RRCSD’s History of Sewage spills: 1985 – 2021, March 21, 2023

To:  Citizens Advisory Group (CAG) and Interagency Technical Group (IT Group)

Russian River County Sanitation District’s (RRCSD’s) : History of Sewage Spills & Permit Violations

By Brenda Adelman on behalf of RRWPC

Introduction: Part 1

As the Action Plan for the Russian River Watershed Pathogen Total Maximum Daily Load and associated documents and studies awaits approval by the State Water Resources Control Board, and as we also await final decisions on the County’s Onsite Wastewater Treatment Systems Manual, A Citizen’s Advisory Group (known as CAG), set up almost four years ago now, along with an Inter-Agency Technical (IT) group, continues to evolve.  The ‘IT’ group was composed of Supervisor Lynda Hopkin’s representatives and those from Sonoma Water who manage RRCSD, Planning Department (Well & Septic Division), North Coast Regional Board, Sweetwater Springs Water District, and a few other community agencies.  Nine community members currently comprise the citizen’s group with five of them being property owners in the Monte Rio/Villa Grande communities and who will be greatly affected by decisions made by agencies of IT participants.

It has been our group task to give input to County and State officials on citizen concerns.  Some expressed expert opinions and suggestions regarding new requirements to be established.  Most citizen members are themselves on septic and very familiar with the ins and outs of maintaining such a system.  One person worked for the County for over 30 years in the Well & Septic division and is very much an expert in such systems.  I am the only Russian River County Sanitation District (RRCSD) ratepayer in the group.  I have studied and expressed concern about its evolution since before its construction (1978).  This paper serves  as a contribution of some of my memories about the history of this facility, which I have followed closely on behalf of our group, Russian River Watershed Protection Committee (RRWPC).  I do not consider myself an expert on the operation of wastewater treatment facilities, but have learned a great deal about the many rules under which they function and many of the problems meeting requirements that they have experienced.

Our group has attended many Regional Board meetings over the years concerning planning decisions and regulations about this facility. We have submitted comments on regulatory and planning documents and numerous CEQA documents. We had many meetings with staff regarding our concerns.  We filed a few legal actions on proposed projects and expansions, and as a result of our extensive dedication over so many years, was awarded the North Coast Regional Water Quality Control Board Executive Officer’s 2018 Water Quality Stewardship Award for our advocating on behalf of the Russian River Watershed.
RRWPC view of current circumstances….The CAG has been presented with three options to consider in regard to resolving how to bring these two communities into compliance with not yet finalized new septic system rules.  Those options are to be studied by Brelje & Race consultants, recently hired to write a plan for a project proposal.  Those three options include: repair and/or upgrade individual septic systems that are not in compliance with new rules, establish guidelines for community septic systems utilizing community leach fields, and/or hook up to a central treatment system such as RRCSD or Graton.  (These are the most likely two facilities being considered.  Others, such as Santa Rosa and Airport, because of great distance, are probably too expensive to consider.)

Those three could really be considered as  two options (sewer or septic) as the two septic proposals can function as one with some being single systems and some being part of a common leach field.  Then there is a third which we suggest as the No Project Alternative.  This third can include setting up a septic district that arranges for inspections, helps with funding, and advices on how to come into compliance, but does not serve a regulatory role (or perhaps a very minimum role) and does not get involved in siting, repairing, constructing, or directly approving actual systems.  It would serve more as an ombudsman program. (There can be many other configurations of such a program, the idea being to make it protective of the environment while also affordable for property owners.)

There is another aspect to the viability of the options we have to choose from.  We question whether communities in rural areas can even afford central sewers, especially in geologically challenged areas such as West County?  In an email letter I received from Charles Reed on January 9, 2006, he responded as follows to a question I had asked: “Clearly additional connections increase the baseline wastewater flows and add more wastewater and I&I during wet weather conditions.  As you suggest, additional connections may exacerbate existing plant deficiencies.” (emphasis added)

Furthermore, it has become clear that district rates cannot cover the needs of the system.  Because our rates are so high, they can never go high enough to take care of its needs.  Adding new ratepayers may give the District more money to work with, but it would also put greater strains on the system that could bring costs to much more than the communities can afford, especially if maintenance costs grow at a rapid rate, which would not be unusual in this day and age.  And maybe worst of all, much of the system has not been seismically secured and if a major earthquake occurs, we are all up a creek, so to speak.

After RRWPC reacted strongly to the over million gallon spill in the Vacation Beach area in 2019, we got a lengthy letter from Grant Davis, head of Sonoma County Water Agency saying: “Since 2004, the District has invested more than $21 million in capital projects.  Of that amount, more than $16 million has been secured in grants and low-interest state loans.  Another $3.5 million has been invested by the District in these capital projects, and Sonoma Water has spent $1.4 million from its General Fund to pay for maintenance and equipment replacements.  We have done all this with the understanding that the District has limited resources and we have leveraged grants and loans as much as possible to minimize the impact to ratepayers.

The truth is, in our view, this project is a hot potato of which no one seems to want to be in charge. No one is stepping up, but for the Water Agency that would probably be willing to add hundreds of new hook ups to a partly antiquated system (RRCSD).  The point of this paper is to explain why we think it is a very bad idea to add any new hookups to our current system until most repairs that our system needs are in place.

Not only that, but storage and irrigation areas would need to be expanded to properly accommodate an influx of new flows to our system.   There must be a way to deal with flood flows and prevent untreated or partially treated sewage from entering the river.  To even contemplate such hookups now would be a travesty.  We are dedicated to seeing that it doesn’t happen before such accommodations and improvements are made.

West Yost did an analysis of lift stations, force main, and headworks.  They estimated condition of each facility and assigned an estimate of cost to most essential work needing to be done (on a scale of 1 to 5, with 4 and 5 being the worst, they estimated each level of repair with main focus on those with 4 or 5 ratings.  For critical short term repairs of all lift stations, they estimated costs of $8,212,000.  That is in addition to costs for force main and headworks and other repairs not far down the road.  Somewhere I saw that total needed was $50 million for everything plus 50% contingency, but am not clear yet what that covers.

RRCSD early days…In the late 1970’s Don Head, in charge of the Sonoma County Public Works Department, and his side kick Hal Woods, met with some Guerneville citizens to talk about the coming Russian River County Sanitation District.  There had been problems with getting citizen buy-in for approval of the anticipated sewer system for Russian River County Sanitation District.  (RRCSD)  Perhaps local citizens had a premonition of what was coming down the road, for in two elections, they failed to approve moving forward with the project and commit to a proposed share of cost of about $3M, a great deal of money for our low and middle income community at the time.

Even in its early stages, the system had been fraught with challenges.  Citizens had voted down two initiatives calling for their funding share, originally thought to have an ultimate price tag of $13M with State and Federal programs committed to funding about 75% of the total estimated EPA approved cost.  In addition, County officials were having trouble getting bids that came within their limits and had to redesign the project to save costs and entice bid responses.

Some of the details allude me now, but we recall they made changes to the gravity slope, they cut out two pump stations, and we assume many other changes as well.  We recall they made a deal to use cinnabar rock from our local Sweetwater mine for pipe bedding (which was believed to have Mercury in it and was much cheaper).  Some pump station contractors tried to alert us of other problematic changes, but we did not have the technical knowledge to determine whether the changes were appropriate or not, so we didn’t take action on it.

The first two elections for the District project required a 2/3 majority of citizens voting to pass, but then Doug Bosco who was a US Congressman at the time became involved, and he helped fashion a proposal that would only need to pass by a majority.  The third vote passed by the 2/3 originally sought and the community’s commitment to sewer became official.  That was around 1978.

