.   SCWA had put out a warning barricade and a sign so small that you would have to walk in raw sewage to read it.  Sandbags were installed (to block half of the street), but it directed sewage to a drain that led to back yards of nearby properties.  It took SCWA a week from the time it was reported, to come and clean the raw sewage from the street.  All along I have kept requesting specific information on the underlying causes of the problem and am still asking what is needed to fix this problem?  The letter implied that nothing can be done as conveyed in the sentence, “….maintenance crews prepared for possible overflows from a manhole on Orchard Avenue, which because of its lower elevation is known to overflow during floods.”  In no way are we critical of work crews.  We know they worked as hard as they could during the flood.  We believe the assumption that nothing could be done needs to be changed to, what can be done to fix the problem for the future? 


Esa brought up many ideas about informing the community on how to stay safe (other than to just evacuate, which Esa could not do).  She was upset that information was almost totally lacking.  We both threw out ideas that could improve the situation and officials said they would consider it, but we haven’t heard much yet.  We are still in the reporting stage.


Response letter from Grant Davis, General Manager noted that his staff would review everything that happened and would come up with ideas to improve the situation.  We believe that the Regional Board should figure out what can be done to prevent raw sewage from spreading over a neighborhood during floods and into the river and on private property.  Since this is illegal, then it should be enforced.  (All communications about this event failed to provide suggestions about how spills could be prevented in the future.)


SCWA’s April 15 2019: Technical Report for Category 1 Spill ID 856715:  Summary

Technical Report (45 Day Report) from the start states that SSO was discovered at Manhole 6-1 overflowing near 17821 Orchard Ave. in Guerneville, CA by RRCSD staff during routine inspection on February 26, 2019 and determined that manhole 6-1 began overflowing on that day.  Esa Day, who lives in close proximity to the manhole and has to drive by it to get to her house, noticed the spill at 1:00 PM on that date as she drove to her house.  This is contradicted by the claim in other parts of the report that the spill lasted two days (March 1st and March 2nd), and not four days (see below).  It is also in opposition to the Report’s own initial statement quoted above.


Total volume spilled was estimated at 348,000 gallons by RRCSD staff (in report).  They stated that there were fluctuations in flow over duration of overflow.  Staff claimed they monitored overflow through rain event until it was unsafe due to flooding, which probably would have been around early morning of February 27th.  Staff next observed the manhole on March 1, 2019.  They state that all work was complete by 6:30 on March 2, 2019, after surcharge ceased.  Esa had noted that surcharge was still going on in morning and stopped around mid-day of March 2nd.   


Also, residents asked to have the silt tested.  Grant Davis’s letter to me on 4-8-19 (also sent to three staff of Regional Board) said the total and fecal coliform levels upstream and downstream were all similar but the highest was upstream of the manhole.  But the 45 day report giving water sample results for tests taken on March 1st, indicate that all readings (upstream, site, downstream) were all the same for total coliform (>1600).  For fecal coliform the result was 540 MPN/100mL upstream, >1600 at spill source (manhole), and 920 MPN/100mL downstream.  Since much of the pollutant at the manhole was ending up on nearby properties, that might explain why it was not higher.  SCWA draws the conclusion from these results, “…Similar to the silt samples, the results indicated that there were high levels of total coliform and fecal coliform in all of these water samples.  Both the silt and water sample lab results were consistent with the widely acknowledged understanding that floodwaters contain numerous potentially harmful constituents from a variety of sources throughout the watershed.”  Should we interpret this to mean that because the flood water was dirty, it was okay to allow the spread of feces all over nearby private property and into the river?  I think not! (See discharge prohibitions on page 2 above.)


SCWA’s narrative states that workmen cleaned the street “…several days after water receded and cleaned about 100’.”   Esa said it was March 8th that cleanup crew and truck finally came, which was many days after she requested help (March 1st).  She had to drive through and live with the sludge in front of her house, exposing her family to unknown amount of pathogenic material before they sent the vacuum truck and pressure hose.  We don’t know if they hosed sludge into the river (Beach St. goes down to the river and is about one house from the manhole.  To clean the street meant they may have flushed the toxins either into the playground, the private properties, or the road to the river.) or whether the vacuum was able to absorb all the fecal matter into the truck.  SCWA claims they followed all OERP procedures, but I believe that the procedures may have been inadequate and possibly inappropriate for this situation.  It would be preferred if Regional Board staff could look into about this.  We also don’t know if they cleaned a large enough area since the sandbags directed the sludge into the backyards. Esa requested that SCWA clean her front yard but they wouldn’t.


