Monthly Archive for April, 2007

EPA List of New Drinking Water Contaminants

I thought this might be of interest (and possibly of use).

Have a great day,
Rue

Regulatory Determinations for Priority Contaminants on the Second Drinking
Water Contaminant Candidate List

On this page
The Second CCL Regulatory Determinations Schedule
http://www.epa.gov/safewater/ccl/reg_determine2.html#schedule

April 2007 Preliminary Regulatory Determinations for Priority Contaminants
on the second Contaminant Candidate List
Federal Register Notice
http://www.epa.gov/safewater/ccl/reg_determine2.html#fr
Support Documents for Regulatory Determinations Notice
http://www.epa.gov/safewater/ccl/reg_determine2.html#supportdocs

Discussion on Trace Pollutants in Our Water System

Katy;

Once the stuff enters the wastestream the only way to remove it is with modern a modern plant. But You are also correct that everyone should  reduce the so-called point source of pollution. We will probably need serious legislation for this to happen on a large scale but many contaminants can be kept out of the wastestream to begin with. All out-of-date or unused pharmaceuticals, for example, should be dropped off at central locations for disposal. In the east Bay, EBMUD has a program where anyone can drop off unneeded drugs at any pharmacy; the point is NEVER flush them down the toilet.

You can use abrasives like BonAmi instead of chlorine cleaners like Comet, etc., and other eco-friendly cleaners. Unfortunately, these actions, although important, have a tiny effect compared to the sheer volume of contaminants we have to deal with.  In Europe you cannot bring a product to market without first demonstrating how it will be disposed of safely. Obviously, we could benefit from this kind of thinking. In the meantime, modern treatment plants work.

If you don’t know about the meeting posted below, and if you have time, you and everyone you know might like to attend and urge Santa Rosa to clean their sewage not partially clean it. Most especially don’t dump this stuff in the Russian or dump it on grapes.

Regards,

HR

——

Trace Pharmaceutical and Personal Care Product Residues in Recycled Waters: Occurrence, Fate, Toxicology, and Risk.

During studies related to the IRWP, there has been some concern expressed from the public regarding impacts to human health and the environment associated with trace organic pollutants. As a result, the Board of Public Utilities has requested a Study Session on the latest information available regarding unregulated compounds so that they may make informed decisions. The tentative speakers include Jean Debroux Ph.D., chemical and environmental engineer/scientist with Kennedy/Jenks Consultants, Laura Kennedy, risk analysis specialist with Kennedy/Jenks Consultants, Shane A. Snyder, Ph.D. R&D Project Manager, Southern Nevada Water Authority and Dr. Stanley Deresinski MD, and Stanford professor.

The Study Session regarding currently unregulated compounds such as trace pharmaceutical and personal care product residues will be held on April 19th at 1:30 pm in the City Council chamber at 100 Santa Rosa Avenue. The Study Session should last about 90 minutes and is designed to help decision makers in Santa Rosa determine the potential impacts of discharge of excess recycled water to the Russian River and/or its tributaries.

Tami DeVol
Administrative Secretary
Utilities Department
Phone 707 543 3371
Fax 707 543 3399

Yes, this helps.  I thought it was a matter of refraining from using certain products.  But, that isn’t the point.  The point is getting modern treatment plants.  And, hey, I can’t imagine getting people to stop using personal products anyway.

Please keep me posted as to how one pushes for modern treatment plants.

Thank you,
katy

Katy, et. al;

The O.W.L. Foundation has prepared a reader on the subject of partially treated wastewater (it is not recycled water as some claim) and you can download it from our home page (1.3MB PDF). The articles in the reader are from various news sources, scientific abstracts and the last article is a description of Orange County’s modern treatment plant and its advantages. Please feel free to distribute the reader to any interested party.

The main thing to grasp about partially treated sewage is that the risks, which are considerable, are completely unnecessary and avoidable.