The County rebid the project and hired Montgomery Engineers and Caputo Wagner Construction Company.  Many problems occurred, including:

  • Ultimately there were 30 change orders and the system went from an anticipated $13M to a final $32M.
  • Additional costs covered digging out underground large tree stumps to the tune of $1M.
  • They had problems with water pipeline maps, when they had them. Many were not available.  Not sure how they resolved problem of maintaining required distance from water supply pipes with inadequate, or in some cases, no maps.  We don’t know if they had special equipment to locate pipes. We do know this was a big problem at the time.
  • We understand they started two pipelines between Guerneville and Rio Nido that were supposed to meet in the middle somewhere but apparently that didn’t happen. Not sure how they resolved it.  (Recent road work on the Rio Nido strip included manhole cover replacement which alternated between north  and  south sides of River Road.  Could this have been the result of original placement where pipes from different directions did not meet?)
  • There were problems with high water tables, making pipe installation difficult.
  • The construction contractor accused engineer of not always being present on site and they weren’t able to fulfill their duties and ended up suing the County. The County lost the suit, fired the engineer and hired another contractor to finish the job.
  • EPA had a lot of problems with some of the claims. We believe they held back some funding as a result but don’t recall details.
  • In 2021 there were problems with severe pipeline corrosion at Guerneville lift station that required emergency repair. A Water Agency engineer asserted that the wrong kind of pipe had been used during original construction.  There had also been a major break in the pipe near Vacation Beach where a similar claim was made and 100,000 gallons of raw sewage flowed into the river.
  • (RRWPC saved most of the documents from that time, but for those of us with bad backs however, it’s been too hard to access them from storage.)

RRWPC’s point in providing this history is that many assertions are currently being made by Water Agency staff about how affordable it would be to hook up Monte Rio and Villa Grande to RRCSD.  We don’t agree.  Based on experience, major revisions and repairs will probably be necessary before the two communities could be hooked up.  For that matter, in addition,  it is likely the septic system inspections and upgrades will seem (and be) onerous for many property owners also, and the RRCSD is falsely being targeted as an easy and affordable solution to their situation.  Becoming aware of this earlier RRCSD history can help educate residents as to realities about some outcomes that can occur, the biggest reality being that we pay almost $2000 a year for the service, (not counting hookup fees) and this does not begin to cover the fiscal needs of the project. No doubt there would be other, new, unexpected issues to confront as well, but certainly, funding is a very big one.

RRCSD, the local environment and new regulations…We live in a vacation getaway.  People come from the big city on summer weekends to play in the lower Russian River, see the redwoods, visit the ocean, and more. Many end up cherishing this area so much, they retire here.  They are comfortable with the rustic life style.  People far and wide know about the Russian River and Guerneville.

Our towns are eclectic and wish to remain that way.  Tiny little shops, quaint little restaurants, and friendly people.  Most river towns are served by river water and those further from the river rely on wells.  They say there are 40,000 wells in Sonoma County, with many existing in the western portion of the County. There are institutions that have recently been set up to regulate groundwater, although our area is not included at this time.  In this time of global warming and extreme multiyear droughts, it is a necessary endeavor.  The Sonoma County Water Agency has many plans to study the extension of water supplies, with urban contractors making their own plans as well.  They all believe that drought will return and they want to be prepared.  Protecting Russian River water quality and quantity is the goal of many in our lower river community as well.

Living in the river environment is not always easy: the floods and  fires are a challenge, along with relatively frequent electrical outages, limited services, trees that crowd out the sun (a great advantage in summer, but so very gloomy in winter).  The streets become rivers in heavy rain. The forest can be bone chilling in winter and provide cool relief in summer. Little need for air conditioning where we live.  Many people live on limited incomes.  They won’t be prepared to fork over large amounts for sewer, especially since they are used to paying nothing over the years.

Because of the variable geology, land plans can be haphazard and parcels are often confined by hillside configurations and large trees that few locals can alter or remove.  Some of the new rules do not seem to recognize existing situations.  Big houses on small lots may have difficulty getting septic permits because large yardage size will now be needed for leach fields. What’s to be done in those situations? New rules appear to be rigid on this requirement yet something has to give on existing structures. Our lot sizes are variable like our geology.  Nothing is regular on the river.

Features that make our area so desirable can be lost if new regulations, designed for large, flat, and square parcels, are forced on our unique natural environment.  Some believe that switching from septic systems to central treatment systems (such as RRCSD) in a flood plain, guarantees that when there is a huge spill of raw sewage, it will be accepted as a necessary evil, with the idea that it only happens once in a while during big floods and should be excused, even if totally illegal and dangerously unhealthy.

(Comments about septic system issues with proposed new regulations have been defined by others, more expert than myself, and RRWPC has agreed with many of them. We won’t describe them here.  A significant list has been developed and we support most of their concerns.)

The very problems to be addressed with new rules just become different problems and people are stuck with the new circumstances that require great expenditures to adapt. We are thinking that the main point of the TMDL is to prevent any systems dealing with human waste products to ever fail, but the truth is that major failures regularly occur during large floods, and sometimes only at that time,  with both conventional central sewer systems and septic systems, especially when the age of the systems becomes an issue. As far as the TMDL is concerned, either way is a problem.

(In 2017 and 2019 RRCSD discharged total of 2.3 million gallons of raw and partially treated sewage.  The operators and the Regional Board are still negotiating the penalties six and four years after the events. Such events are and have been illegal under State and Federal law.  The agencies cry ‘poor’ and nothing gets done for a very long time.  It has been four years that RRWPC submitted a complaint on the major spill in 2019 and nothing has been resolved yet.)

Drought has been said to damage the trees and makes them unstable, and we wonder what happens to redwoods if you take away all the septage in the summer time?  What happens to salmonid fish greeted with nasty, disease ridden sewage during the height of their migration period under flood conditions?  Similarly, to switch everything to pipeline transport should require studies as to what this will do to our forests AND our fish.  What will it take away in carbon sequestration if trees are lost? How will large spills impact migrating coho?  If communities choose to switch to RRCSD, then there should be no new hookups until all needed repairs and upgrades, needed to prevent major spills at all times, are accomplished at RRCSD.  We believe, should a pipeline solution be selected, that a better option would be to get Monte Rio and Villa Grande sewage away from the Russian River all together.  Sending it to Occidental to then hook up with the planned pipeline to Graton sounds like a possible viable solution for people and the environment.

It is our sense that governmental entities, because of complex circumstances including serious funding issues, really don’t want to manage septic system programs, and may in any case prefer to hook up to Russian River County Sanitation District. It is much more convenient for them. But, if there is a better solution for citizens, under the circumstances, it must be taken.
River Citizens Sewer Committee is born:

In 1980, citizens of the lower river joined together to form River Citizens Sewer Committee, (later to become Russian River Watershed Protection Committee (RRWPC)), initially so-named because of our focus on the new sewer project being planned at the time.  Our main concern was cost, but we also raised concerns about the functioning of the system, management of the system during floods, the need for cutting many trees, and potential spills that could cause degradation to the river and local environment, etc.  We were told that the Treatment Plant was state of the art.