The report refers to this as a natural disaster.  But this disaster has happened many times over the years.  The February 27th flood was only the 6th worst in recorded history.  It was actually the second flood this February, although he first one was about ten feet lower.  In both the letter to RRWPC from Grant Davis, and in this 45 day report, SCWA claims they have spent a lot of money up-grading the system with capital improvements.  We have not examined the use of the money they collect and whether there are more efficiencies that could have been realized, but the system has many problems that need attention.  They said they spent $21M in 15 years on capital improvements AND required maintenance (average about $1.3 million a year), but that tells us nothing about whether they could have been more prepared for such a flood, especially since such events may come more frequently with climate change.  We may be looking at the new normal and need to get ready for that.  They should be required to investigate ways to cut I&I into the Treatment Plant to far less than the 22% reported (in Report of Waste Discharge: October 2018))


Additional comments on Technical (45 Day) Report:

  • Their report looks at total and fecal Coliform but not E.coli. The >1600  MPN/100mL reading comes up in both upstream and downstream measurements, making it impossible to discern the coliform impact from the spill.  It would have helped to have E. coli readings as well.  Can that be required in the future?
  • The chart midway through the report claims the initial report of overflow, and the time they claim it started, was on 3-1-19 at 5:00 (AM?). They report flow stopped on 3-2-19 at 8:30 (AM?).  Yet in their 45 day Technical Report they state on the first page that Manhole 6-1 began surging the morning of February 26th.
  • Then on the CIWQS Report (within the Technical Report) they state that the surging manhole went on for two days estimated at 168,000 gallons per day with a total of 336,000 total with none recovered. They repeat this estimate on lines #17 and #20.  But Esa saw the manhole surging at 1:00 PM on 2-26-19 which means it was probably flowing for 4 days which would mean discharge amount may have been 672,000 gallons.  Can this be checked?
  • Line #31 claims cleanup was completed by 3-3-19, but Esa and her neighbor stated that their vacuum truck didn’t come until 3-8-19.
  • While they did post signs, they were so small and hard to read (see photos) that one would have to walk in feces to read it.
  • We believe there should be monitoring for toxic constituents and other pathogens than for total and fecal coliform only. They claim that the sludge mixed with flood water which was toxic in itself and imply it’s not their responsibility.
  • It’s not that RRCSD should be responsible for everything, but prohibitions are in their discharge permit and estimates should be made to attribute the extent of their responsibility. RRCSD also needs to figure out how to stop surging manholes, because it happens during much lower floods as well (Manhole at River Dr. near Main Pump Station surged during both floods.)  Repetitive events at both of these locations need to be examined in detail and mitigated to the extent possible.


Technical Reports for two spills at Main Pump Station on Riverside Dr.

  • This spill occurred at Manhole 17-22 on Riverside Dr. on February 14, 2019 (in Guerneville). It was observed by staff at approximately 5:38 that day. The report claims it was a result of extreme wet weather.  The amount of spill was 200,664 gallons. The river crested at 34.8’ the next day, with flood stage at 32’.  The rain amount between Feb. 12th and Feb. 16th was estimated to be 6.7” rain in Cloverdale and approximately 5.9” in Guerneville.  We looked up Santa Rosa’s rainfall for those dates and it was approximately 4.66”.  In any case, this was considered a very minor flood by Guerneville standards.  We believe that the Vacation Beach manhole described earlier did not surge in this early flood.  The report claims the Riverside area was inundated.  We don’t have a way of verifying that, but it does seem that the report description may be inflated.  The overflow ceased the next day (another indicator that the situation was not nearly as serious as the Orchard Ave. spill.)  They state that cleanup and all work connected with the spill was over by 10:00 on February 16th.  All fecal coliform samples taken on 2-14-19 came in at >1600 MPN/mL.
  • The second spill occurred at same location and was first noticed on February 26th at approximately 11:00 and lasted until Friday morning, March 1, 2019. Total overflow was estimated at 483,000 gallons.  None of the wastewater was recovered.  (This was not treated, it was raw sewage.)  The report was virtually the same as for the Vacation Beach Report.  They state that all procedures were properly followed.
  • RRWPC assumes these are honest reports, but all of the concerns we expressed for the Vacation Beach event can apply here. We won’t repeat other than to ask how many overflows have occurred at this location over the last ten years?  Whatever the number is, they should not continue.

Documents in Regional Board files on SSOs (RRCSD only):

  • RRWPC also went through the SSO file at the Regional Board. We had a lot of difficulty downloading documents and Cathy Goodwin was kind enough to help us.  Even so, we are not sure if we got everything we needed and there were a lot of duplicates we only noticed when we got home.  There was a lot of email discussion between various SCWA and Regional Board staff about the need for new Force Main pipeline.  They were going to hire a consultant to examine the condition of the pipe but then just decided they would replace the pipe because it was old and assumed deteriorated. To our knowledge the project has neither been funded or planned or placed in the CIP list for the next five years.  We wonder why not?


