THE IRWP

The Incremental Recycled Water Project (IRWP) is a plan to dump "treated" sewage in the Russian River, the Geyers hotsprings and also in large, open reservoirs. This "treated" water, which is dangerous, will then be used for agricultural irrigation, watering lawns, and other domestic uses that do not require potable water. The IRWP represents an agreement between the cities of Santa Rosa, Rohnert Park, Cotati and Sebastopol. All these cities have accumulated an embarassing amount of sewage that requires disposal, an avoidable problem created by excessive growth that ignored the water balance of supply and demand.

How dangerous is this? The Russian River is also Sonoma County's largest source of fresh water. Three of the planned dump sites are above Sonoma County Water Agency ("SWCA") collectors for drinking water.

The plan also ignores recent scientific discoveries that demonstrate wastwater is a source of emerging toxicants. In other words, wastewater itself is creating entirely new poisonous compounds by combining the danerous material it necessarily contains.

Below are O.W.L.'s comments and questions to the Board of Public Utilities of Santa Rosa for the scoping session of the IRWP EIR.

8/28/06

Chairman Richard Dowd
Santa Rosa Board of Public Utilities
100 Santa Rosa Avenue
Santa Rosa CA  95404-4906

Comments for the IRWP Scoping Session

Dear Chairman Dowd;

Thank you for this opportunity to comment on the City of Santa Rosa’s (“City”) proposal to discharge waste into the Russian River. The O.W.L. Foundation (“O.W.L.”) submits this letter providing written comments for the City’s scoping session on the Incremental Recycled Water Program (“IRWP). We have structured this comment letter with numbered questions, and we are requesting that the City prepare its responses in a form that corresponds to our numbered paragraphs.

Considerable Concern

It’s important to bear in mind that water is a finite resource and that pure, fresh drinking water is recycled water—that’s what nature does; it recycles polluted water to make fresh water. The water that comes out the nether end of a sewage plant is polluted water, not recycled water. The use of the word “recycled” in the IRWP nomenclature is misleading and gives the impression that wastewater is somehow safe enough to dispose in a public drinking water supply, like the Russian River. Wastewater is not potable water; it contains numerous toxic compounds and by definition is therefore not recycled water.

Worse, there is a growing understanding in the scientific community that the varieties of toxic compounds found in so-called treated wastewater interact to produce wholly new toxic compounds.

The O.W.L. Foundation is concerned about the proposal to dump sewage into the Russian River. The Russian River is the largest source of freshwater for Sonoma County. In the past, dumping treated sewage into this major artery was deemed acceptable, but today dumping should be considered a clear public health risk in light of recent research. Perhaps the foremost concern is the likelihood of contamination due to insufficient understanding of chemical interactions occurring in so-called “treated” sewage water.

A Common Pain Remedy Rendered Harmful

Acetaminophen is one of the most widely consumed drugs in the world. When taken according to directions, Acetaminophen is a relatively safe drug. However, exceeding the recommended dose, or if taken with alcohol, Acetaminophen can cause hepatic failure. Indeed, this common drug is the leading cause of liver failure in both the U.S. and in the U.K.

Scientists were alarmed to discover in 2005 that Acetaminophen and sewage plants pose a completely new danger, two new dangers in fact. When exposed to the chlorination process, Acetaminophen spawns two entirely new toxicants, 1,4-Benzoquinone and N-Acetyl-p-benzoquinone Imine. I am attaching the results of a study performed by Mary Bender and William A. MacCrehan of the Analytical Chemistry Division, National Institute of Standards and Technology in Gaithersburg, MD that describes this transformation.

It’s important to note that the city of Santa Rosa does not rely on the chlorination process in any significant way. However, the whole point of this surprising study is that it proves that unwanted and unsuspected chemical reactions are taking place within wastewater and that these wholly new toxic compounds can proliferate into the environment. This recent discovery underscores the necessity for extensive testing before wastewater is dumped into a drinking water supply. Most of the contamination in a discharge event does not necessarily dissolve in river water, much of it settles into the sediments below, exactly where children might squish their toes.

1. How much Acetaminophen, in parts per billion of wastewater or in total metric weight does the City estimate will be dumped into the Russian River according to current discharge proposals?

2. How much 1,4-Benzoquinone and N-Acetyl-p-benzoquinone Imine, in parts per billion or in total metric weight, is created as a result of the chlorination process in treatment plants in a one year period?