Our concerns were well justified, as there have been many serious problems over the years.    We acknowledge that due to difficult terrain, sliding hillsides, periodic great floods, fragile soils that can liquify during major floods, etc., we have a difficult system to run and costs have ballooned.  Annual fees for ratepayers started out at $300 a year; they are now approaching almost $2,000. The North Coast Regional Water Quality Control Board regulates the system to minimize environmental damage, but because of these difficulties, the budget is often too inadequate to properly repair and manage the system.  Fines and penalties have provided income to improve the system, but there’s never enough and recent cost estimates put some needed repairs,, especially to lift stations, at about $50M with a 50% contingency, as recently assessed by West Yost. So while they have improved some aspects of the treatment plant, the collection system (including critical lift stations) goes mostly unrepaired.  A large percentage of the stations are in critical condition.

(Recently several emergency repairs, including about 800’ of force main pipe in Vacation Beach area, have occurred and so far, in 2023, I have heard of no major spills in that area.)
RRCSD: TMDL Issues…The Regional Board staff has been working on the Pathogen Total Maximum Daily Load (TMDL) for many years now.  It is in its last stage, awaiting State Water Board approval.  The TMDL has been intended to assess bacterial pollution in summer and the extent to which it is a risk to public health.  The TMDL is supposed to identify amounts and sources and allocate the means for addressing the problem.

While the goal is to protect human health while recreating, most of which occurs in summer, the TMDL covers the entire year.  When RRWPC questions why there are few E coli exceedances in weekly samples each summer at Monte Rio and Villa Grande and other down river locations, and if there is very limited, if any, recreation in the winter time, it is admitted that a great deal bacteria runs off and ends up in the river during heavy rains.  Yes, we agree with that.  Septic systems fail when it rains a lot.  JUST LIKE THE TREATMENT SYSTEM FAILS WHEN IT RAINS A LOT.   Yes, there are huge amounts of bacteria in the river during a winter flood.  So only if the collection system of the RRCSD is repaired, and storage and irrigation area deemed adequate, should anyone consider adding large numbers of new hookups to the system, especially if the purpose is to limit sewage spills into the Russian River AND keep it free of pathogens.

It’s not hard to find various bacteria in the river, much of it benign, and some generated as a result of no available toilets for canoeists as they traverse the river in summer, or homeless people using the river as a toilet, or animals, other upstream sources, etc.  But studies, to our knowledge, have not specifically demonstrated that septic systems, and release of E coli pathogens, are causing the main problem in the lower river.  Twelve years of monitoring the lower river in summer under the Biological Opinion, failed to show that E.coli is polluting it, and that measure is the one required by the State to prove that human bacterial pollution in the lower river where septic systems prevail is a concern.  I hear all the time that septic systems are not polluting the river in summer.  We also don’t see health department warning signs for bacteria either.  (The river IS loaded with phosphorus however, and we frequently see warning signs about toxic algae.)

Furthermore, our area includes huge masses of redwood trees, sometimes as far as the eye can see, among the septic systems and around the Treatment Plant. In fact the TMDL states that the least amount of summer pollution is in forested areas.  Because we have houses however, they don’t count our area as forested.  Go figure.  We theorize that the effluent almost never reaches the river in summer because of the mass of underground roots that suck up the water.  While it has been demonstrated that E coli does exist in the winter high flows, and it is likely a percentage is from failing septic systems, based on the evidence from all the spills, it’s a matter of how do you want your poison?  It makes no sense to make people go through the turmoil of switching systems, when similar problems will occur anyway through other means.  Another source is people of course.  A study was conducted on the Monte Rio Beach one year, showing substantial E. coli present on a very crowded July 4th weekend, but  the pathogen rapidly disappeared a few days afterwards when everyone went home.

Financing is also needed to help those that cannot afford to put in a new system when needed.  All of this could be cheaper than immediately constructing major upgrades to expand the Russian River County Sanitation District or any other facility serving the same function.  (A recent professional cost estimate for upgrading lift stations and headworks would cost about $50M and have a 50% contingency factor.  We do not think this includes costs for expanding the system to accommodate about 1500 other connections to serve Monte Rio and Villa Grande or replacing the force main in the lower segment of the system.)  Not only that, it is probably not fiscally viable to  hook up some parcels and not all or most of them.  Pipeline installation is difficult and expensive in our area and it should be an all or nothing deal.

It has been our impression that prior (and possibly current) water boards and staff have always wanted to see septic systems abandoned in favor of central systems, preferring more control over wastewater discharges and pollution.  We know that the Water Agency, manager of the RRCSD, prefers to add communities to the RRCSD.  We are quite certain that they do not want to manage septic systems.  And in fact, so far, almost no qualified entities have indicated that they would be willing to govern a septic system program, so that’s another reason for the reluctance.  Almost the entire time that RRCSD has been in existence, someone has wanted to expand the RRCSD system to include communities now on septic.  Yet, as we have already indicated, RRCSD has more sanitary sewer over flows (probably allowing more bacteria into the river) than any other system allowed to discharge in winter time.  They have made major improvements to the treatment system and that is noteworthy (most being a result of penalties) but it’s the collection system that continually has problems during major floods, and so far that has been too expensive to permanently fix.  Furthermore, funding institutions generally don’t want to fund septic improvements and mainly prefer to fund central sewers.

At one point, Occidental and Camp Meeker were favored to hook up to RRCSD and Camp Meeker Recreation and Park District, water system Board, tried two different times to get approval for such projects, one of them in league with Occidental.  They both failed to be approved because of cost and in Camp Meeker’s case, a faulty EIR.  Monte Rio tried for years to develop their own wastewater treatment project, (Electric grinder machines were to be installed on each property and then waste moved through pipes to a central disposal site where it would get irrigated on a field.)  and at one point got very close.  The community had actually approved moving forward with a project, but the consultant increased project costs by about six million dollars, after funds had already been obtained for the original amount, and the County killed the project.  Interestingly, both the Occidental/Camp Meeker and Monte Rio projects (which didn’t cover all of Monte Rio) came out about the same time with estimates of $22,000,000.  That was much more than the communities could afford.  And today’s cost would no doubt come out to be much more than that.

At the time, the County and State were very clear about wanting to join up septic systems to RRCSD. Besides Camp Meeker and Occidental (who had their own failing system and a long history of failed solutions to their problem), Forestville, Graton, Monte Rio and Villa Grande and small community systems and individual septic systems in between were all being considered.  This regional proposal was the topic of a Board Meeting by all five Supervisors in Forestville in May, 1996.  About 300 people from the surrounding community showed up and said “NO”!

Ten year comparison of permit violations…… The “Updated Final Staff Report for the Action Plan for the Russian River Watershed Pathogen TMDL” contains a chart entitled,  “Sanitary Sewer Overflows in the Russian River Watershed from 2007 to July, 2017” (Table 6.3: Pages 6-24 & 6-25).  Nineteen Russian River dischargers are listed, including RRCSD. The Table lists the number of SSO’s (Sanitary Sewer  Overflows), the volume of SSOs (gallons), volume that reached surface water (gallons) and percent that reached surface water for each discharger.  There were 275 SSOs by all dischargers and a combined volume of 1,729,925 gallons illegally discharged.  RRCSD had 19 SSO’s, and discharged 1,445,969 gallons during that time period. (Huge number of gallons with each SSO is obviously very unusual.  This was a result of events occurring during major floods.)  100% of RRCSD’s spills went into the Russian River.  Put another way, RRCSD illegally spilled about five times more into the Russian River or its tributaries, than all other dischargers combined, including Santa Rosa and the Subregional system.

