RWQCB rescinds waste discharge order for Rainbow Conservation Camp

Joe Naiman

Village News Reporter

The Regional Water Quality Control Board rescinded the RWQCB waste discharge order for the Rainbow Conservation Camp.

The 6-0 RWQCB vote Sept. 14, with Megan Blair absent, approves the rescission of the waste discharge order. The facility is still subject to waste discharge restrictions, but the facility is now part of the County of San Diego’s Local Agency Management Plan for on-site wastewater treatment systems and the discharge requirements will be regulated by the county's Department of Environmental Health and Quality.

The Rainbow Conservation Camp is in the 8200 block of Rainbow Heights Drive. The California Department of Corrections and Rehabilitation has closed the Rainbow Conservation Camp, but the California Department of Forestry and Fire Protection will take over that facility.

The on-site wastewater treatment system includes a bar screen, a flow equalization tank, an anoxic basin, an aerobic basin, a clarifier, and a sludge storage tank. The treatment system collects wastewater from the mess hall, kitchen, offices, shop building restroom, barracks which include toilets and showers, laundry facility, and recreation building.

The RWQCB adopted the waste discharge order for the Rainbow Conservation Camp on April 8, 2009. The order established requirements for the discharge of domestic wastewater from the on-site wastewater treatment system.

The State Water Quality Control Board has a water quality control policy for siting, design, operation, and maintenance of on-site wastewater treatment systems. That policy established a risk-based and tiered approach for regulation and management of on-site wastewater treatment system installations and replacements, and the policy also allows the Regional Water Quality Control Board to approve a Local Agency Management Plan in which the local agency regulates and enforces the waste discharge requirements. The RWQCB approved the County of San Diego's Local Agency Management Plan in April 2015.

The RWQCB has issued four staff enforcement letters for Rainbow Conservation Camp violations. The California Department of Corrections and Rehabilitation failed to report sewage sludge monitoring in 2014, and the total dissolved solids effluent limitation was exceeded in 2015, 2016, and 2021. In 2016, the sulfate effluent limitation was exceeded. In 2021, the effluent limitations for iron, nitrate, manganese, and total suspended solids were exceeded.

Although the facility had violations of effluent limits in the past, it no longer houses inmates and thus no longer consistently generates the adequate wastewater flow for proper operation of the package treatment plant.

The enrollment of the facility in the general order will not only transfer compliance responsibility to the county but will also allow use of the septic tank for treatment and disposal of wastewater when the facility does not generate enough wastewater to sustain the package treatment plant’s activated sludge treatment process. RCWQB staff inspected the facility Nov. 1, 2021, and did not observe any violations of the requirements specified in the waste discharge order.

The tentative rescission of the waste discharge order was released for a 30-day public review and comment period March 9. The only public comment received by the April 8 deadline was from the county’s Department of Environmental Health and Quality.

DEHQ noted that the facility is in the Vallecitos Hydrologic Subarea of the DeLuz Hydrologic Area and thus within the geographical area described in the Basin Plan and Final Technical Report for Total Nitrogen and Total Phosphorus for Rainbow Creek. The RWQCB responded that the rescission order does not modify waste discharge requirements and that provisions to implement the Rainbow Creek limits are more appropriately placed in other documents.

The enrollment under the state general order rather than a specific RWQCB order allows the regional agency to focus its resources on discharge entities not eligible for the state general order.

The rescission of the RWQCB waste discharge permit eliminates the need for the California Department of Forestry and Fire Protection to submit monitoring reports and pay fees to the State Water Quality Control Board. CalFire will be required to submit all waste pumping records and proposed treatment system upgrades to the County of San Diego.