Many communities around the world, like Orange County, operate modern treatment plants. These plants remove everything from sewage that is not the molecule H2O. The product is, literally, pure water and nothing else. With pure water you can not only irrigate crops with no risk whatsoever, you can inject pure water into groundwater aquifers and restore damaged levels. Even better, pure water from modern treatment plants will dilute naturally occurring contaminants in groundwater like arsenic, radium, radon, uranium, etc. making the groundwater better quality than before. Pure water also has a high monetary value and can be sold to customers as pure water.

Partially treated sewage is a hard sell and many farmers, grape growers and others quite naturally resist its use and some have gone to court over the issue. “Regular” water currently sold that is extracted from surface sources, like rivers, are routinely decontaminated with chemicals like chlorine. Pure water is pure water.

There are three prominent health concerns about partially treated sewage: 1) drugs, both legal and illegal drugs remain in partially treated sewage; 2) a family of chemicals called phthalates that have virtually the same biological effect on living organisms as the hormone estrogen; and 3) so-called “emerging contaminants”. This category is by far the most worrisome. As you will see in the reader, partially treated sewage contains many diverse chemicals that are reacting in unpredictable ways. For example, Acetaminophen and chlorine can combine to produce two completely new toxicants neither of which were introduced into the wastestream (see article in the reader). So the chemicals left behind in partially treated sewage are reacting in unpredictable ways and producing  even more dangerous compounds.

This last category, emerging contaminants, is important because it proves that no one knows what is in partially treated sewage, nor could anyone know what is in it without accounting for every single chemical constituent and demonstrating every possible permutation—a ridiculously impossible task even with the aid of the largest supercomputer. So anyone who claims that partially treated sewage is safe, for any use, cannot possibly know that as a fact because they cannot account for all the possible emerging contaminants being brewed in this waste, hence the term “witches brew.”

The point is that no one should be asked to take this risk because modern treatment plants can remove everything.

Hope this helps,

HR Down

Study Session on Trace Pollutants to SR’s IRWP

At this study session for Santa Rosa’ watershed plan, Brenda Aldeman from the local Russian River Protection Committee will give a short talk on the research she has done on various trace pollutants getting into rivers mainly from wastewater sources.

Here is the notice of this study session and other speakers:

During studies related to the IRWP, there has been some concern expressed from the public regarding impacts to human health and the environment associated with trace organic pollutants. As a result, the Board of Public Utilities has requested a Study Session on the latest information available regarding unregulated compounds so that they may make informed decisions.

The tentative speakers include Jean Debroux Ph.D., chemical and environmental engineer/scientist with Kennedy/Jenks Consultants, Laura Kennedy, risk analysis specialist with Kennedy/Jenks Consultants, Shane A. Snyder, Ph.D. R&D Project Manager, Southern Nevada Water Authority and Dr. Stanley Deresinski MD, and Stanford professor.

The Study Session regarding currently unregulated compounds such as trace pharmaceutical and personal care product residues will be held on April 19th at 1:30 pm in the City Council chamber at 100 Santa Rosa Avenue. The Study Session should last about 90 minutes and is designed to help decision makers in Santa Rosa determine the potential impacts of discharge of excess recycled water to the Russian River and/or its tributaries.

Judge Orders State to Stop Killing Delta Fish

Agency told to obey law in 60 days or shut down pumps that send water to Southern California
Glen Martin, Chronicle Environmental Writer March 2007

The pumps that send water to 24 million Californians illegally kill endangered and threatened fish species and must be shut down, an Alameda County judge has decided.

The judge’s draft decision, released Friday, is far-reaching in scope, but nobody expects immediate rationing in the areas that receive the water — the East Bay, the South Bay and Southern California. Judge Frank Roesch gave the state 60 days to figure out a way to comply with the law.

Ultimately, the state Department of Water Resources could be forced to radically change the way it allocates water via a complicated set of canals and reservoirs known as the State Water Project. Changes could mean more water for the beleaguered Sacramento-San Joaquin River Delta and less for municipalities and Central Valley farms.