This chart, intended to indicate OTHER sources of bacterial pollution in regards to TMDL, (as compared to septic systems), proves that RRCSD is by far the greatest contributor of pathogens to the Russian River from Sanitary Sewer Systems. It is ironic to consider that several Water Agency and Regional Board staff appear friendly to the idea of hooking Monte Rio and Villa Grande to RRCSD in order to comply with the Pathogen TMDL.   Is it possible they consider the resolution of eliminating bacterial pollution to be hook up to a system that periodically spews millions of bacteria and toxins into the river during large floods?  (In 2017 and 2019 we still have the unresolved SSO spills of a combined 2.3 million gallons spilled.)

Perhaps even more difficult to comprehend is the idea that current SSO problems and compromised sewer mains (due to old age) started becoming evident as far back as nine years ago in 2014 when a large pipe broke close to Vacation Beach that resulted in 100,000 gallons of raw sewage being spilt.  The raw sewage and partially treated wastewater, loaded with viral and bacterial pathogens and many unidentified toxins (including pharmaceuticals), much of it first discharged through sanitary sewer overflows into a residential neighborhood in the area where children used to play in a former children’s park, adjacent to the Vacation Beach Lift Station in close proximity to the Russian River.  Most was discharged during the Coho migration season and could have had a dire impact on the fish, assuming there were any present to experience it.

The text located immediately above the chart downplays the impacts of these huge amounts by claiming there were only a few pipe breaks and a few SSOs caused the excesses (true), ignoring the huge amounts of pollution entering the river because of the spill.  It also states that because people usually don’t report failures in their septic systems, they conclude there are probably many more septic failures than we know about. They don’t mention the very thing their pathogen studies supposedly concluded: that the TMDL was necessary because of supposed defined evidence of excessive bacteria in the river. (i.e., The TMDL claims to have proven that many septic systems are failing, but here they state it is an assumption.)  So which is it: scientific proof or general unproven assumption? **

THESE WERE ILLEGAL DISCHARGES that must have contained millions of bacteria and other pathogens and toxins.  We don’t know how much came out during subsequent monitoring regarding impacts to the local environment and we don’t know how much long term damage may have been done to fish and aquatic life.  (We have very recently learned that ‘forever’ PFAS chemicals, soon to be regulated by the EPA, have been found in toilet paper.  Since PFAS containing many families of hundreds of different chemicals, is found at low levels in most humans and animal life at this point, and as they are not regulated in wastewater, we can be looking at a huge source of toxins that will finally be addressed.  EPA apparently now agrees and have made historical proposals to limit their occurrence.

**  Most of the very large spills occurred during record floods. There were 15 floods of record over 40’, which seems to be the level over which most big spills occur. (In 2014 there was also a major pipe break by Vacation Beach Pump Station which resulted in a major spill of about 100,000 gallons.). Six of those floods occurred after the system went on line in 1983, (although there was a spill in 1983 that we don’t count because there were few hookups at that point.)  The large spills of record took place in 1986, 1995 (2), 1997, 2006, and 2019.  Legally the system is required to prevent illegal discharges 100% of the time.  The operators’ complaint has been that conditions were such that they couldn’t prevent the event.  Regional Board insists that they have to comply but ‘negotiations’ over the penalty are held in secret, often for years.  Currently the pressure mains, the 11 lift stations, and the headworks are in need of significant repairs.

The big concern for many was the prospect of major growth and development in the fragile hillsides, traffic nightmares on our few, narrow, winding, deteriorating roadways, and the desire to retain the unique individual nature of each of our small communities.

Pathogen TMDL motivates change & citizen’s committee established….Over the last ten years or more, Regional Board staff have worked on developing a Pathogen Total Maximum Daily Load (TMDL) for the Russian River. The main goal of this effort was to set new rules that would assure that no pathogens would reach the Russian River.  A plan evolved to require upgrading out of date septic systems or the establishment of community septic systems, or hookups to RRCSD.  Monte Rio and Villa Grande were close to the river and believed to have many substandard septic systems. They were chosen to lead the way for other communities. There would be a consultant hired to draw up a plan and an ombudsman to work with the community.

A Citizen’s Advisory Group (known as CAG) was set up, along with an Inter-Agency Technical (IT) group.  The ‘IT’ group was composed of Supervisor Lynda Hopkin’s representatives and those from Sonoma Water who manage RRCSD, Planning Department (Well & Septic Division), North Coast Regional Board, Sweetwater Springs Water District, and a few other community agencies.  An ombudsman was assigned to work with the community also.  There were initially ten CAG members representing the community and two communities upstream.  That group, included RRWPC as a RRCSD rate payer.  (Both the current and past Sweetwater managers are in the group as well as a representative of the non-sewered Hacienda area.)

The Citizen’s Advisory Group (CAG) has been meeting for almost four years now, along with IT Representatives, with the goal of helping to develop waste disposal protections that prevent pathogens from entering the river in Monte Rio and Villa Grande.  An ombudsman has been assigned to serve as a liaison with the community and give input to the study that will look at three possible resolutions to upgrade and or replace supposedly failing or inadequate septic systems in the area. The consultant (Brelje & Race) has been recently hired and are now working on the basic design and plans.

(Note: Ten years’ worth of water quality monitoring of local beaches in summer show constant phosphorus exceedances and very few  E. coli exceedances.  Septic options include total replacement or upgrades that meet new guidelines for waste disposal on individual properties along with inspections every five years to make sure everything is working properly.  They will also be looking at the possibility of community systems (or a combination of the two) and the possibility of hook ups to RRCSD.)

RRWPC agrees that septic systems need some kind of oversight and management.  We support inspections that occur every five years.  We believe, based on our long time (40 year) experience with RRCSD, and for reasons listed below, that our collection system must be fixed before other communities are hooked to our system.  It may be determined that new communities cannot safely and/or affordably even be hooked to our system.  We are also worried that the problem this is all supposed to fix, i.e., keeping pathogens from sewage out of the river, will become worse than it is now because of the increase in sewage to be treated at the treatment plan, especially during high floods when raw sewage often spills into the river from manholes, as a result of surging flood flows.

RRWPC has been concerned that plans might move forward before the serious illegal discharge history of RRCSD is addressed and fixed :

  • RRCSD should be able to perform without any SSO discharges of raw sewage into the river during the highest floods. As mentioned earlier, RRCSD is five times worse in this area than all other river dischargers put together.   We want our lift stations, headworks, and force mains repaired (with grants and loans) so the system can withstand floods without polluting the river.
  • Any expanded capacity to serve winter flows must first be able to serve flood flows so we don’t pollute the river. (As global warming expands, and based on the almost constant rain we have had this winter, we can probably expect even more flooding in the future.  Planners should incorporate this into the plans.)  Septic systems along the river should be able to adequately perform during all potential increases in water levels.
  • Rate increases of over 5% to pay for all this should not occur. Last year the increase was 8.5% and we can’t sustain that.  We are a low to mid-income community that has the second highest rates in the County (Only Occidental with only 84 hookups is worse.) More lobbying may be needed to generate federal funding for these improvements.

Finally, other changes are currently being proposed such as more low income housing, exploring viability of incorporation, cuts in summer river flows, hooking up more properties to nearby central sewer systems rather than more septic systems, and a new Housing Element EIR calling for a lot more housing expansion.


Russian River County Sanitation District’s (RRCSD’s) : History of Sewage Spills & Permit Violations:  Part 2

What is a Sanitary Sewer Overflow (SSO)?

California State Sanitary Sewer Overflow Reduction Program Dec. 6, 2022 states:

A sanitary sewer overflow is any overflow, spill, release, discharge or diversion of untreated or partially treated wastewater from a sanitary sewer system. Sanitary sewer overflows often contain high levels of suspended solids, pathogenic organisms, toxic pollutants, nutrients, oil, and grease. Sanitary sewer overflows pollute surface and ground waters, threaten public health, adversely affect aquatic life, and impair the recreational use and aesthetic enjoyment of surface waters. Typical consequences of Sanitary sewer overflows include the closure of beaches and other recreational areas, inundated properties, and polluted rivers and streams.

