Murphys Sanitary District General Managers' Letter

Using treated sewage for irrigation
is a common practice

     On March 23, 2012, Murphys Sanitary District;s new  General Manager Julio Guerra wrote a letter to the Central Valley Regional Water Quality Control Board in Rancho Cordova revising the data from the wastewater treatment facility for October of 2011, which included previously unreported bypass flows.

   In the letter, in part Guerra states:

    "As reported by telephone and e-mail, there was a bypass of the treatment system filtration and chlorination process.

    This bypass commenced on 5 July 2011. While this constituted a reportable occurrence pursuant Sections B (1) and E (2) of the Standard Provisions and Reporting Requirements of Order 5-00-264, requisite notice and reports were not provided within required timeframes.  The third quarter 2011 report from the District did contain the following language:

     ...Ironstone Vineyards has worked with MSD to treat and discharge the necessary water from Pond # 4 to insure adequate storage capacity for a major rain event or 100 year storm year..

     In the daily report section for 5 July there was this notation:

    ....Began using portable pump to satisfy Ironstone demands...

    At this point we have ascertained the following:

     1.  The Murphys Wastewater Treatment Plant, as currently configured, cannot process effluent through the filters at rates sufficient to satisfy peak irrigation demand at Ironstone Vineyards.

     2.  Pond 4 at the WWTP had been impacted by excessive wastewater volume attributed by District staff to the failure by the vineyards to use water at contracted levels, this was exacerbated by a wet season, and, as of 21 March 2011, effluent volume had intruded into minimum required freeboard...    

 ....6.  On 5 July a portable pump capable of 1000 gpm flowrate was placed into service to draw water from Pond 4 and deposit it into the "De-chlorination Detention Basin" that serves as the irrigation storage reservoir.  Staff apparently estimated effective pumping volume at 600 gpm under field conditions.

     7.  This procedure resulted in bypass of the filtration and disinfection system.

     8.  No particular effort to fully disinfect the bypass flows appears to have been engaged in, with reported Calcium Hypochlorite use consistent with non-bypass days where it had historically been added for purposes of ensuring temporary compliance with coliform standards as described in the January 2012 DMR.

     9.  A Notice of Violation was issued 9 June 2011 that specified that all existing or potential noncompliance was to be reported to RWQCB per the requirements in Standard Provisions; a response was issued by the District on 7 July that included a "Short-Terms Contingency Plan" as required by said NOV, as well as assurances that such noncompliance would be reported in a timely fashion. The plan did not include treatment component bypass as a listed option.

    10.  Monitoring of the combined treated and untreated effluent did not occur for the period 5 July-25 October so potential negative environmental effects of the bypass cannot be fully assessed.  On 26 October a set of samples were taken  of the combined discharge, while BOD and TSS results were consistent with fully-treated effluent, of particular note was the order of magnitude disparity in TKN concentrations, see attached data table.  TDS results of unfiltered effluent were 75% of the combined effluent and Total Coliform of 23 MPN/100 ml in the combined effluent was still in compliance with effluent limits.

   This bypass procedure was characterized by District staff as necessary to prevent potential overflow of Pond 4.  To date the District has averred that having the reclaimed water user accept all the effluent it is obligated to receive, along with disposal capacity offered by the planned addition of the 20-acre sprayfield would ensure lawful retention of all District effluent.  However, it is recongnized that current facilities cannot fully serve the current end-user.  Therefore some manner of treatment system upgrade is needed in any case.  The District intends to begin preliminary engineering for such an upgrade, with the goal of providing Title-22 tertiary treatment, during the next budget cycle."

....as you can see the letter goes on and on, with one notable statement from Julio Guerra, the Murphys Sanitary District General Manager as of January 2012:

   "AS OF JANUARY 2012, STAFF HAVE BEEN DIRECTED TO SCRUPULOUSLY OBSERVE ALL PERMIT REQUIREMENTS"

    This is written three times in the letter. Something was obviously very wrong before January of 2012, when Guerra took over.