May 17, 2008
Glen Wright
City of Santa Rosa
100 Santa Rosa Avenue
Santa Rosa, CA 95402
Comments Concerning the Discharge Compliance Project Draft
Environmental Impact Report (DEIR)
These comments are made on behalf of the Clean Water Coalition of
Northern Sonoma County (CWC-NSC). The purpose of the CWC-NSC is to
ensure that water infrastructure projects protect and preserve the natural
resources, agriculture and scenic character of Northern Sonoma County.
Members include the Alexander Valley Association, the Bishop’s Ranch, the
Dry Creek Valley Association, the Russian RiverKeeper, the Soda Rock
Neighborhood Association and the Westside Association to Save
Agriculture. We represent citizens who live in the Alexander, Dry Creek,
and Russian River valleys and who depend on high-quality groundwater
supplies for drinking, domestic uses and agriculture.
Our analysis of the Discharge Compliance DEIR indicates that it is
inadequate to support any discharge of wastewater into the Russian River
without additional treatment to remove soluble contaminants. The
wastewater contains high levels of copper, lead, nickel, cyanide and very
high levels of both nitrogen and phosphorous nutrients. It contains selenium
at levels close to those toxic to fish, mercury at levels close to those toxic to
humans, and boron at levels close to those toxic to grapevines. It contains
very high levels and high variability of soluble organic contaminants as
indicated by the TOC of as high as 60 mg/l. The total of all soluble organic
compounds that have been identified and quantified by analysis accounts for
less than one percent of the TOC. Thus, the overwhelming majority of the
TOC is organics which have not been identified. However, data from others
who have been willing to identify much of the TOC in their wastewater
indicates that many of these unidentified soluble organics are certainly
emerging contaminants such as pharmaceuticals, personal care products,
plasticizers, and pesticides. Some of these emerging contaminants have
been shown to be endocrine system disruptors and to have chronic human
health impacts and impacts on salmonoid species at very low levels. These
contaminants must be identified before the impact of the discharge of this
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wastewater into the Russian River on surface water quality, groundwater
contamination, public health and biological resources can be defined.
The analysis of the soluble organic chemicals comprising the high level of
TOC in wastewater to be discharged upstream of drinking water wells and
into salmonoid habitat is clearly inadequate. We question why additional
analysis has been avoided. We recommend that Santa Rosa carry out
analysis of the wastewater for pharmaceuticals, endocrine chemicals, and
other indicators of municipal wastewater as specified by the California
Department of Health Services in its Draft Regulation for Groundwater
Recharge Reuse, Article 5.1, Section 603020.047 (a) (3) and Endnote 5
published January 4, 2007. This analysis would provide at least an
indication of presence or absence of soluble organic chemicals with potential
public health impacts and help define additional work required.
The DEIR concludes that discharge at the Alexander Valley Road Bridge
(D4) would contaminate surface water and groundwater to a degree
sufficient to create a public health hazard in the Healdsburg water supply. In
fact, the BPU decided on May 15, 2008 to eliminate D4 from the DCP on
the basis of the unavoidable impacts which would occur. We certainly agree
that this was appropriate. However, the BPU decision and the DEIR also
conclude that these impacts will be avoidable at other river discharge
locations (D3 and D1). We disagree. We do not believe that the DEIR
contains sufficient facts to support this conclusion. It is based on many
questionable and complex assumptions, approximations, and models.
The many assumptions, approximations, and models which lead to the
conclusions that surface water contamination and groundwater
contamination by discharge at D3 or D1 will not cause significant impacts
on public health or salmonoid species include the following:
1. Upstream indirect discharges of secondary treated wastewater by others
including Cloverdale, Geyserville, and Healdsburg are considered to provide
the same level of contamination as direct discharge of tertiary treated
wastewater (page 4.6-86, Table 4.6-39). This assumption is highly
questionable based on information contained in TM I-3 which indicates that
the soils in the Russian River valleys do not significantly attenuate organics
remaining in the wastewater.
2. The DEIR fails to identify and study discharge impact on all drinking
water sources within one half mile of proposed discharge locations as
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requested in the CDHS letter dated September 2006 (DEIR Appendix A).
Furthermore, the cursory analysis of potential impacts on non-municipal
wells contained in TM I-8 uses a “screening-level analysis where the local
hydrological budgets are developed on assumptions rather than a sitespecific analysis” (Section 4.5, p.31. See also extensive discussion in the
comment letter from Nicholas Johnson in 2. Vulnerability of Non-Municipal
Drinking Water Wells.)
3. The DEIR assumes that river percolation to groundwater in the discharge
season is relatively unlikely along some gaining reaches of the river based
on a conceptual model of gaining and losing reaches along the Russian River
(Figure 15, TM I-8. See also extensive discussion in the comment letter from
Nicholas Johnson in 2. Vulnerability of Non-Municipal Drinking Water
Wells.) This assumption is speculative and is not supported by April, 2008
facts from the Sonoma County Water Agency which indicated that extensive
pumping from wells adjacent to the river for frost protection significantly
decreased river flows. It is clear that this extensive pumping created a losing
stream and created significant gradients of flow toward frost protection
wells. These gradients could have impacted domestic drinking water wells
in the vicinity to a far greater degree than assumed in the DEIR.
4. The DEIR presumes for some undefined reason that the threshold for
concern for human health impacts for non-municipal wells is 10%
wastewater (See the extensive discussion of this assumption in the comment
letter from Nicholas Johnson in 3. Determination of Potential-Impact
Significance). We believe this is a non supportable presumption.
5. The DEIR totally discounts any human health impacts from the
unidentified soluble organic contaminants on the basis that they are currently
unregulated. This is an inappropriate conclusion. Lack of regulation does
not equate with lack of impact. The DEIR is to analyze potential impacts
irrespective of status of current regulations.
6. The DEIR concludes that discharge at any of the River sites will not cause
impacts to endangered or threatened fish. This conclusion appears to be
based on the fact that there is no evidence of such impacts to date. However,
it also appears that there has been little effort to determine if there will be
impacts and there is essentially no evidence to the contrary. Meanwhile,
such impacts have been demonstrated in other locations with other tertiary
treated wastewater (See the extensive discussion of this subject in the
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comment letter from Daniel Schlenk, Professor, Aquatic Toxicology,
University of California, Riverside).
7. The DEIR fails to consider the cumulative impacts on surface water
quality, groundwater quality, public health and biological species of
decreased flow in the Russian River from the proposed and highly likely Dry
Creek Bypass Pipeline Project and the North Sonoma County Agricultural
Reuse Project. Both of these projects proposed by the Sonoma County
Water Agency are being studied in Environmental Impact Studies and are
beyond speculative.
In conclusion, we believe that DEIR conclusions of no significant impact on
human health or biological species from discharge at D3 or D1 are not
supported by facts. We believe that the FEIR must contain more substantial
studies and data in order to reach these conclusions.
Thank you for the opportunity to comment.
Fred Corson
Chairman
Clean Water Coalition of Northern Sonoma County
PO Box 1636
Healdsburg, Ca 95448-1636
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