The decision further undercuts the faltering consensus approach that has guided state water politics during the past decade, and it harks back to the 1970s and 1980s, when acrimony and litigation prevailed.

Consequences of changing State Water Project operations are huge: The system is a major source of water for cities like Los Angeles and irrigates 775,000 acres of cropland. State officials say it is also directly responsible for a $300 billion portion of the California economy.

At a minimum, complying with the judge’s decision will force the state water agency to obtain a permit from the California Department of Fish and Game allowing the “incidental” killing of delta smelt and chinook salmon at the Harvey O. Banks Pumping Plant near Tracy as well as to develop a plan to aid in the recovery of the protected fish.

Roesch’s ruling was in response to a 2006 lawsuit over the killing of the fish. The suit was filed by the California Sportfishing Protection Alliance against the California Resources Agency, which oversees the Department of Water Resources and the State Water Project.

Officials have two weeks to provide more information, after which Roesch can either modify or maintain his order.

“This was a bell ringer,” said Bill Jennings, the executive director of the Alliance, a confederation of anglers based in Stockton. “We have a real likelihood now that the delta will receive more water,” he said.

Jennings said that the Water Resources Department ignored the California Endangered Species Act and state Fish and Game codes in operating its pumps, which have ground up large numbers of fish.

The state’s pumping station can transport 10,300 cubic feet of water a second, equivalent to a large river. The nearby pumps that sustain the federal Central Valley Project are much smaller, with a capacity of about 4,600 cfs. The Central Valley Project is not affected by Roesch’s decision.

The Water Resources Department maintained it was given a pass on state laws by virtue of five agreements concluded in the 1990s, including two negotiated by CalFed, the joint state and federal agency created to solve California’s water disputes.

Roesch ruled that the agreements did not constitute a permit to kill the salmon and smelt, as the state contended.

The best that can be said of the five agreements, Roesch wrote, “is that (they) accept fish will be killed in the Henry O. Banks Pumping Plant operations and that the parties agree that mitigation measures will be undertaken.”

State officials expressed dismay at the decision.

“We obviously strongly disagree with the court’s proposed decision and will present additional information to challenge (it),” state Resources Secretary Mike Chrisman said.

Ryan Broddrick, the director of the California Department of Fish and Game, said conservation strategies of the kind Roesch requires are complicated and time-consuming.

“We want to find solutions for the delta that have long-term sustainability,” Broddrick said. “The (60-day) time frame offered is not sufficient.”

Lester Snow, the director of the Water Resources Department and the former director of CalFed, agreed with Broddrick and noted that the state recently authorized a $1 billion delta habitat conservation plan. Such a comprehensive and well-funded effort, Snow said, is preferable to fighting the matter out in court.

“(Roesch’s) response is devoid of any recognition of this conservation plan,” he said.

Snow also said that the consequences of curtailing Southern California water deliveries would be unacceptable.

“The California gross product is $1.6 trillion,” he said. “Of that, the State Water Project directly supports $300 billion. That’s a lot of farm and industrial jobs.”

Water contractors also are concerned.

“We get 80 percent of our water from the state project, so we find this very worrisome,” said Jill Duerig, the general manager of the Zone 7 Water Agency, which serves the East Bay cities of Pleasanton, Dublin and Livermore.

“It highlights the uncertainty and risks we face in securing our drinking water supplies,” she said.

But Jennings said Roesch’s decision “blew away the smoke screen” that obscured many delta problems and underscored the general failure of CalFed.