  • In a 12-24-14 email from Mike Thompson to Cathy Goodwin, he states: “The collection system and treatment plant performed well during the December 11th Coordinated efforts between the Water Agency’s operations and maintenance divisions included  shutting off valves to laterals serving low lying properties, operating lift stations manually, and on-site monitoring of water levels in manholes.  As a result of these efforts, there were no overflows from the collection system.” (goes on to mention that TP treated almost 3 mgd on peak day)  How does this compare to actions of Treatment Plant staff before big February flood?  If they implemented same actions, why was it less effective?


  • Another email was from 1-9-17 and indicated there was a similar issue at Vacation Beach where they also posted warnings; the manhole was under water that time also. One day later, Cathy reports that a decision had been made to hold water in the collection system to avoid overwhelming the plant….  He (Garett?) went on to indicate that this would mean that raw sewage would be escaping at other points in the collection system beside Vacation Beach.  (I believe surging manhole was also reported at Main Pump Station that year as well.)  I recall Garett Walker saying the same thing at the Tour of the Treatment Plant May 18, 2019.


  • On Feb. 12, 2017, Garett Walker sent email to Cathy stating as follows: “At approximately 1145 hours Thursday the 9th we began flowing into the river, through the discharge pipe, blending fully treated Title 22 water with untreated water from the collection system. This continued until 1810 the following day….The following morning ….we again started blending through the effluent pipe….This gives us a total of 42 hours & 35 minutes of blending over the 3 day period.   Initial estimates show we blended approximately 1,100,000 gallons with the effluent flow over the 3 day period.  This action eliminated the uncontrolled SSO at the Vacation Beach lift station which helped to avoid putting public health and property at risk.”


  • Is blending the only option to stop over-flowing manholes? Could there be much less blending to accomplish the same effect?  I assume blending would violate terms of permit.


Post May 14th illegal discharge:

  • The letter to the Regional Board from SCWA announcing the illegal discharge, also excused it as having few impacts because river flows were 3850 cfs on May 19th and the less than 1% discharge was promised to have no effect different from that of May 14th when it was a legal discharge. (USGS data indicates the gage at Hacienda reported about 3500 cfs on May 21st and down to 1500 cfs by May 27th.)  What were Treatment Plant inflows during the week?  Did flow levels really justify taking this action, especially on a holiday weekend?  The letter didn’t explain (for me) why the situation was so dire, especially when they started the discharge right as the holiday weekend began. (Were decision makers on vacation?) While District managers could not predict the future on May 19th, we wonder why they had to discharge for seven days when flows were going down?  Why weren’t they adjusting their situation on a daily basis and greatly minimizing the discharge?  Perhaps they did and I simply did not have the information.


  • Working with NASA, SCWA has been putting large investments into weather prediction to avoid a repeat of the 25,000 AF of water dumped by the Army Corps of Engineers in 2013 (intending to make room in the flood control portion of Lake Mendocino in preparation for 2013 winter storms that never came). Can they utilize this information to time wastewater discharges and minimize impacts on the treatment plant and ultimately the Russian River? We request that Regional Board staff consider use of sophisticated scientific data to make better weather and water flow predictions for plant operation.  Perhaps this can be spelled out in their revised permit being worked on this year.


  • Adequate public noticing protocols should be in place and followed during discharge events (legal or illegal discharges) and required in their revised NPDES Permit being developed this year, especially since the new Pathogen TMDL assumes that recreation occurs at all times of the year. (need for consistency on public health protection) We visited Monte Rio Beach on Saturday May 25th and saw no signs up about the discharge there, although there were plenty of warnings about the danger of the river at that time. As our pictures show, about four signs went up at Vacation beach but not the much more highly populated Monte Rio Beach. (This time it was not much of a problem because people had already been warned about strong currents and dangerous conditions on the river and were encouraged to stay out of the water. (Photos: Attachment #  )


  • I took pictures at Monte Rio Beach around 2 pm on Saturday, May 21st. (Attachment #5) There were some people there with a few in the water.  Is there any way public noticing protocols could be integrated into the revised discharge permit?  Lynda Hopkins mentioned setting up a committee to work on emergency information during floods and other disasters.  Part of this could be educating people about the importance of minimizing water use during flood events.  A ‘who to call for what and when’ list would also be appropriate.


We hereby submit these comments for your consideration.  We believe any penalty should go to thoroughly clean up the properties of those subjected to the surging manhole, including the Russian River Park & Rec’s children’s park on Orchard Ave.  Furthermore, we would like to see studies done to assess the problems with the system and a fiscal analysis to get them fixed.  This should include the collection system.  Then system needs should be prioritized with health concerns getting top consideration.  No one should have to walk/drive up and down a street for a week (during which there was no additional flooding and streets were passable) that is filled with poop remnants.