3. How much 1,4-Benzoquinone and N-Acetyl-p-benzoquinone Imine in parts per billion or total metric weight does the City estimate enters wastewater that has been created by domestic chlorination units? How much is created by exposure to household cleansers that contain chlorine? What test has the City used to determine this quantity? If not tested, please explain why not.

4. How much 1,4-Benzoquinone and N-Acetyl-p-benzoquinone Imine does the City estimate will be discharged into the Russian River in any one-year period?

Acetaminophen, also known as Paracetamol,  is sold under the brand name “Tylenol” in the U.S. and “Panadol” in the U.K. It is a common additive to other analgesics making the drug nearly ubiquitous.

Dangerous Drugs in Wastewater

A wide range of pharmaceuticals exists in wastewater, not just Acetaminophen. Reports from all over the world affirm that drugs, both legal prescription drugs and illegal drugs, even veterinary drugs, are not removed from sewage treatment plants and are reintroduced into the environment. In northern Italy, in the Po River Basin, authorities test Po River water for both the excreted metabolite byproduct of cocaine, and for pure cocaine itself that is not metabolized to calculate the estimated levels of abuse of this drug in the population living in the basin.

5. Has the City performed scientific examinations to detect pharmaceuticals in wastewater? If so, what were the results of that test? If not, why not?

6. How much benzoylecgonine (BE), cocaine, and diacetylmorphine, in parts per billion or in total metric weight does the City estimate will be dumped into the Russian River drinking water supply via the proposed discharge schedule? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

7. How much Ethinylestradiol, Levonorgestrel, and Norethisterone does the City estimate will be dumped into the Russian River drinking water supply via the proposed discharge schedule? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

8. Does the City intend to dump other estrogens or progestagens into the drinking water supply? If so, which ones and in what amounts does the City plan to dump in the water supply? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

9. How much interleukin-4 PE38KDEL cytotoxin does the City estimate is in the wastewater, in parts per billion that will be dumped into the Russian River? What does the City estimate are the amounts of other cytotoxins, in parts per billion that will be dumped into the Russian River? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

Phthalates

Phthalates are dangerous endocrine disruptors that can feminize unborn males, male neonates and young boys by mutilating male genitals. They are strongly suspected to be an underlying etiology of the dramatic rise in breast cancer and in the worldwide phenomenon of falling sperm counts. Exposure to phthalates also trigger early menarche and breast enlargement in girls as young as 10 years old.

Phthalate esters are additives used mainly as plasticizers to add flexibility to polyvinyl chloride (PVC), polyvinyl acetate, polystyrene, cellulose nitrate, polyamides, and polyesters.  Phthalates serve as intermolecular lubricants that impart flexibility. But these chemicals lack a covalent bond and are not chemically bound to the polymer and as a result, easily migrate into the environment in significant quantities. Phthalates are also found in soaps, shampoos, paints, pesticides, nail polish, caulk, and other common products. In light of the inability of Sonoma County treatment plants to remove these endocrine disruptors they must be presumed to exist in wastewater.

10. How many parts per billion of Di(2-ethylhexyl) phthalate (DEHP) does the City expect to dump in the Russian River drinking water supply? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

11. How many parts per billion of Di-butyl phthalate (DBP) does the City expect to dump in the Russian River drinking water supply? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

12. How many parts per billion of Di-isononyl phthalate (DINP) does the City expect to dump in the Russian River drinking water supply? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

13. How many parts per billion of Di-isodecyl phthalate (DIDP) does the City expect to dump in the Russian River drinking water supply? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

14. How many parts per billion of Benzyl butyl phthalate (BBP) does the City expect to dump in the Russian River drinking water supply? If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

15. Will any phthalate discharges into the Russian River drinking water supply exceed 6 parts per billion? If so, please explain why this level exceeds the Environmental Protection Agency’s Maximum Contaminant Level (MCL) set for phthalate contamination in drinking water. If no estimates have been made, please explain why this examination was skipped or deemed unnecessary.

An Exaggerated Need

The City’s ambitious proposal to dump 4.5 billion gallons of sewage into the Russian River is an extraordinary leap beyond past practices or needs. Last year during one of the wettest winters on record, the City dumped 1.3 billion gallons of sewage into the river. The request to sharply escalate contaminates in the Russian River drinking water supply is unjustified and unnecessary.