“Under CalFed, water exports from the delta have increased, and we’ve seen the general collapse of the region’s ecosystem,” he said. “It became clear to anglers that if we were going to have any fish left in the delta, we were going to have to step away from the backroom deals and hold the agencies accountable to the law.”
The State Water Project

Court Rules That WaterRight Restrictions To Protect Fish Habitat Did Not Constitute A Taking

By Alfred E. Smith, II
Nossaman Water Law

In a decision entered on March 29, 2007, the United States Court of Federal Claims ruled that the government need not pay compensation to a water district for restrictions on water diversions to protect endangered species. Casitas Municipal Water District v. United States, Case No. 05-168L (“Casitas”). The case involved a municipal water district that built a fish ladder and other improvements to assist the passage of endangered steelhead trout at the Robles Diversion Dam located on the Ventura River.

The water district argued that restrictions imposed by the U.S. amounted to a taking of property thereby triggering the Constitution’s just compensation requirement because the restrictions required the district to forego the exercise of a right to divert approximately 3,200 acre-feet of water per year for irrigation purposes. The water district pointed out that water is a unique asset, the value of which is tied exclusively to its use, and when its use is restricted or denied, all value is lost.

The government disagreed, claiming that the water restrictions did not amount to a physical or per se taking, such as when the government takes property for a school or road. Instead, the government argued that the restrictions should be treated as a “regulatory” taking, requiring compensation only when the restriction deprives an owner of all economically beneficial use of the property under the criteria adopted in Penn Central Transportation Co. v. New York City, 438 U.S. 104 (1978).

SCWA Dangerously Low Water Supply Alert

SCWA Low Water Supply Level Alert

Press conference: Thursday, 4/12, 10:30am, Healdsburg Memorial Beach

Media Advisory
For Immediate Release Contact:
April 10, 2007 Brad Sherwood 707. 521.6204
Cell Phone: 707.570.7448
Dangerously Low Water Supply Levels Projected
Agency to urge for immediate water conservation
Santa Rosa, CA –The Sonoma County Water Agency (Agency) on Thursday, April
12 will hold a press conference to announce the release of a projection
that indicates dangerously low water supply levels in Lake Mendocino this
summer and fall. The Agency will call for the immediate implementation of
voluntary water conservation efforts by its water contractors, customers
and agricultural community. Impacts of the low water supply levels will be
addressed, including Russian River flow levels and fishery concerns. The
year-long projection is based on past and projected rainfall patterns,
Russian River flow requirements, and recent agricultural and municipal
water demands in the Russian River above Healdsburg. The water released
from Lake Mendocino plays a significant role in providing drinking water
to 600,000 residents in portions of Sonoma and Marin counties, habitat for
threatened salmon species and recreation.
Who: The Sonoma County Water Agency – Speakers to include:
Agency Board of Directors Tim Smith and Paul Kelley; Pam Jeane, deputy
chief engineer of operations; Chris Murray, principal engineer; Sean
White, principal environmental specialist.
What: Announcement of Russian River Water Supply Projections
Date: Thursday, April 12, 2007
Time: 10:30 a.m.
Location: Healdsburg Memorial Beach – On the Russian River (near the fish
ladder)
13839 Old Redwood Highway, Healdsburg, CA (directions attached)
RSVP: Contact Brad Sherwood at 707-521-6204 to verify your attendance –
special parking will be provided at the site.
###
Sonoma County Water Agency provides water supply, flood protection and
sanitation services for portions of Sonoma and Marin counties. Visit us on
the Web at www.sonomacountywater.org.
Directions to Press Conference at Healdsburg Memorial Beach
>From San Francisco/Bay Area:
1) Take Highway 101 North towards Healdsburg
2) Take exit towards Healdsburg Avenue
3) Turn right onto Old Redwood Highway
4) Turn left into Healdsburg Memorial Beach
Follow the road through the parking lot to the Russian River. Parking will
be available near the Russian River. The press conference will take place
near the Russian River and fish ladder.
>From Eureka/Northern California:
1) Take Highway 101 South towards Healdsburg
2) Take Westside Road exit toward Guerneville
3) Turn left onto Westside road
4) Stay straight to go onto Mill Street
5) Turn right onto Healdsburg Avenue/ Old Redwood Highway
6) Turn right into Healdsburg Memorial Beach
Follow the road through the parking lot to the Russian River. Parking will
be available near the Russian River. The press conference will take place
near the Russian River and fish ladder.
Contact:
Brad Sherwood
Programs Specialist
Sonoma County Water Agency
Phone: 707.521.6204 (office)

Gone to the Well Once Too Often

Percentage of State Population dependent on Ground Water

The Importance of Ground Water to Rivers in the West
A Report by Trout Unlimited’s Western Water Project

Click Here to Download Report and here for
Ground Water Question and Answers.