RRCSD’s history of illegal discharges…This paper documents much of the history of illegal discharges by RRCSD into the Russian River.  Where known, we note spill amounts into the Russian River, penalties, and system improvements made with portions of the penalties when authorized by the Regional Board. We try to cover the period of  its operational history from 1983 to present.  Information is based on official documents, newspaper articles, meeting minutes, governmental documents, and other reports collected by Brenda Adelman of Russian River Watershed Protection Committee (RRWPC).

We call attention to repetitive spills and other problems of managing this sanitary sewer system in a major flood plain. Our record of the RRCSD facility covers the last 40 years, its entire functioning life.  Major spills occurred when river level went above 40’ (32’ is early flood stage in downtown Guerneville. We include a list of other flood levels and at what level they inundate streets and properties).  We assume that massive amounts of infiltration occurs from the pressure of large quantities of water surrounding the pipes that also deteriorate over time, in addition to degradation of the connective plumbing that experienced large amounts of wear and tear over the years.

In addition, the force mains may have been of lower quality and poorly constructed when new, in order to save money on the original project construction.  This points out the dilemma of public projects. Government is strongly encouraged to make sure that projects are affordable for the public, yet cutting costs can lead to inferior construction  and more problems down the road.

Flood waters can enter collection systems through plumbing fixtures of flooded homes, ajar manholes, illicit connections, drainage, and other sources.  Early on, improper system design and materials were assigned blame for disfunction, but as time went on blame shifted to the age of the system and resulting wear and tear over the years. Both conditions caused problems.

Regional Board’s Violations Determination Process
Each major spill event, especially those since 1995, since the time when SCWA took over,  can take years to resolve.  Regional Board usually combines 4-5 years’ worth of compliance data into one penalty process covering the entire period. Staff assigned to penalty phase have no working connection to staff responsible for planning and permit oversight.  Enforcement staff determine violations based on permit demands and monitoring and reporting requirements, such as spill violations, treatment violations, recovery requirements after a spill, reporting requirements, and managing, auditing, and program requirements etc. The discharger’s attitude is even assessed and factored in. (Are they cooperative? Do they file reports in a timely manner?  Out of three rankings, Sonoma County Water Agency (SCWA), managers of RRCSD since 1995, earned a ‘2’.)

These violations are then combined and ranked as to the seriousness of the spill; how much effort was made to minimize the spill; how much money was spent on fixing the problem (or needs to be spent); how effective and timely was the effort of the discharger with cleanup and reporting? etc.  Each of these rankings has either a minimum penalty assigned to it for unsatisfactory performance and/or a new requirement that eliminates or improves the violating circumstance.  (This is a rough estimate of steps they go through.)

How many gallons were spilled?  Was spill site all cleaned up, or did sewage end up in a waterway, and how much ended up there?   By the end of the assessment, each infraction had been carefully determined and quantified and a monetary penalty amount arrived at.  And sometimes there are tradeoffs. (Often the assessment of spilled sewage is underestimated by the discharger, but there are ways of assessing whether this was the case.  For example, in 2019, RRCSD staff understated the number of days that the spill was occurring.  The days that were eliminated were the same days where workers could not access the spill area.  This does not mean the spill was not occurring.)

Spills during flood of February-March, 2019, is not yet resolved as we are enter 2023. Along with other violations between 2017 and 2019, the Regional Board determined that the RRCSD violated their permit by allowing a total of 2.3 MG (million gallons) of raw sewage into the Russian River during spills in those years, mostly  during major flood events.  The recommended penalty for that combined violation over a four day time frame came to $23,000,000, although the State formula allowed for a larger assessment.

Following the violations determination phase, a lengthy period occurs during which negotiations take place.  (Regional Board and Sonoma Water are still in negotiation over that most recent issue which could end in litigation by the County.)  Often the facility, run by Sonoma County Water Agency is allowed to make improvements to the system in lieu of paying a large part of the fine (compliance project) and also some of the penalty might be forgiven, but not if they file a lawsuit.

Violations: System repairs needed will require governmental fiscal support….  As noted, RRCSD has had a long history of violations over the years, beginning when the system was only two years old, with some spills the result of human error, and many the result of dealing with large flood events and infrastructure breakdowns. There have been several treatment plant compliance projects during that time that were part of the penalty and addressed some of the important problems.  They were fiscally accomplished partially on the backs of current rate payers, with loans and grants also helping a great deal. (Note: some improvement projects included the Third Unit Processes project in 2006, a $9M UV Disinfection system completed in Oct. 2012, and later a Biological Nutrient Removal project (BNR); as well as the Natural Hazard Assessment and related upgrades, development of a Collection System Master Plan, etc.).  But the most recent rate hike (2022) saw an increase of 8.5%, and brought annual costs for ratepayers to almost $2000 a year, a burden for this moderate and low income community to bear.

Recently West Yost completed an assessment of pump station and headworks conditions and another firm has assessed condition of the force mains.   West Yost estimated that repair and replacement costs of pump stations and headworks alone may be as much as $50M with a 50% contingency.  They do rank all repairs needed as to urgency.  The price can be considerably reduced by phasing repairs in order of importance and urgency.  But whatever the amount, government subsidies will absolutely be necessary.  (Water Agency representatives have warned that future rates may be regularly increased by 10% each year.  That would bring ratepayers out to hearings if it comes to pass.)

As a result of above mentioned completed improvements, the system is now rated at 3.5 MG during wet weather flows (as compared to summer limits of .5 MG), although recent mention has been made by a Water Agency official that the 3.5 MG capacity can be allocated for service to hookup other communities.  That is unlikely to happen without numerous additional system expansions and improvements such as increased storage capacity and expanded irrigation area, mainly because the system is not allowed to discharge into the river between May 15th and October 1st.  The 3.5 MG capacity is needed for much heavier winter storm flows and high floods and is not intended for system expansion.

There is absolutely no point in contemplating the joining of new communities to RRCSD in order to prevent those communities from causing septic system bacterial pollution, and in doing so prevent RRCSD from complying with regulations that prevent river bacterial pollution with illegal discharges of raw sewage resulting from the loading addition, and for which current ratepayers would be further penalized.

And yet, we are concerned that the new 600 page plus County Housing Element calls for adding new housing to the sewer system west of Armstrong Woods Road and east of Monte Rio.  County Supervisors had previously directed Local Agency Formation Commission (LAFCo) to study the impacts to the sewer system of adding thirteen parcels to sewer district in order to hook up George’s Hideaway, recently purchased by the County for a Homeless Project, and lying 13 parcels outside of District boundaries.  This study is called a Municipal Service Review, which we commented on for the LAFCO meeting.  (RRWPC got the  review at the last minute and entered comments into the record.  It turns out that ten of the 13 parcels are unbuildable and therefore are not considered serviceable.  LAFCO voted to approve rezoning of 3 parcels to be used for a homeless project and RRWPC conceded that decision but insisted that the document under which it was approved be substantially upgraded before using it for broader application.  Staff agreed.)

Then we also learned that, as a result of the passage of SB 1215, the State established a funding and regulatory framework for consolidation of failing or inadequate septic systems to a central water treatment facility.  In our local case, that would be the Russian River County Sanitation District for the communities of Monte Rio, Northwood, Villa Grande and everything in between.  Staff has been hired by the Regional Board to facilitate the consolidation process.  The report to the Board, while expressing possible drawbacks, was mostly upbeat and positive about taking this on.  Of course, little about what we reveal in this paper has been addressed, evaluated, or mitigated.