Three of the proposed discharge sites are scenic areas frequented by holidaymakers: Healdsburg Beach, Riverfront Park and Steelhead Beach. Spreading the above-mentioned contaminants in areas where young children would most likely be exposed to them represents a serious public health risk.  As noted above, children are by far the most susceptible to hormonal manipulations and the most obvious victims of genital mutilation, in little boys, or early-onset puberty in little girls. 

16. Has the City performed any studies focusing on the potential for lowered sperm counts, the feminization of young boys or the early onset of menarche in very young girls due to exposure to phthalates discharged by the City of Santa Rosa into Russian River tourist beach areas? If no studies have been conducted, please explain why this examination was skipped or deemed unnecessary.

17. The three above-mentioned direct discharge sites also sit above water collectors operated by the Sonoma County Water Agency (“SCWA”). Has the City performed any tests to estimate the potential for disfigurement of young boys or the effects of xenoestrogens on very young girls due to exposure to SCWA drinking water removed from this area of the Russian River? If no studies have been conducted, please explain why this examination was skipped or deemed unnecessary.

18. Moreover, the City apparently has failed to address the possibility that two or more of the contaminants in its wastewater will combine chemically to create new compounds, as the Bender MacCrehan study demonstrates. The possibility of unintended chemical reactions taking place in such a “witches brew” of chemicals is high and unexpected impairments should be anticipated and avoided before irrevocable physical damage occurs. If no such studies have been conducted, please explain why this examination was skipped or deemed unnecessary.

At the very least, we urge the City to perform the necessary tests prior to discharging any wastewater into public sources of clean water.

The Solution to Pollution is Restitution

There is a simple way to prevent these dangerous chemicals from entering the Russian River and spreading throughout the environment: remove them. Modern treatment plants are able to remove everything in wastewater that is not water. In other words, all chemical compounds that are not the molecule H2O can be taken out of sewage water. The plant in Fountain Valley, CA, serving Orange County does this with micro and nano filtration systems; reverse osmosis and exposure to ultraviolet light and hydrogen peroxide. Indeed, the only health inconvenience with the water coming out of a modern treatment plant is that it lacks minerals because every molecule that is not H2O is taken out.

A modern sewage plant has several striking advantages for the City, by far the most important of which is that the product is safe and not a public health risk. A clean water product has a high monetary value because it is pure. It can even be used in injection wells to restore the overdrafted Santa Rosa Plain Groundwater Basin. The system is drought proof and will produce as much clean water during a prolonged drought as it does during monsoon conditions.

Trying to save money by not cleaning sewage to the very best of our abilities, and then dumping partially cleaned sewage back into a public water source elevates frugality to the level of a psychopathology.

We look forward to receiving the City’s written responses to our comments.

Sincerely,

[original signed]

President, O.W.L. Foundation

Attachments:

U.S. Environmental Protection Agency, Consumer Fact Sheet ion DI (2-Ethylhexyl) Phthalate, 4 pages

Presence of Pharmaceuticals in Wastewater Effluent and Drinking Water, Metropolitan Atlanta GA, July-September 1999, 1 page

Chemical and Engineering News: Panel Ranks Risk of Common Phthalate, 7 pages

Newscientist.com: “Gender Benders” cause sperm burn out, 2 pages

Guardian Unlimited: Chemicals in Plastics harming unborn boys, 2 pages

Environment California: Phthalates Overview, 8 pages

Silent Spring Institute: Breast Cancer and the Environment, 2 pages

New Scientist.com: ‘Safe’ painkiller is leading cause liver failure, 2 pages

Postgraduate Medicine: Alcohol-acetaminophen syndrome, 10 pages

Transformation of Acetaminophen by Chlorination Produces the Toxicants 1,4-Benzoqinone and N-Acetyl-p-benzoquinone Imine, 2 pages (Abstract)

Transformation of Acetaminophen by Chlorination Produces the Toxicants 1,4-Benzoqinone and N-Acetyl-p-benzoquinone Imine, 7 pages

Applied and Environmental Microbiology: Infectious Cryptosporidium parvum Oocysts in Final Reclaimed Effluent, 2 pages

Guardian Unlimited: Stay Calm Everyone, There’s Prozac in the Drinking Water, 2 pages

Times Online: Where Rivers Run High on Cocaine, 3 pages

Scientific American.com: Ubiquitous Chemical Associated with Human Reproductive Development, 1 page

Applied and Environmental Microbiology: Virus Persistence in Groundwater, 5 pages

World Health Organization: Di(2-ethylhexyl)phthalate in Drinking Water, 13 pages

Download ALL the attachments here WARNING 6MB (Zip file)