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HomeMy WebLinkAboutCUP 194A; Aquaculture Systems International; Conditional Use Permit (CUP) (13)8 SEAFARMS WEST Snellfish Specialists Mailing Address P.O. Box 1540 Carlsbad. CA 92008 Phone (619) 438-2444 June 20, 1990 Mr. Arthur Coe Acting Executive Director San Diego Region REGIONAL WATER QUALITY CONTROL BOARD 9771 Clairemont Mesa Blvd., Ste. B San Diego, CA 92124 RE: BACTERIAL CONTAMINATION OF AGUA HEDIONDA LAGOON -- PROPOSED STUDY . Dear Mr. Coe: As the one most immediately and directly impacted by bacterial pollution coming from the ocean, I believe it is most appropriate for me to comment on the proceedings to date -- most especially, the MEC/SAI counter-proposal (submitted by the Encina sewage treatment plant) to that of the State Department of Health Services (DHS) and Department of Fish and Game (DFG). My comments are based upon reviews of the two proposals; the DHS Sanitary Survey (Wells and Price, 1989); seven years of bacterial sampling in the lagoon, very extensive knowledge of the lagoon’s tides, currents and drainage; six months of off-shore bacteriological data; better-than-average knowledge of offshore sewage disposal theory; and an extensive biological and marine ecological background as a teacher and researcher, backed by a Ph.D. from the University of California, Santa Barbara. There should be only one question to be asked. Are total coliform and fecal coliform bacteria enterinn the lanoon from the ocean? If so, which of the two closest sewage outfalls is responsible? This single question, as far as I am concerned, has been answered. It has been clear from the past 18 months of sampling that incoming tides frequently bring fecal coliform bacteria into the lagoon. There is only one type of ocean source -- sewage! Postulating other sources, such as street or creek drainages, really stretches one’s imagination, especially during the dry season. The next step should be enforcing the Ocean Plan to protect shellfish resources and human health in general. Numerous other regulations, policies and water quality goals could also be invoked. Farm Location - Agua Hedionda Lagoon. Carlsbad. California Mr. Arthur Coe June 20, 1990 Page 3' SEWAGE INDICATORS AND SHELLFISH There are no proven indicators specific for human sewage. Thus, all public health standards are based upon general indicators which are relatively widespread in the environment and come from warm-blooded animals. The kev factor to remember is that fecal coliform bacteria are not normallv found in the Southern California marine environment, except around sewage outfalls. Filter-feeding shellfish, such as mussels, clams and oysters, pump large volurnes Gf xater in order to obtzir, their plankton food. A single mussel may pump up to ten gallons per day and will concentrate its food and any contaminants many times over. It is this feature of mussels that makes them ideal as pollution indicators (e.g., Mussel Watch Program). LAGOON DATA SUMMARY Allow me to summarize what we know of the Agua Hedionda Lagoon situation relative to fecal coliform bacteria and mussels: 2. 3. ,- 4. 5. In years past, during the dry season, fecal coliform bacteria were either not present or occurred infrequently at low concentrations. During any extensive rainfall/runoff, fecal cofiform bacterial concentrations increase to very high levels. This phenomenon is well documented by the EPA in many areas (e.g., "first flush"). Tidal flushing rapidly lowers bacterial concentrations so that in two to four days after a heavy rain, the concentrations are very low. Approximately three years ago, there began episodes of elevated fecal coliform bacterial concentrations. These were infrequent and unpredictable. In the last two years, elevated fecal coliform bacterial concentration events have become ever more frequent, until now it is almost continuous. Fecal coliform bacterial concentrations are higher in the outer lagoon than in the inner lagoon -- the water skiing area. Mr. Arthur Coe June 20, 1990 Page 4 7. The bacteria are clearly coming from the ocean on incoming tides. 8. Mussel "stations" placed in the ocean regularly show elevated fecal coliform bacterial concentrations. These stations are spread between the Encina outfall and the lagoon mouth. 9. Recent current studies conducted by the Encina sewage treatment facility clearly show on-shore currents running north. 10. There is frequently no obvious correlation between fecal coliform bacterial concentrations in mussels and the water in which they are living. This is readily explained by the fact that the mussels are averaging" the concentrations that change in the water with the change in ocean currents and tides. tt BUREAUCRATIC PROBLEM The problem that we face is that those of us (myself, DHS, DFG, USFDA and EPA) who have had long experience with such matters and are familiar with this particular situation, have little doubt that the sources of contamination are the sewer outfalls. On the other hand, the sewage treatment agencies are very skeptical, based upon the widely accepted dogma that off-shore sewage disposal is safe, not only to humans, but to the general environment. This situation is somewhat complicated by the fact that the local RWQCB staff has little experience with such situations and lacks expertise in bacteriology, oceanography and marine biology (i.e., its past efforts have concentrated on mineral" pollution, not living materials). Finally, there is the Board itself, which is composed almost entirely of laymen in these matters. It GENERAL SUMMARY Keep in mind that my shellfish farm is not the problem -- it is only an indicator, part of an informal, early-warning system. The problem, sewage pollution, needs to be recognized and solved now, before it gets worse and even more expensive to fix. Mr. Arthur Coe June 20, 1990 Page 5' In summary, the original DHS/DFG proposed study goes directly, rapidly and inexpensively to the root of the problem. It should be adopted and implemented immediately, in order to not lose the dry season for study. I would welcome any questions you may have. I suspect that I am the most knowledgeable local person on the subject of shellfish sanitation and can easily serve as an expert witness at the July 16, 1990, hearing. Sincerely, Richard D. Glenn, Ph.D. RDG: lw cc: Distribution List Elected Officials F. R. Studdert, Esq. P.S. Should it become necessary, I am prepared to present a very critical analysis of the MEC/SAI proposal to show that the proposal is poorly conceived and shows a clear lack of understanding of many technical and environmental issues.