Continue reading ‘Gone to the Well Once Too Often’

Troubling times for Santa Cruz water supply

By Shanna McCord Sentinel staff writer Worried that the city’s reservoir could run uncomfortably low this summer, city water workers will hand out tickets to people washing cars or watering lawns during the heart of the day.

Beginning May 1, the Santa Cruz Water Department will place mandatory limits on water use for the 90,000 people it serves between Capitola and the North Coast. The restrictions, a response to this year’s low rainfall, prohibit watering lawns, gardens, ornamental landscaping and the like from 10 a.m. to 5 p.m. every day, said Toby Goddard, the city’s water conservation manager. The limitations will be in place until further notice.

Continue reading ‘Troubling times for Santa Cruz water supply’

Quotes from Shiva’s Water Wars

Hi, I’m sending this to every one I know because I really do believe that water is something we all need to be more mindful of. I hope you will take a look at the information below about bottled water and maybe do some research of your own on water privatization.
The world is changing fast, there are lives in the balance of things many of us take for granted. Water like Air is essential for life, lets do all we can to protect water, this elemental necessity.

In her book, Water Wars, the Indian author Vandana Shiva lists nine principles underpinning water democracy. At least two of these principles are directly compromised by the privatization of water. Point number four states that “Water must be free for sustenance needs. Since nature gives water to us free of cost, buying and selling it for profit violates our inherent right to nature’s gift and denies the poor of their human rights.” When private companies try to make large profits through high water prices, it denies the poor the inalienable right to the most necessary substance for life.

In accordance with this fact, point number seven states, “Water is a commons. . . It cannot be owned as private property and sold as a commodity.” How can one justify claiming water as their own through contractual agreement while letting another human being go thirsty? Water is a commons because it is the basis of all life. Water rights are natural rights and thus are usufructuary rights, meaning that water can be used, but not owned. As far fetched as water ownership may seem, it is happening at an increasing rate around the globe. This paragraph is from the Water is Life Homepage.

2002 RR Water Quality Testing Report and Endocrine Disruptors

This should be an interesting and helpful study. Endorsement by the SCWC would be a valid idea. The SCWC should also find out which other utilities or groups in Sonoma County and surrounding areas are also planning or conducting similar studies and efforts. We may also wish to consider other endorsements.

FOR ROBERT RAWSON: How will measurements for endocrine disrupters, pharmaceuticals, and personal care product removals be made and who will make them? My under standing is the measurement methodology is still not very reliable, and there are only one or two labs in the US that do them. These doubts are also expressed in the attached article. I’m definitely interested in the project and verifiable results.

Len Holt

MMWD’s Russian River Water Quality Testing: what’s it mean?

Dear David, Thanks for forwarding this interesting article. You might be interested to know that we have applied for $250,000 in EPA wetland grants for endocrine research at Graton CSD.

We plan to study the removal of endocrine disruptors, pharmaceuticals, and nutrients that remain as residuals from a tertiary treated wastewater effluent. Our Capital Improvements Project will be completed by the end of the year and provide the tertiary component. The grant will involve the use of multiple barriers consisting of mycofiltration, bioremediation, phytoremediation (nursery and redwood forest), as well as employing various soil matrix components such as zeolite, peat moss, ferric hydroxide, and carbon.

