October 9, 2006.

E. coli: Why Monterey County Made a Poor Decision on the Type of Water to Use for Irrigation of Their

Part One of Two Articles

By Frank Pecarich
Retired Soil Scientist

The September 2006 case of E. coli food contamination, the 20th national case and the 9th case in California in the last
decade to be traced back to the region, has masked over the over-arching question of why Monterey County would
choose to use tertiary treated sewage effluent to irrigate 12,000 acres of widely consumed food crops such as
strawberries, artichokes and tender leafy green vegetables such as lettuce and spinach.

For nearly a decade, the Food and Drug Administration has zeroed in on the Salinas Valley -- the "Salad Bowl of the
Nation" -- as a hot spot for food-borne illness. The latest E. coli outbreak is the ninth incident in the last decade to be
traced back to the region, which produces two-thirds of the nation's spinach and much of its other fresh greens.
Water, contaminated by human or animal waste, has consistently been a leading suspect. Those bacteria can move to
lettuce or spinach in many ways -- from a creek flooding a field in winter to dirty water in a roadside ditch soaking a field
worker's boot or even in tertiary treated sewage effluent used to irrigate 12,000 acres of Salinas Valley vegetables and
edible food crops.

Most of us have seen situations where tertiary treated sewage effluent was used on non-food vegetation such as golf
courses. We all have noticed the signs that warn golfers to avoid excessive contact with any material that may have
been sprinkler-irrigated with tertiary treated effluent water and some even recommend you thoroughly wash your golf
ball after playing on such turf.

Well, why you might ask, if we are so concerned about the use of such water, would Monterey County have decided to
irrigate their precious and expensive cropland with such potentially dangerous water? The answer goes beyond the
current, September 2006, examination of that decision -- the infection of over 200 people and three deaths attributed to
E. coli 0157:H7.

Early Problems

It turns out that Monterey's rich and agriculturally productive Salinas Valley has been a concern for growers and
agriculturists for many years going at least back to 1940. There was a continuing and major problem that was occurring
that could ruin these highly productive lands forever. That problem is called "saltwater (sea water) intrusion". Basically
this is a problem along certain areas of the California coastline where heavy groundwater pumping of water has caused
a hydraulic deficiency which causes the seawater at underground levels to move into the now-empty fresh water aquifer

Without "recharging" that groundwater aquifer with clean water and trying to force the seawater back or at least attempt
to prevent its advance, this problem continues to grow worse every year with the encroachment zone creeping ever
inland and ruining farm deep water supplies one-by-one.

The problem was so acute by the 1970s that the local planners started to seriously look at alternatives to recharging
their groundwater supply with high quality water. One of the more obvious solutions was to build a dam and use that
source to irrigate crops and also recharge the groundwater supply. But for various reasons, that idea was never
seriously adopted except for the construction of the dam forming Lake Naciemento which discharges water into the
Salinas River for recharge purposes.

The problem was that even with the Naciemento Lake water, the seawater intrusion was still overtaking and ruining
agricultural and domestic water wells year by year. The planners also looked at building a delivery system to allow them
to take fresh canal water from the State Water Project in the Central Valley. Again for various reasons, that obvious
solution was rejected by the Monterey County leaders.

In the meantime, Monterey County was realizing that government regulatory restrictions on handling effluent were
increasing and their supply of effluent was also increasing with growth in the Monterey County population. It was clear
that this was going to be a big problem for the County in terms of the cost of safe sewage effluent disposal and

My guess is that somebody thought, "Hey, why don't we solve both problems with the same solution? Let's take our
tertiary-treated sewage effluent and pipe it to the farm site and use it to irrigate our crops in the area of this salt water
intrusion, some 12,000 acres worth (18.75 square miles of cropland.)


In 1992 the Monterey Regional Water Pollution Control Agency (MRWPCA) and the Monterey County Water Resources
Agency (MCWRA) formed a partnership to build two projects: a water recycling facility at the Regional Treatment Plant;
and a distribution system including 45 miles of pipeline and 22 supplemental wells. Its stated objective was "to retard the
advance of seawater intrusion by supplying irrigation water to nearly 12,000 acres of farmland in the northern Salinas
Valley." They believed that "this would significantly reduce the draw of water from the under ground aquifers". The $78
million projects were completed in 1997 after three years of construction.

Reading from the current MRWPCA webpage they say:

"In the mid 1970s, a group of community leaders began discussing the idea of recycling wastewater. This led to the
extensive five-year Monterey Wastewater Reclamation for Agriculture Study that began in 1980. The final results of this
research proved that recycled water is safe for the irrigation of crops that are consumed without cooking. Today, this
definitive report is used as the standard in countries all over the world."

The MRWPCA goes on to say, "the use of highly treated wastewater to irrigate landscaping has been practiced for
years, yet for food crops, it is relatively new". (Emphasis added) They say further, "In the future, MRWPCA plans to
additionally supply recycled water to city parks, roadway landscape and golf courses."

