RRWPC
Russian River Watershed Protection Committee
P.O. Box 501
Guerneville, CA 95446
September 22, 2024
RRWPC’s Preliminary Comments on: Draft MR/VG Wastewater Solutions Project
Alternatives Development and Analysis
Introduction:
This initial study is limited in scope, as required by the consultant’s contract, and appears to be a mostly honest attempt to portray the benefits, liabilities, and scope of the project. We say ‘mostly’ as we rate the section on septic system options as very well done, and the section describing ‘collection system types’ on MR/VG District properties as adequate, although our expertise to judge is limited. (pages 23-26) The part we have great concern about however, is the infrastructure leading to RRCSD located outside of the district and connecting MR/VG to that facility. ( page 27 etc.)
We describe our general concerns in the remainder of this letter, but will provide evidence at a later time when we delve into more detail about project inadequacies. These have already been brought up in past CAG meetings where we discussed degraded and limiting conditions at Russian River County Sanitation District. These issues have been well documented by RRWPC, reported to the CAG and the involved agencies and, if this project is constructed without their adequate consideration, may cause further NPDES permit violations that make RRCSD the worst permit violator of the 19 dischargers into the Russian River.
Our comments in this document will exclusively address MR/VG potential hookups to the Russian River County Sanitation District (RRCSD) since we believe that other members of the CAG are far more versed than we are regarding the pros and cons of individual and community septic systems. In addition, it appears that the varieties and features of septic applications available are far more familiar to the consultant than conditions of the local central sewage treatment facility. While RRCSD facilities inadequacies have been documented in detail, few are acknowledged or described in this document. Also there is no acknowledgement of the affects this project would have on current rate payers of the system and the system as a whole. A lot more work needs to be done to address this problem. Ultimately, the joining of three communities in this facility needs to be seen as an integration process and not an additive one.
We do have a question we will mention here. The boundaries of the MR/VG District are drawn to include vast expansion areas to the northeast, and the southeast and southwest. Why are those boundaries so large? The ability of RRCSD to expand will likely be constricted by the environment and would not be able to serve more than the 10% expansion factor added in. Also, we are not sure it can handle the 10% and we do not believe that you fully demonstrated that it can. It is my understanding that when the RRCSD was set up, it mostly included developed parcels, except where empty lots were surrounded by developed parcels. They did not include vast undeveloped areas for which the argument for expansion can later be made.
- Background:
Parcels are analyzed on the basis of whether they produce septage or not. (On page 2 the term ‘wastewater’ is used to allude to the initial waste product needing to be managed. In my experience, raw waste is usually called by numerous other terms other than ‘wastewater’, which generally denotes the end ‘water’ product after treatment. Would ‘septage’ or ‘sewage’ better describe the first phase of the process that separates liquid and solid waste and disposes of each separately?)
We also wonder how potential conversions of developed parcels that do not currently produce human waste to ones that do would be addressed? Does the 10% growth factor account for this potential additional flow? Again, we are very concerned about the vast amount of vacant land included in the new MR/VG District. If these communities joined with RRCSD, would there be a new district formed at which time those vacant areas could be removed from the district? Would there be a vote conducted of all owners approving or disapproving of the new District? Water laws require that sewage be treated to a high level no matter what weather conditions are.
3.2 Centralized Sewage Collection System Alternative (p. 23)
Two types of collection are described: gravity and pressurized systems. (RRCSD is gravity and consultants recommended that MR/VG collection system would be of a different design.) Consultants assumed that MR/VG would be a more desirable low pressure system because it is much easier to install. But how do low pressure systems perform during great floods and also on steep slopes? Are the soils strong enough to hold together under all weather conditions?
On page 26 in second paragraph it states that electricity costs for grinder pump would run about $4 a month. It sounds grossly underestimated when one thinks about winter electric bills that can run $200-$300 a month or more in winter without a pump. What is the propensity for line breakage during severely inclement weather conditions, especially if in a shallow area? What can happen in areas where water floods through houses and flows go through the plumbing system? (There seems to be an assumption that the kind of system described because of pipeline size and materials that infiltration and inflow won’t be a problem.) Finally did the assumptions about flood plain inundation levels look at actual floods of 1986 and 2019? And what happens to the system when outages last longer than two days?
3.2.2 Project Description (P. 27)
On this page it states that, “Likely two centralized main lift stations would be required to serve the Study Area, one on either side of the Russian River. The crossing of the Russian River and Dutch Bill Creek would occur in casings under the existing bridges.”
It appears that the project intends to use force mains on both sides of the river, including in proximity to the Main Pump Station and the Vacation Beach Pump Station (on either side of the river) in order to transport the wastewater to the treatment plant in the underground river pipeline. All of these facilities transport about 90% of the total sewage from the entire RRCSD system. There is a fraught history of breakdowns in all of these facilities, especially during large floods, yet nothing is mentioned about their current condition in this project description. In our view, that is a major flaw of this work.
Evidence of these problems won’t be provided at this time, but many of our comments on this topic can be found at our website at www.rrwpc.org . There have been six major floods in the years since RRCSD was put on line. At least half of them since 2014, have resulted in major spills. According to a chart produced by the Regional Board, between 2007 and 2017 the RRCSD illegally discharged five times the amount of partially treated wastewater than 18 other dischargers to Russian River altogether (including Santa Rosa).