That staff person will study the feasibility of such a program, and if he or she finds it appropriate, will help facilitate its development.  At the same time LAFCo (Local Agency Formation Commission) is supposedly putting together a study looking at the feasibility of expanding RRCSD district boundaries, as our Supervisor is trying to generate support for incorporation of the lower river communities.  The idea promoted is to give communities control over our destinies, but no mention is made yet of what large amounts will be needed to fix our sewer system or to provide all the necessary services.  At some point, there will be an election to determine whether the community supports incorporation and all that it entails.  We are hopeful that the County is not using the idea of incorporation to get rid of some huge problems, for which, as yet, they have not found any good solutions.

It is our goal to shine a light on the historical failings of the system and improvements needed to assure future compliance, especially if other communities are allowed to hookup.  The facility must be expanded  in order to meet all clean water requirements even during high floodwaters, whether or not the District is expanded.  Up to now, improvements possibly resulting in increased treatment capacity were added to address flood flows and not for the purpose of allowing expansion to serve other communities.

Furthermore, before any additional populations are added to the system, they should fund current and additional facilities to an appropriate degree. For instance, costs of additional storage should not fall on the backs of current ratepayers.  Any past improvements that had been paid for by current users, should be compensated by new hookups to the extent that they benefit from the already constructed improvements. There should be an economic assessment that bases rates for new hookups on the amount of life left in the current system that would benefit new users and that should be prorated into new rates appropriately.  Similarly, prior ratepayers should be compensated (with lower rates) for sharing any uses for which they had already paid.

RRCSD Sewage Spill History: List of specific SSO failures:  Part 3

This section addresses individual spills over the life of the RRCSD facility. We have probably missed some, but provide enough information to give a good sense of the extent of the problem.

I had different kinds of information on each of the spills.  As time goes on, there has been a substantial increase in the amount of required information for each spill.  Early spills really weren’t reporting nearly as much.  There is now extensive reporting required by dischargers to State and North Coast Board.  This report only addresses SSOs.

June 15, 1985: raw sewage spill

Information from three Press Democrat articles appearing on June 13, 14, 15 as follows:

Guerneville Plant Leaks Sewage by Catherine Barnett and Bony Saludes: June 13, 1985

River Remains Closed by Catherine Barnett, and Carolyn Lund: June 14, 1985

River Declared Safe by Bony Saludes: June 15, 1985

(RRCSD system was less than two years’ old at this point. This was its first spill incident.):

Nearly 4,000 gallons of raw sewage may have spilled into a 12 mile stretch of river near Vacation Beach and the Main Pump Station, temporarily closing the Russian River for 12 miles downstream. (Because of an incident reporting delay, the specific amount of discharge was estimated but never actually quantified.)

A pump had malfunctioned at the Station and the system automatically shut off.  Sewage backed up and leaked through unsealed outlet into a backyard on Riverside Dr.  The spill was not reported until the following day which, it is said, made Ben Kor (Assistant Executive Officer of the Regional Board) very angry.  At the time of the spill, the alarm system wasn’t working because of an earlier parts failure which was out being fixed at the time of the breakdown.  The event occurred during the recreation season. The river was posted as unsafe on a Wednesday and declared safe again the following Friday.

February 18, 1986 flood ranks as the #1 worst of record:This flood lasted about four days and the river rose to 49.5 feet.  It is often referred to as The Valentine’s Day Flood.  In addition, it had been preceded the week before by a raw sewage spill as well.  The flood caused extraordinary devastation in the floodway, but the news reports said little about sewer system failures.  Until 1995, the Building Department was in charge of sewer services.  Even though the ’86 flood was the worst, there were wet winters between that year and 1995 when the Sonoma County Water Agency took over in January, a year in which two major floods occurred in January and March (#2 and #10 respectively).  So it is possible that problems did occur but weren’t publicized.

January and March, 1995: Water Agency takes over wastewater responsibilities this year & two major floods occur:

From Press Democrat – Sonoma County sustained more than $5 billion in damages from megastorms known as atmospheric rivers over 40 years, the hardest hit among 414 counties in 11 western states, according to a new study. The flood-prone county’s economic toll was tops by far, with Lewis County, Oregon in second place with $3 billion in damage, according to the study, which calculated the cost of 1,603 atmospheric rivers from 1978 to 2017. The 1995 storm that inundated Guerneville for three days, pushing the Russian River to its second highest flood level since 1940, was ranked the most destructive atmospheric river in the study period.

Insured losses in Sonoma County exceeded $50 million from the January 1995 storm that also made landfall in Southern California and did $3.7 billion in total damage.

Flood of January, 1995:
From Regional Board Interoffice Communication dated February 3, 1995 entitled: Russian River Flood 1995- Effect on Treatment Works

(The following memo by Regional Board Engineer, Bob Tancreto, covered all Sanitation Districts south of Ukiah.  Noncompliance is only for parts of his report that apply to RRCSD.)

“Effect on Treatment Works”

“The Redwood Empire has had measurable rainfall virtually every day since the beginning of the year.  Starting on January 6, 1995, there were four days of intense rainfall.  Many areas of the basin measured 3 inches per day, or more.  By the afternoon of Sunday, January 8th, flood stage was being approached in Guerneville as well as other locations along the river.  Heavy rains continued through January 9th, resulting in peak flooding in Guerneville in the early morning hours of Tuesday, January 10th.  By the afternoon of Thursday, January 12th, the flood waters had receded to below flood stage.

Additional Rains on Friday the 13th, caused the river to again begin rising and threatening another flood.  The rains slowed and the second river peak occurred on the afternoon of Saturday, January 14th.  Fortunately, the river peaked a full ten feet lower than earlier in the week.”

Russian River CSD in Guerneville:
“Guerneville was being flooded on Sunday January 8th. That afternoon the pump station near Johnson’s Beach was 4 feet underwater and went out of service resulting in raw sewage bypass.  By 3 am the next morning high flow at the plant was causing a partial bypass of secondary effluent around the AWT filters.  About that time there was an area wide power outage which caused all remaining pump stations to go out of service and bypass raw sewage.  This condition remained essentially unchanged until the 17th when the system was back in operation.  We are taking a close look at this system since it was out of operation for an extended period of time and we did receive a complaint about its operation during the flood.”

Quotes from noncompliance reports by Regional Board staff for both January and March, 1995.  Here are some highlights:

Noncompliance for January, 1995 includes:

Extremely high flows entered treatment plant as Russian River flood waters entered the collection system through the lines, isolated by flood waters which prevented operations from controlling the pumps, therefore, all the pumps ran and overwhelmed the treatment plant.

The treatment plant could not handle the incoming flows so portable pumps were set up to transfer water out of the aeration tanks into the emergency holding pond.  Even with these portable pumps running the aeration tanks overflowed onto the ground. 

The emergency holding pond filled and overflowed into the receiving waters.  The partially treated water was heavily chlorinated by hand using “HTH” as best as could be treated.

When the electric power failed at the Main lift station all influent flows stopped.

When the power was restored to Main lift station the flood waters were still over the collection system so all pumps were shut down.  The plant remained out of service until 1-16-95 when the lift stations were re-started.

The high flows were treated with high dosages of chlorine and not de-chlorinated allowing longer contact in the final pond prior to discharge.  The discharge chlorines residual exceeded 0.1 on eleven days.

