RRWPC Newsletter, September 2019: TMDL, Septic, and Sewage Spill

Regional Board meeting on Pathogen TMDL….
Although not heavily attended, those who came out for the Regional Board Meeting on August 14th to take part in the hearing on the Pathogen TMDL, were very informed citizens on this topic, as many had been tracking the issue for years. (You can see entire meeting by going to: http://cal-span.org/static/meetings-RWQCB-NC.php  Click on camera icon in box labeled August 14, 2019.  A black box will come up mid-screen.  Scroll down and click on message “download video”.  This will take about a minute.  The entire hearing took about three hours.  There’s a horizontal bar beneath the video that you can move and skip around the various presentations.”)

Essence of RRWPC’s Presentation…
RRWPC has had some internal conflict on this issue as with no other.  We have been torn between those aspects of the now adopted regulation that supports a clean environment, while fearful that it would tear the fabric of our community apart because of potential hardships created by the costs, complexities, and magnitude of program implementation.  On the one hand, the evidence of septic pollution provided by Regional Board staff is less than compelling, nevertheless we can probably all agree that there are some septic systems out there polluting the environment that need to be identified and then repaired or replaced.  We would hope that officials do this in a compassionate way and not with a heavy hand.  Once this regulation is finalized in Sacramento and implementation begins, we’ll see how things go.

RRWPC has helped play a role in getting Regional Board to soften their tone a bit with the community.  This has been effective to a limited degree.  They have promised the following:

  • They are looking into ways to expand the list of professionals qualified to conduct inspections that considers effectiveness of soils to filter pollutants from Onsite Wastewater Treatment Systems;
  • Although cesspools will no longer qualify as acceptable OWTS (Exact definition of ‘cesspool’ is unknown so far: State will be asking property owners to describe their systems.)
  • they will extend compliance deadline for as long as 15 years for low income people who agree to not expand OWTS capacity or load but inspections will be required every five years;
  • and they will look into the viability of composting toilets.

Another sign Regional Board staff is responding to community concerns about their minimal evidence of pollution from septic systems is the following: In response to comment in Appendix A: Holmer-7, they state, “The TMDL makes no finding that septic systems along the main stem are contributing to violation of water quality objectives.  In fact, the TMDL makes no finding associated with any specific OWTS at all.  If OWTS are cesspools, failing or overloaded, the OWTS owner must seek replacement or repair.”

As you recall, RRWPC has been struck by the very low number of exceedances of E. coli (official measure) in the lower river all summer over the last nine years.  We just received data for Monte Rio Beach for 2018.  There were NO E. coli exceedances for the 25 samples taken between May 15th and October 16th, 2018.  This implies there continues to be no indication of a health threatening trend by current septic systems.

Yet it is interesting that a different staff person involved with this project stated at the meeting that there was other, new evidence of E. coli pollution that staff recently found that had not been included in prior analysis.  For the last week, we have been asking staff to show us this new evidence and she will not respond to our messages. Draw your own conclusions.  Like everything else, the friendliness demonstrated to the public may depend on who you talk to and when you talk to them.  We hope our supporters will help us track any bureaucratic nightmares that occur when the rubber hits the road with implementation of this project (sometime next year).  As for Board members themselves, we had the strong impression they came into the room knowing in advance that they would certify these documents.

Finally, we questioned during our presentation at the meeting: “We ask why, if septics pollute, or threaten to pollute, are there are so few E. coli exceedances in the lower Russian River from May through September over the last nine years?  Wouldn’t a trend of exceedances indicate septic systems are failing?”  We conclude that it would seem that a lack of a trend over this long period of time could prove the opposite.”

Regional Board finally responds to RRWPC’s complaint on raw sewage spill last February….
As you probably recall, RRWPC filed a complaint on the raw sewage spill at the Russian River County Sanitation District (RRCSD) on June 2, 2019.  During most of that time, we had asked the executive officer of the agency and also appropriate staffers, when there would be a written response.  Well, knowing that we wanted to discuss this situation at Public Appearances at the Board meeting last Thursday, staff contacted us and said a letter would be forthcoming on Friday before the meeting.  Then they told us that it would come on Monday.  Well, we received it Tuesday afternoon, a day before the meeting.

In the meantime, we looked back on all the reports and discovered that, based on their estimates,  approximately 1,400,000 million gallons of raw sewage went into the neighborhood and Russian River at two manholes that were surging around February 14th and between February 26th and March 2nd at Vacation Beach and Riverside Dr. (Surging manholes were on opposite sides of the river but both are among closest to treatment plant and therefore may be under more pressure during floods.)  We believe this indicates serious deficiencies in the collection and treatment systems.

The letter we received was really only a page; but here are some highlights:

As you correctly noted in your detailed complaint summary, the District’s NPDES permit prohibits sanitary sewer overflows that reach waters of the State and discharges that create pollution, contamination, or nuisance….The District’s NPDES permit also prohibits point source waste discharges to the Russian River from May 15 through September 30.  Our preliminary assessment of the facts related to these matters is that the alleged February 2019 sanitary sewer overflows described in your complaint and the off-season discharge of treated wastewater would constitute a violation of NPDEA permit prohibitions.  Regional Water Board staff is currently reviewing for possible future enforcement action the information provided by the District in response to the discharges and the information that you have provided to assess the facts and circumstances of the discharges…. It is our intent to work with the District to address any deficiencies in the District’s NPDES permit when it is scheduled for renewal in 2020.”

The problem with this, and which we expressed to the Board at their meeting, that this says nothing about exploring the deficiencies of the system, or determining a plan and budget for making needed improvements such as increased storage, increased irrigation area, probable need for a new force main (large pipeline), collection system improvements, and more.  They didn’t say much, but our big concern is that they may want to expand the system for new hookups without making needed improvements.  Sonoma County Water Agency, managers of our sewer system, is great at getting funding for water projects (They recently went to Washington, D.C to lobby for funds for their water infrastructure, but in the almost 24 years of running the Occidental system, the best they could come up with is a system where they truck 5-15 loads of raw sewage around the County every day.) There is a clear difference in approach here by Regional Board.

RRWPC needs your continuing support!
RRWPC counts on your continued support to sustain our river protection work, but some on our list have not contacted us for a while.  We hope to hear from you soon so that we know you continue to be interested in receiving our mailers and supporting our work.  Any sized and all donations are appreciated. We rely on six mailers a year for our entire fiscal support. On the label by your name you will see two numbers that represent the month and year we last heard from you. Also, we encourage those of you who have not shared email addresses as yet to sign up so that you can receive important messages.  Our last mailer of the year (next mailer) will come out in Mid-November and will contain our annual door list for donations received between November 1, 2018 and October 31, 2019.