If the grant is awarded we will be spending a great deal of money conducting sampling and laboratory analysis, looking at processes useful for the removal of endocrines. In turn this will provide a lot of information on the quantities of these compounds in wastewater which has been treated in different ways. Different secondary and teriiary treatment processes will be suggested once the importance of endocrine disruptors gets incorporated into NPDES permits.

I think this issue should be made of prime importance as Santa Rosa evaluates the option of indirect discharge. Conventional activated sludge treatment has very short detention times and allows perhaps half of the medicines and endocrines to pass through. Graton will be employing pretreatment in the collection system using selected strains of bacteria capable of digesting endocrines, followed by secondary oxidation in staged aerated ponds equipped with recirculation and further bacterial inoculation to initiate nitrogen removal, followed by a Suspended Air Floatation (SAF) for copper, zinc, TSS removal, a fuzzy filter with depth filtration, accompanied by coagulation with a starch based polymer for virus removal, followed by disinfection, long term storage, and then the mycofiltration, bioremediation, phytoremediation and soil components.

I believe this approach will remove everything below a detectable limit for less cost than membrane filtration. We have received a letter of support for this from Congresswoman Lynn Woolsey. I think this is a timely study that might show a better way to release treated effluent back into the environment such that it is a benefit to ground and surface waters rather than a detriment.

Sincerely, Bob Rawson General Manager, GCSD From:

What does the MMWD 2002 Report on Russian River Water Quality Testing mean? Overall, by their assessment, the water quality of the Russian River looked pretty good. However, there were some significant defects in the testing procedures, particularly for endocrine disruptors. See a contemporaneous critique article from Louis Nuyens, below, from the Coastal Post. This report, if taken at face value, apparently gives us a reasonably good picture of the Russsian River, and what happens when the wastewater is diluted downstream of the Laguna, and all that tea is chlorinated and pumped down our pipes by SCWA. The next questions are: - complete a valid analysis for endocrine disruptors and any new chemistry of concern since 2002 within the Russian River; are the limits of detection used in this report still valid? what about combination by-products? - do a complete analysis of all the critical components in the wastewater stream, since that will not be diluted when applied to agric etc. for the Ag Reuse Project. - do the research on what happens when this wastewater is applied to ag soils, and to edible crops, such as grapes; what if it is used to recharge groundwater, deliberately or inadvertantly? - do any components of concern make it thru to the grape juice or, more importantly, wine?

David

MMWD Study Marred By Poor Science

COASTAL POST, JULY 2002 By Louis Nuyens

In June, the Marin Municipal Water District (MMWD) staff presented the results of a quietly instituted, 12-18 month water-quality testing program on the Russian River. The program seemed to be targeting criticism, and attempting to defuse concerns raised by Marin and Sonoma County environmental leaders and public health advocates who, two years ago, brought up the issue of contaminants and pollutants being discharged into the Russian River (RR), a major drinking water source for the two counties.

Many of the concerns to date have centered around mistrust of information provided by the Sonoma County Water Agency (SCWA) a body thought by many to be too closely aligned with pro-development interests — which has frequently under-informed and misinformed its major municipal clients while negotiating agreements with them. Considering its value as wildlife habitat, recreational resource, and agriculture and drinking water supply, comprehensive, scientifically valid water quality studies of the Russian River are long overdue.

On its surface, the MMWD program is a good one, testing for pesticides, herbicides, 319 organic chemicals, pharmaceutical pollutants, and endocrine disruptors. However, sewage wastewater was not addressed, and, unfortunately, problems with methodology, quality control, questionable use of new technology, and inappropriate partnerships that undermined the foundation of the entire program. The program was implemented in such a slip-shod manner that the results cannot be considered a scientifically validated study, but merely an exercise in placation.