Nothing is mentioned about the problematic condition of the main pipeline transmitting raw sewage across the river itself (from Main Pump Station to Vacation Beach) Then there is the mysterious unused pipeline close to the irrigation pipeline transporting fully treated wastewater to the golf course for irrigation. The exact location is not clear in the text and does not appear on maps and the condition of the unused pipeline crossing the river is unknown. Much more information is needed about that pipeline if it is to be seriously considered for this project. The irrigation pipeline from the treatment plant to Northwood Golf Course is not to be used for untreated waste. It is used every summer for golf course irrigation. (Someone stated its really a stub near the irrigation pipeline.) How can you come up with a meaningful assessment of costs and viability if you don’t know anything about that essential pipeline? That would be a major expense.
It is clear that consultants intend for the two communities to utilize the force mains and lift stations at the west end of the RRCSD collection system. About 90% of the raw sewage from the entire system are serviced by these force mains and the associated pump stations on either side of the river: Main Pump Station and Vacation Beach. They both have a lengthy history of serious failures, especially during major floods such as 2014, 2017 and 2019. RRWPC has provided extensive information about this on our website at www.rrwpc.org.
This initial study does not describe what impacts will occur if additional load from two communities is added to the current infrastructure. It does not identify the needed expensive infrastructure repairs described by West Yost consultants, and it does not address implications for current ratepayers, either in terms of potential system failure and likely associated costs to those who are currently paying some of the highest utility rates in the County. It is essential that system failures of pumping and loading that have yet to be fully repaired, be thoroughly addressed and also fully revealed to the communities who want to be added to the system. (See Figure #11) They are expected to be in the $50 Million range and yet loans from the State have not been forthcoming. How could you account for that scenario. It would seem to put all options on a level playing field. (If Trump wins election, there probably won’t be funds for any project.)
The route traveled to the RRCSD by the raw sewage as shown on Figure #11, gets to the Vacation Beach Pump Station. This area has been in very bad condition. A few years ago about 800’ of pipeline was replaced but we don’t know much about it’s capacity or the condition of the related equipment. That pump station has had numerous failures as has the underwater segment of the pipe which had a major break in 2014. We believe that the viability of the entire structural facility in this area and the area of the Main Pump Station, must be fully analyzed under all conditions before being assumed viable for much greater loading. It is subject to surging manholes during floods. They replaced some of the pipeline in this area but we don’t know how it can handle major flooding AND flood flows in the pipelines from two new communities. (This Study does not describe much about the condition of these facilities and added flow that will be used in conjunction with current users.) In general, the basis for facility adequacy used for projecting costs, is very weak.
We also request an analysis (environmental and cost) of combined flows be addressed in regards to impacts to these vulnerable facilities and the new impacts on current users, especially during major floods. In addition, we believe there should also be a hazards analysis for both communities if there should be a major breakdown of either or both systems during flood periods and emergency remedies provided. Perhaps your contract does not require this, but it should. Any merging will have real impacts on current users that need to be revealed and addressed.
Finally, it’s not clear to me exactly where the MR/VG pipeline that parallels the irrigation pipeline will connect to the treatment plant. On Neeley Road there is almost a mile of homes that could not hookup to the Treatment Plant because of the high pressure in the pipeline as it gets closer to the plant. (At least, that’s my understanding of the situation.) So how could MR/VG loading occur there. Can you be more precise about where it enters the TP and give a diagram? How would that work in with the other facilities at the plant?
Similarly, on page 29 several disposal issues that the Water Agency (operators of RRCSD) are working on are mentioned, and it is stated that that has nothing to do with this current project. And I totally question that assumption. It may have a major impact on current ratepayers and we don’t know why that should not be considered in this current document.
On page 30 you provide cost figures. Who pays for installation of grinder pumps? Are the property owners responsible for installation? Who pays for lateral pipelines?
Miscellaneous Issues:
Page 36:
I don’t think you mention anywhere what will happen if water gets in drains of houses that take water during a flood. This has caused a great deal of inflow and resulting flood problems in Guerneville.
There is a statement claiming that the grinder pump solution is less likely to cause flooding. That isn’t the same as saying its UNLIKELY to cause flooding. Much of Guerneville’s flood water comes from inundation of houses in the flood plain. (Does MR/VG not have any of those?)
Ernie Carpenter was Supervisor when RRCSD was being built. Ask HIM if building RRCSD was easier than installing a septic system with grinder tanks.
The statement is made (p. 37) that it’s much easier to obtain government funding to build a sewer than install septic systems. Generally that may be true. But ask Sonoma Water how easy it’s been to get loans to fund major repairs needed and they may paint another picture. And if the male candidate for president gets elected, forget about funding anything for at least four years.
RRCSD ran into trouble recently with a generator going out of commission and a violation occurred. It might be beneficial to get information from Sonoma Water directly as to the history of generator problems during outages.
I wrote a paper that’s on our website (top of side bar on main page) that tells a story of RRCSD construction. Or even better, you can consult with Ernie Carpenter. It was a nightmare. Costs ended up more than double the original estimate. The collection system was a mess and much had to be redone. And more…..
Finally, what bothers me about this is that the project you prefer is painted to be much rosier than the one you reject. I think either one will be extremely difficult and a lot more study (like a well done EIR) should go a long way in painting a truer picture.
Brenda Adelman