Editors note: The following
e-mail was sent to Greg Bartow,
Hydrogeologist for the San Francisco PUC, on October 21, 2003. In
it we have requested information that would assist us in assuring that
public health and safety has been fully considered in this
experiment. To date (11/04/03) we have received no reply to this
request other than to indicate that discussions with the various
authorities have been initiated. We will now pursue Sunshine
Ordinance compliance in an attempt to get answers to these questions
(bold-faced in the following edited version of this e-mail).
Greg:
Thank
you for filling in some of the background on this project. Now
that you
have I do recall some discussion of a perforated pipe delivering Vista
Grande
water, although I was under the impression that was to be used after
the source
of coliform in that water had been identified and eliminated. I
was not
aware, and this may well be my lack of attentiveness, that this was
being
proposed as a solution to that problem.
That
said, your response does raise some additional questions which I will
raise
below:
First,
however, let me emphasize that we are dealing here with a public health
issue,
one that I believe we must attend to with the utmost caution and
concern.
Whether we think it likely to be used in this way or not, the lake
has
been designated by the Regional Water Quality Control Board (RWQCB) as
an
emergency supply of domestic water for the city of San Francisco.
And
whether we think that designation to be realistic or not, when I last
checked
with the RWQCB, just a few months ago, they thought that designation to
be
eminently reasonable, and expressed no inclination whatsoever to change
it. Not that the person with whom I spoke can not be outvoted,
but that's
where the status stands now.
Parenthetically,
the report to the RWQCB that you cited mentions coliform two
times, first
to indicate that the system installed to process Vista Grande water
"did
not remove fine, suspended sediment to which metals and coliforms may
bind." The second reference states, "the separation chamber
effectively removes oil, grease, and grit, but has fairly low nutrient
and
coliform removal capabilities." Nowhere does it state that
coliforms
have been found in this stormwater, and that testing the ability to
remove
those coliforms is a primary goal for this project.
My
first question, then, is this, has
the public been adequately notified about
the intent and design of this program? Were any of the
meetings you
listed publicly noticed with the intent to provide public review of
this
specific issue with clarity that a public health issue is
involved? I would
appreciate receiving copies of any such public notice, as I do not
remember
seeing any.
In
our phone conversation you observed that some of the Vista Grande water
is
expected to flow directly into Lake Merced, while the remainder will
percolate
into the aquifer. That first portion constitutes what is called
direct
potable reuse of untreated stormwater; I know of no precedent for such
a
program in the State of California. Has the RWQCB approved this
program? Has this project been reviewed by the San Francisco
Department
of Public Health?
Apparently
the purpose of this project is to test the ability of the ground to
clean the
water as it settles. Has
sufficient engineering study been done to
estimate the ability of this system to perform, assessing the coliform
content
of the input water and the expected impact of the settling system in
terms of
coliform reduction? Is a copy of that study available that
I might post
to our web site?
You
mention that there will be extensive monitoring of water quality during
the
conduct of this project. What
monitors will be in place? What will
be measured? At what intervals? With what expected
results?
What are the trigger values that will lead to stopping this project?
Again, is a copy of this monitoring plan available that I might post to
the
web?
A
closely related question: If you are
monitoring water quality and the monitor
indicates that the cleansing has not taken place as expected, does that
mean
that pollution has already occurred? If so, what steps can then
be
taken
to clean up the pollution that has been created?
A
couple of questions not directly related to water quality: First,
apparently a 300-foot stretch of flora will be removed from the top of
the bank
where the pipe is to be installed. We have had significant
erosion
problems along that shoreline. What
engineering review has been conducted
that assures that there will not be erosion in this
area resulting
from clearing out the ground cover?
Also,
someplace (that I can't find right now) you mentioned that groundcover
would be
removed from upland banks, and that wetland habitat would therefore not
be
affected. Is there any impact
expected on upland habitat? If not,
has that conclusion been documented?
Again,
however, my primary concern is with issues of public health and safety,
and
those I do not believe can be set aside or ignored. While
there may be
every reason to believe that adequate answers to these questions can be
provided, and may in fact exist, I think that these answers need to be
brought
to the public's attention before any Vista Grande water is actually
pumped into
Lake Merced.
John