They describe the tertiary treatment disinfection process they utilize thusly, "The disinfection process destroys bacteria
and germs by maintaining a specific chlorine level in the water for two hours. The final product is clear, odorless and
safe to use for irrigation."

Finally, the MRWPCA says, "After treatment, the recycled water is held temporarily in an 80-acre/foot storage pond
before it is distributed to farmlands via an underground 45 mile long pipeline system. During the rainy season, when the
growers don't need the treated water, it is safely discharged two miles into the Monterey Bay."

Monterey County Grand Jury Report 1999

It didn't take long after MRWPCA and MCWRA started delivery of the tertiary treated sewage effluent to farms that
serious complaints surfaced from farmers. In a 1999 Monterey Grand Jury report the first finding stated that sixty-five
percent of the growers responding to a survey indicated dissatisfaction with the quality of water received. Further, eighty-
two percent either believed or were uncertain whether or not long-term use of the water would have a detrimental effect
on the productivity of the land. Fifty-four percent were dissatisfied with the Agency's responsiveness to issues raised by
the growers in the CSIP area. Comments were also received regarding the need for better cost controls over operations
and variations in water quality based on the amount of blending with well water.

It was clear to the Grand Jury that these were issues requiring a formal response from the Monterey County Board of
Supervisors (MCBOS). While the entire report of the findings of the County Board of Supervisors can be found on the
Monterey County Court website, I will summarize the MCBOS responses here.

To the finding described above, the MCBOS responded that:

The Board of Supervisors partially disagrees with this finding. Water quality and customer service have been priorities of
the MCWRA from the onset of the Castroville Seawater Intrusion Project (CSIP). The MCWRA recognizes that high
quality customer service requires communication and responsiveness. Both are vital elements in the success of new and
innovative projects. The development of relationships with the agricultural community began in the 1970's and 1980's
during the Monterey Wastewater Reclamation Study for Agriculture (MWRSA) and continues today through the
interactions of the Water Quality and Operations Committee and outreach efforts conducted by the MCWRA. Agency
customer service and outreach efforts include:

1) Grower information meetings (held monthly for the first full year of operations and continue semi-annually; meeting
attendance dropped over the first year from approximately 50 per meeting to less than ten per meeting).

2) A public outreach and education program developed by Ketchum Inc. is in position with a comprehensive response
package developed for CSIP area grower/shippers.

3) Water Quality and Operations Committee (monthly meetings are held to discuss operations issues and customer
concerns and provide a forum for direct input regarding the CSIP operation to the MCWRA Board of Directors).

4) Commitment of a full time staff member as an on-site grower liaison.

The second finding of the Grand Jury report found:

The Monterey Wastewater Reclamation Study for Agriculture Final Report, the pilot program for CSIP, did not
adequately address the long-term effects of use of reclaimed water on agricultural lands.

To the finding described above, the MCBOS responded that:

The Board of Supervisors wholly disagrees with this finding. The Monterey Wastewater Reclamation Study for
Agriculture (MWRSA) evaluated agronomic impact on soils in the CSIP area for five consecutive years and found no
adverse impacts.

Based on a preliminary assessment by a Plant-Water Relations Specialist, the salinity of the CSIP water could be
detrimental to certain crops grown in the project area. In 1998 and 1999, crop yields in the CSIP area were not
adversely impacted by the use of recycled water. No reports were received indicating the salinity of the water delivered
by the CSIP had detrimental impacts on the crops grown. Further, while the original MWRSA study did not evaluate the
impact of recycled water on strawberries; there is no conclusive evidence that the water delivered by the CSIP would be
detrimental to strawberries.

The Grand Jury also recommended:

The Agency, in conjunction with the Water Quality and Operations Committee, seek an independent, authoritative
determination as to the agricultural suitability of the CSIP water and the long-term effect of use of this water on
agricultural land.

To this recommendation the MCBOS said:

The recommendation will not be implemented because it is not warranted. The MWRSA study broke new ground in the
area of recycled water research. It was the first comprehensive evaluation of agronomic use of recycled water in
California, and is still cited as a reference in the development of recycled water projects. The study monitored and
evaluated impacts on soil over a five-year period and found no adverse impacts from recycled water use on the MWRSA
study area soils, nor were any indicators of adverse conditions identified. While the MWRSA study developed new
information never before compiled and established a new standard for recycled water research, it was never intended to
be the end of the monitoring and data development for the CSIP. The MCWRA and the MRWPCA have continued to
monitor, study and evaluate the short and long-term impacts of the CSIP on the soils and crops grown in the project
area. Laboratory monitoring budgets for the first two years of operation have exceeded $35,000 and the proposed SMP
will provide additional data to build upon the work conducted under the MWRSA study. Both MCWRA and MRWPCA
continue to be fully committed to evaluate and improve CSIP water quality.