Other limits that were exceeded were: Turbidity 11 days, also no samples taken during periods of no flow.

As flood waters receded the sewage lift stations were started up and the plant quickly came back into compliance.

Non-compliance for March 1995 includes:

High storm water runoff flooded the collection system for the second time this year.  This resulted in flows into the plant that exceeded the capacity of the system.  Lift station pumping was restricted to control excessive flows into the plant.  The addition to the emergency holding basin.

Chlorine dosages were increased during high storm flows.  Chlorine was hand applied to waters in the emergency holding basin prior to discharge to the receiving waters.  Residuals >0.1 were recorded on eight days.

Turbidity greater than 5.0 NTU were recorded thirteen days as flows and loadings overwhelmed the filter units.

Flows were estimated due to failed meters.

Causes of non-compliance:

The major cause of plant non-compliance was the system flooded out by storm waters.

Flow meters failed due to trash entering the meters.  Meters were also in need of calibration.

Corrective action:

As the river level fell and the system could be brought into full operation that plant and collection system was returned to normal.  Water stored in emergency holding basins was returned through the plant.

Flow meters were repaired and scheduled for re-calibration.

Maintenance is being scheduled for failed equipment to return the plant to full operating condition.

It must be noted that this was Sonoma County Water Agency’s first year on this job.  Over the years they have initially and consistently fought compliance for damage occurring during river floods but have been forced to make improvements that helped the river and the system considerably.  At times government loans and grants were obtained to help fund the projects.  It is a constant conundrum that communities qualifying as low income cannot ever afford all the required repairs and upgrades.   They should regularly be granted funds to make necessary improvements to the system and not burdened with higher and higher rates they cannot afford.

About this same time, the Board of Supervisors was considering joining the West County communities together in order to hook them all to Guerneville (including Forestville, Graton, Occidental, Camp Meeker, Monte Rio, and Villa Grande).  There was a meeting in Forestville with Supervisors and about 200 members of the community there to participate.  Most were opposed to centralization.  There were questions about how costs would be determined, and a lot of queries about what to do about floods.

In a letter of February 22, 1996 about this proposed project (centralization of wastewater treatment in Guerneville),  I asked “Guerneville’s entire system regularly breaks down during major flood events putting it out of compliance with its permit and the Clean Water Act.  How do you plan to address this problem?”  Never got an answer.

May 21, 1996:

Discharge of 201,000 gallons of advanced treated wastewater through irrigation runoff through to Russian River.  Discharges between May 15th and September 30th each year are prohibited.  Cease and Desist Order was prepared and RRCSD is required to submit a report describing short-term and long-term solutions that would prevent such incidents in the future.  Report submitted on March 25, 1997.

28 Day Flood Event of February, 1998

During this month, it rained every day.  According to a list of historic crests on the web (source unknown) the river crested at 36.60 on 2-4-98, 36.04 on 2-7-98, and 32.50 on 2-20-98.  The entrance to Rio Nido floods at 39`’ and I recall that we never lost access to Guerneville on River Road that month.

Yet events out at the Treatment Plant (west end of Neeley Road) turned into a nightmare described in a letter to the Regional Board from Sonoma County Water Agency in response to the State regarding allegations of permit and other violations.

On February 6, 1998, SCWA’s response letter alleged Bypass and Discharge.  Bypass is when a portion of the sewage only received primary treatment.  It was then blended with some of the fully treated tertiary wastewater, but still had vast amounts of bacteria in it.  It was discharged into the river anyway because too much water was coming into the Treatment Plant and things were getting backed up.

On this date there was a large landslide behind the treatment plant that deposited about 175 cubic yards of mud and debris into the storage pond.  By the end of the month, they were to have 29” of rain. (By comparison, Santa Rosa had 19.76”)  They couldn’t fully clear and clean the debris out and “…during the most severe periods, inflow to the plant far exceeded its capacity.  Further, as the flood event continued, sludge buildup and silt from the River plugged clarifiers and filters causing significant operational problems.”  The three crests during this month, listed above, were only the 25th, 29th, and 37th highest floods of record.

Violations identified by Regional Board included: 27 coliform, 2 chlorine residual, 14 suspected suspended solids violation and 1 BOD violations (Biological Oxygen Demand).  It also included failure to sample blended effluent for 6 constituents, discharging other than Advance Wastewater Treatment (AWT), and not meeting median 2.2 coliform level.  SCWA went on to claim that they had no other option but to discharge as they did.  They asked to have monetary penalties deferred to beneficial project on additional storage options.  The alleged items mentioned in SCWA response lists prohibitions.  SCWA treated 1.2 mgd to AWT standards, excess flow (about 1.09 mgd) went to emergency storage pond (1.0 mg).  About 30.5 mg bypassed wastewater directed to pond on 2-1 to 2-28).  They added chemical to disinfect bypass water, blended it with AWT water and discharged it to Russian River. Blended water did not meet water quality requirements.

Regional Board found 28 days of bypass, 24 days of discharge, and discharge volume of about 29.64 million gallons (mg), all illegal.  The introduction to the Staff Report for this item stated that this event was similar to ones in January, 1997, and two in winter of 1995.  Those last two ended in installation of a bypass pipeline which allows diversion to emergency pond of excess sewage and adds control to treatment system and reduces need for emergency pumps.  In February, 1998, 29.61 mg of flood water received primary treatment before being blended with AWT water prior to discharge.

Other things that occurred this month:  lift stations experienced numerous power failures, additional operators and mechanics were called.  Back up generators were used.  On several days, access to plant was blocked because public roads were closed.  Numerous equipment failures were experienced.  Total effluent for the month was 52.78 mg.  This was for a system that produced less than half a million a day of effluent during high summer use periods.   Extensive repairs to the entire plant were needed.  And the flood experienced was only the 25th largest flood of record.

Regional Board staff identified the need for more storage in order to function properly in a flood.  SCWA promised that they were going to begin the process to study sites for more storage.  (More storage was never built but other components of the system were oversized to partially make up for the storage shortage.)  This hasn’t prevented the system from violating their permit since, especially during very high flows.

Regarding the “Ability to Pay” section, SCWA states, “Any penalties imposed as a result of this enforcement action will be paid by the Ratepayers of the RRCSD.  Any penalties paid by the RRCSD will decrease the revenue available for the planned improvements currently the subject of the EIR process.  The RRCSD was charged with bypassing advanced treatment and resulting discharge of 30 MG of partially treated wastewater.  Order directed RRCSD staff to develop short-term and long-term solutions to prevent illegal waste discharges.

Order 1998-1983:

Feb. 1998: Bypass of 30 mg of partially treated wastewater into RR

Feb. 1999: Watson Lift Station spill 2,400 gallons sewage spill into RR tributary

Bypass at treatment facilities and resulting discharge of 30 MG of partially treated
wastewater into RR  (primary water blended with AWT water prior to discharge). This was the February where it rained every single day and there was a big landslide at the treatment plant on February 6th with about 50 yards of debris ending up in the main
storage pond. That month saw 29” of rain fall in Guerneville.