The Program: The MMWD study included monthly testing of samples for 319 synthetic organic compounds, which were processed by a certified, commercial laboratory. The program ran for 18 months, from the SCWA treated drinking water at Marin¹s Ignacio Pump Station, and for 12 months for raw (untreated) water in the Russian River. The untreated water samples were gathered below the Laguna de Santa Rosa (the wastewater discharge point for the city of Santa Rosa) and below SCWA drinking water collectors in the Russian River. These samples were gathered by Sonoma County Water Agency staff. Additional limited samples were taken at the above sites, plus upstream of Laguna de Santa Rosa, for similar time periods; they were tested using experimental techniques for pharmaceuticals by the University of California at Berkeley, and for endocrine disruptors by Wisconsin State Laboratory of Hygiene using E-Screen Assays which use breast cancer cell growth to determine estrogenic activity.

Methodology Misfires: Coastal Post inquiry uncovered that MMWD did not put together a program plan, sampling protocols, quality assurance plan or a quality control plan for the Russian River water quality study all crucial factors in validating scientific methodology, and a standard practice in any industry. Nor was there any of the above documentation provided to MMWD from their partners, UC Berkeley or Wisconsin State, which is not necessarily out of the ordinary for academic research facilities, but most certainly problematic for public use of the data. MMWD negotiated with SCWA staff to take all of the samples for the Russian River part of the program recognizing that SCWA has a vested interest in proving that their highly lucrative water source is pollutant free. In fact, the SCWA just hired political consultant with $45,000 in public money to polish its image, while one of its closely-aligned contractors is paying over $300k for lobbying to weaken requirements on toxic dumping. While collaborations are often beneficial, partnering with SCWA, given its past negative history, which has engendered serious distrust in the community, damages the credibility of MMWD’s Study. An example of proper methodology and paper documentation for a very similar study, see the website for the USGS’s Pharmaceutical Testing Program (http://toxics.usgs.gov/pubs/OFR-02-94/index.html).

Cutting Edge Technology Can Be An Unwieldy Sword: Bob Castle, MMWD’s Water Quality Manager, mentioned at the presentation that their partnership with the Civil and Environmental Engineering division of UC Berkeley, who were attempting to test for pharmaceuticals, was not the most successful, or happy of affairs. Throughout the study, UCB was reportedly unable to perform the highly experimental test procedures to achieve the low level detection necessary to produce usable data on pharmaceuticals. Undergraduate students performed the analytical work. According to Mr. Castle, they abandoned the testing for certain types of compounds altogether. UCB has since pulled out of any further testing partnership with MMWD and has indicated that they are not interested in testing surface waters only direct sewage wastewater discharges (which have higher levels of constituents of concerns). In the United States, it appears that the Environmental Protection Agency, and USGS are the only ones who seem to have the capability, at this point in time, to consistently perform the high level of technique required of this type of testing. The E-Screen Assays performed by Wisconsin State also experienced consistency problems; results contradictory to UCB tests occurred on a given sample. E-Screen Assays are used as a general tool to detect estrogenic activity, it does not separate or identify compounds, just that they are, or are not, present. There is ongoing assessment of the accuracy of the test by researchers.

Results and Conclusions: The most viable part of the MMWD study is the organic chemical panel (319 compounds), and was performed by a commercial lab - which would have done appropriate QA/QC using standardized, EPA approved tests, but the sampling procedures are still under suspicion due to lack of documentation of protocols and SCWA involvement. The majority of the results came back “non-detect.” However, the organic chemical report list provided by MMWD to the public, fails to distinguish the Ignacio sample results from the Russian River results, and appears to lump them together. Pharmaceutical testing involves highly difficult techniques, attempting detection in the parts per trillion; many lessons must be learned before reliable data can be achieved reliably by smaller lab facilities. It is worth keeping an eye on for the future, and, in the meantime, lobbying the EPA or USGS to undertake a pharmaceutical and endocrine disruptor study on the Russian River. Unfortunately, virtually no comparative data from other agencies such as USGS, California Department of Fish and Game, National Marine fisheries, is available on RR water quality to compare or debunk MMWD study. MMWD had the right shopping list; it should keep the list and try to fill it properly.