To the recommendation that "The Agency increase blending of the CSIP water with well water until such time as the
salinity of the effluent leaving the plant can be reduced to levels that do not impact crop yields." The MCBOS again
The recommendation will not be implemented because it is not warranted.

Blending of well water with recycled water is designed into the project through the operation of the 21 supplemental
CSIP wells. Perhaps the single most important area for improved CSIP water quality is the agronomic issue of salt (or
sodium) reduction. The MCWRA and MWRPCA have adopted a progressive and proactive approach to salt reduction
leading to the MRWPCA Salt Reduction Program and the Salt Management Plan (SMP). Through these programs the
MCWRA and MRWPCA have implemented programs to improve water quality and promote long-term satisfaction of the
CSIP growers.

The project was not designed to meet all irrigation demands through the use of recycled water. For instance, water
delivered in 1998 and 1999 was one-third well water and two-thirds recycled water, yielding a Sodium Absorption Ratio
(a measure of agronomic water quality and sodium impact to the soil) of less than four (4). The MCWRA and MRWPCA
are also developing CSIP operational protocols to better control the equity of blended water throughout the CSIP
delivery area. When growers have identified the need to use well water in lieu of project water, the MCWRA has
accommodated them by operating project wells and providing the growers well water. The MCWRA grower liaison
provides day-to-day contact and field support for the CSIP growers.

To the recommendation by the Grand Jury that "The Agency conduct a survey of the different soil characteristics in the
CSIP service area to determine if some land should be excluded from irrigating with CSIP water based on the nature of
the soil and its ability to tolerate this water" the MCBOS gave what we now can see as their usual response, to wit: "The
recommendation will not be implemented because it is not warranted."

And to end their response and recap their position and basic unwillingness to change procedure and practice at the
CSIP, they said:

"Finally, it should be noted, the Castroville Seawater Intrusion Project (CSIP) is the first large-scale project using
recycled water as a source of water supply augmentation, and represents a departure from most if not all existing
recycled water projects in California. Most present day recycled water projects have been driven by the need to manage
the discharge of treated waters. The recycled water delivered by the project is key to the long-term reduction of
seawater intrusion, and essential in the Monterey County Water Resources Agency's (MCWRA) effort to preserve prime
agricultural lands and the quality of life in the Salinas Valley."


It would appear that one of the few actions they implemented as a result of the Grand Jury report was to hire a top level
public relations (PR) firm. From this action and their above response we may conclude that they believed their main
problem was one of public relations and the complaints by farmers and users of CSIP were "unwarranted".

Since that time there has been no official complaint about the system's performance in spite of repeated national E.coli
crisis traced back to the Salinas Valley. One would naturally expect that after the complete denial of the concerns of the
area farmers in 1999, most people would eventually give up and determine that the elected leadership was going to
continue to be unresponsive. I think that is exactly what has happened.

Over the past 10 years the FDA has increased its oversight and articulated concern and in this latest situation was
forced to bring in the U.S. Department of Justice and the FBI, who are currently working to find the reason for the

State regulators do not require growers to test irrigation water for contaminants. To us the cause seems apparent and
at the same time the circumstance seemingly most glaringly ignored by investigators. For us, the main and continuing
problem is the use of tertiary treated effluent to irrigate crops consumed fresh without cooking. In particular and most
vulnerable are the soft tissue, leafy green vegetables, lettuce and spinach. In the attachment to this essay I have
provided a lengthy commentary which largely explains the substance of our research which contends that constant
contamination can be expected from continuing to use CSIP water.

One of the major flaws in the Monterey County study efforts was an overemphasis on the soil-water effects
from an agricultural perspective and a grave under-emphasis on the human health factors. One of the
things we have learned from our critique of this series of actions by Monterey County over the past decade
is the clear conclusion that the scientific dynamics are so complicated that they require a multi-disciplined
analysis with a very wide breath of professional disciplines included in the review.

We believe that as long as crops such as lettuce and spinach are grown using tertiary treated sewage
effluent, there will be continual outbreaks of E. coli 0157:H7 and similar pathogens including viruses and
the resultant pain, suffering and death that can occur. This is what the FDA means when it recently
predicted that without a change in practice there will be a 21st E.coli case arising from Salinas Valley. Why
are they so sure? We think it's probable that the FDA is aware of the dangers of the CSIP and such a
prediction with 100% certainty is easy to make in those circumstances.

Frank Pecarich retired from the Washington, D.C. headquarters of the US Bureau of Reclamation in 1987. During his
26 year federal career he worked as a soil scientist with the USDA on the now- published Soil Survey for Monterey
County. He lives in Ventura County.

An informational hearing is scheduled for Wednesday, October 11, 2006 before the California State Senate
Governmental Organization Committee that is titled "Unraveling the e.coli outbreak: Are state emergency response
systems prepared for outbreaks of foodborne illnesses?" Perhaps the state should be asking other questions as well.