Apr. 1999: Drake Lift Station: 99,000 gallons to RR (human error and mechanical  failure)

Sept. 1999: Intentional bypass of 1.41 MG untreated wastewater

Discharge of 1.125 MG partially treated discharge to RR

Watson Road Incident: February, 1999

The RRCSD and the SCWA discharged an estimated 2,400 gallons of untreated sewage from the Watson Road lift station to a tributary to the Russian River.”  They also discharged “…an estimated 99,000 gallons of untreated sewage from a lift station on Drake Road to the Russian River.” The latter spill was in April of the same year. The Drake Road spill was, “….a result of human error and a faulty Mechanical high water alarm system.”  (Complaint No. 99-52 For Administrative Civil Liability dated July 22, 1999) That same month and year they “…bypassed 1.41 MG around the AWT treatment process and discharged approximately 1.123 MG of partially treated wastewater into the Russian River after receiving excessive inflows from elevated river water in February, “1999. (Administrative Civil Liability Order #92-51)  Staff went on to enumerate event details of each of the spills and the specific prohibitions violated.  1.125 MG of the 1.41 MG was discharged into the river.  There were also 3 coliform violations, 1 total suspended solids violation and 2 turbidity violations.

Some staff criticisms regarding Watson Road situation included the following:

  • SCWA took an excessive amount of time to stop the spill.
  • SCWA did not have on-call staff to respond to emergency events. Most municipalities pay a staff person to be on call.
  • No cleanup of surface waters was conducted.
  • Staff did not sample Russian River to determine if it was adversely impacted by the spill.

At the July 22, 1999 evidentiary hearing on this matter, the Board ordered an ACL complaint in the amount of $140,000.   $40,000 was to be paid within 20 days and $100,000 will be suspended upon satisfactory completion of a Supplemental Environmental Project.  The latter included completion of the RRCSD Collection System Study and the emergency storage reservoir’s capacity.  They were also to develop a sewer user ordinance that develops a clear enforcement policy and includes penalties for violations.  They were also to develop and distribute a public information brochure and finally develop  a regular preventive maintenance program.  All of these items had deadlines and if not completed in time, the suspended  monetary penalties would be enforced.

Drake Road incident: April, 1999 :

  • Unsatisfactory communications between SCWA staff and Regional Board regarding initial spill incident beginning on April 27th where Regional Board staff were informed that spill was estimated at 2,000 gallons.
  • About ten days after an initial phone call regarding the event (May 6th), during a meeting about a different spill, Regional Board staff learned that the Drake Road overflow had happened over several days and was now estimated at 100,000 gallons.

Bypass and illegal discharge into Russian River:

  • As noted above: bypassed 1.41 MG around AWT treatment process which is not allowed.
  • They discharged approximately 1.125 MG of partially treated wastewater into Russian River

Regional Board is issuing this complaint with a suggested penalty of $50,000. This included the possible suspension of $45,000 if SCWA did the following.

  • Develop a Supplemental Environment Project which would include a comprehensive spill response and notification plan to be used by all SCWA operations in the region and this is to be developed by an outside consultant.
  • They included deadline dates and more details on what needed to be done in order to comply with this order.

Administrative civil liability (ACL) Complaint:

October, 2004:

Oct. 24, 2004: 14217 Armstrong Woods Rd.  30 gallons recovered from SSO violation

March, 2005: 

Old Monte Rio Rd. between manhole 46-8 and 46-9: 165 gallons (about 15g recovered)

May 25, 2005: Leak in Lower Irrigation reclaimed water pipeline into RR tributary 2,400 gallons

Dec. 5, 2005: Leak to lower irrigation field, unknown amount, out of season discharge

April, 2006:

4-20-06:  Old Monte Rio Rd. between Manhole 46-8 and 46-9: 480 gal (about 200 recovered)

1-16-07:  Old Monte Rio Rd. between Manhole 46-8 and 46 -9: 46 gallons (about 16 recovered)

R1-2003-0026 : Between Oct. 2004 and Jan. 2006 penalties were total $74,000.

This was the time that the Third Unit Processes Project was built.

ACL: Order No. R1-2008-0045: During period of 10-1-04 and 5-31-07 there were 6 prohibited discharges with 4 SSOs. Penalty was $21,000.  (Many other violations brought total penalty to $99,000.)

August 9, 2007:

16315 Watson Rd.  74 gallon spill resulting from malfunctioning pump with spill ending up in the street, but did not reach waterway.

December 22 2008: Spill of 15 gallons between manholes 46-8 and 46-9 on Old Monte Rio Rd. did not reach waterway. $45,000 penalty for 2007 and 2008 spills.

May 23, 2010:  Release of 300,000 gallons of treated wastewater outside of discharge period to RR due to worker error at discharge pond.  9 days outside of discharge season.

February 12, 2014: Order No. R1-2016-0022: force main crack near air valve allowing raw sewage leak near Vacation Beach lift station.  Next day workmen returned to site and discovered that leak was worse. After they started work on it, the force main pipe fractured and discharged to river. There was an estimated spill volume of 132,000 gallons.  Penalty for this spill and prior one was $275.771.  Compliance project allowed $67,885 plus $135,000 suspension.  Promised force line assessment within 5 years.  The compliance project was a tertiary filter upgrade.  The $135,000 would go towards that project.

On page 6 or Order No. R1-2014-0034 there was a statement that more work on the Collection System pipeline was needed and: “The Permittee anticipates that large investments to the collection system are needed to reduce the potential for catastrophic damage and threats to public health and the environment from a large-magnitude earthquake.”  At that time it was estimated that corrections to the collection system would cost from $10 to $20 Million.  Current estimates for Lift Stations is $50M or more.  That was about the time that SCWA constructed the UV Disinfection System and they could not afford both projects.

February 12, 2014: Hazardous Materials Spill:

There were also failures at the other side of the river by the Main Pump Station on Hwy 116 and Riverside Drive.  Interestingly, these two areas that have seen the most problems  over the history of the system. There was a sump pump failure which started a leak and another manhole started to backup. (don’t know if the two occurrences were connected to one another) It appears that the spill in this event was around 1,450 gallons and a different report indicated another spill of 10,000 gallons.  Some of this material did not reach the river and much of it was pumped to a different location.  Therefore the amount of material that entered the river will be researched and reported when available.

February 13, 2014:

A ruptured sewer main in Guerneville discharged an estimated 100,000 gallons of raw sewage into Russian River before leak was stopped and repairs begun.  A 16” concrete pipe, about 4’ underground had ruptured on February 13th at Beach and Orchard near the Vacation Beach Pump Station. A 5’ crack had opened up, allowing sewage to spill at about 40,000 gallons per hour. The leak was stopped a few hours after discovery; the pipe was found to be rotten and there was erosion at a joint where they found steel on steel and no seal in between. The sewage ran down hill towards the river about 40 yards from the spill.  High flows, caused by heavy rain, exacerbated the situation.  The Regional Board was called and staff determined that there were no immediate threats to public health or the environment. It was determined that this area is very vulnerable to repeat failures and the Water Agency was to find a means to assure that the problem does not continue.  It was anticipated at this time that large investments would be necessary to address the problem.

A later assessment by the State determined that the amount estimated to have reached the river was actually 134,000 gallons.  It turns out that methods for estimating amounts of sewage (treated or otherwise) have become a lot more sophisticated over the years.  Now there are many factors determining how one arrives at that amount used to determine the size of the penalty.

February 27-March 2,, 2019: Major Spill at Main Pump Station & significant spills at Vacation Beach

We have attached our Complaint on this spill, which is probably one of the worst, to the email that contains this letter.  You can read many details in that document.  We hope to get a few pictures on there as well.  Furthermore, we intend to also attach the report of violations sent in April, 2021.  Those two documents give a good picture of the extent of the violation.

Various breakdowns and spills along HWY 116 in Nov. & Dec., 2021….

The day before Thanksgiving, 2021:  These were very small and did not reach a waterway.  Nevertheless, they indicate more signs of the deterioration of the pipeline.