Water Quality Complaint Re: Pleasure Cove Marina

Date: July 22, 2005
TO: CENTRAL VALLEY REGIONAL WATER QUALITY CONTROL BOARD
 
Good Morning Mark List, Senior Engineer, CVRWQCB

On July 17, 2005 I had the occasion to visit the Pleasure Cove Marina (new Name as of June 1, 2005) now being operated by new concessionaires Forever Resorts of Scottsdale AZ. This resorts sits on the south shores of Lake Berryessa, CA in a cove off of Wragg Canyon Road and CA Highway 128.  The following are my observations and require a follow up action by your Enforcement Agency to ascertain if the problem is severe enough to declare an emergency in the distribution of potable water and sewage treatment and effluent releases and NPDES releases. I have a long association with Lake Berryessa as far back as 1982. I also have two vacation homes as Steele Park Resort on Lake Berryessa.

My finding and observations are as follows:

1.  I found the water quality on 7/17/2005 at 1:30 pm at Lake Berryessa in this cove to be milky white-to-tan and opaque in color. In my many years at the Lake I have not experienced this poor of quality. I am an active boater and fisherman and use all of the lakes coves and surroundings for sport fishing and pleasure boating purposes.

2.  I had an opportunity to examine the water and unfortunately I did not take a sample of it. Nearby campers and children were swimming in this murky looking water. This date the outdoor temperature was 100 degrees.

3.  The resort was impacted and in high use with over 700 people estimated to be present and many families camping in tents along the waters shoreline.

4.  I looked at the water in four points along the shoreline and found the same presentation in water quality. I also notice soap suds, scum and petroleum film sheen residue on top of the water surface. The lake on this weekend had multiple launches of boats and there were over 200 boat and trailer combinations present.

5. I observed tent campers washing their dishes in the lake, unabated including food pots.

6.  I observed water cascading off the slopes below the trailer park spaces that sit on the edge of the lake. It may have been from people putting on sprinklers for fire reduction measures and the use of spray misters to cool their trailer areas.

7.  There was low water pressure in the resort and because of the high use the demand exceeded the water development capability and treatment process on Saturday and Sunday.  I was informed of this by a trailer resident whom I visited.

8.  I observed the washout of boats and trailers on the boat ramp, allowing water to be regenerated into the lake.

9.  This Lake supports downstream water irrigation purpose for Solano County and the Bureau of Reclamation resells water to Solano County cities for reuse and distribution. Also a major user of the Lake Water is Budweiser Brewery of Fairfield, CA.

10.  There is a new concessionaire and they are allowed 75 commercial houseboats to operate out of this resort and also 75 private houseboat permits could be allowed to Forever Resorts. Presently there are 7 private houseboats moored and 2 large 61’ commercial houseboats that arrived at this Resort after June 1, 2005. I have a major concern about this because the marina was never designed for houseboat operations.
 
11.  The subject of gray water and black water has been a problem at Lake Berryessa for many years. Where these houseboats are moored there is no in-line marine effluent pump out or lift stations pump out capabilities along the shoreline docks. Prior to the arrival of the two commercial houseboats it was discovered that the Resort management was pumping out these houseboats with a mobile suction sewage truck.  During the early part of February 2005 the pump out truck failed and remained out of service until June 30, 2005. It is unknown how these houseboats were serviced for sewage removal in the interim. On March 28, 2005 the BOR defaulted the Concessionaire of record a Steve Petty of Napa CA. They closed the resort to use on March 28, 2005 until May 28, 2005 Memorial Day weekend and reopened it on June 1, 2005 with the Forever Resorts in charge as the new Concessionaire. I was informed today that the sewage pump out truck is again non-serviceable and inoperable again after the recent repairs.

12.  In review of a Kleinfelder Engineers Report for Lake Berryessa completed for the BOR it reveals critical information related to water development and sewage treatment capabilities at this specific resort. In Chapter 9 of the Kleinfelder study which looks at the infrastructure and areas of concern to the Water Quality Board. C:\Documents and Settings\hank\My Documents\KleinfelderReport.pdf .

13.  There is inadequate sewage stations and toilets for the Resort and the impact of the large amount of users creates an highly unsatisfactory situation. There is only one bathroom that is plumbed for campers at present. A new bathroom in the camper area is in the construction phase near the entrance area to the resort.  There are also “Porta Toilets” and they appears to be not enough for the impact. It was learned from a former maintenance man that the resort used the sewage pump out truck to pump out the Porta Potties units and then in a off period day would download the trucks waste and send the effluent into the sewage basin of the resort in periods of low usage. I highly question this process in these days and a definite shock to the sewage systems.

14.  This resort has been under close scrutiny by other federal agencies and the CDF for failing to meet codes and many other matters.
 
15.  A full review of this resort and its procedures needs to be conducted. There are major questions of who holds the NPDES Discharge Permits for the Resort and where is the BOR involved in monitoring this resort sewage discharges, water treatment and distribution, marine pump out capability and possible contamination of the lake with fecal and gray water and black water.

16.  Likewise the permits for water treatment operators Class I and Sewage Treatment Operators need to be reviewed.

17.  In review of the CVRWQCB minutes of 18 October 2004 I found an entry Water Discharge Requirements Item 16 c. this was for a name change and/ownership. The gentleman in the list died on December 16, 2003. A Richard DeLooze and his wife predisposed him in 2001.  A contract was awarded by BOR with Steve Petty of Napa, contract date on May 20, 2004. It is unknown whether Mr. Petty requested a transfer of the permit Order 98-086 to his name or the Pleasure Cove Asset Management Group LLC. The status of this transaction is requested if Mr. Petty was granted the NPDES permits and other CVRWQCB permits to operate the resort. Likewise is requested to know if Forever Resorts took out a new NPDES permit and applied for the major changes in operation to the Water Control Board. The BOR  granted Forever Resorts in the June 1, 2005 contract major incentives that will alter the water quality. These items are the establishment of 500 new boat slips:  90 boat slips, which are to be provided in 90 days (September 1, 2005) from contract signature date, 150 houseboats, pleasure water craft rentals, party  boats, and other boats rentals,  150 new tent campsites along the waters edge. There are major incentives included in this 30-month agreement that was codified on June 1, 2005. Most alarming is they are allowed to open up an area known at the “Outback” that was a previous non-compliant area with your agency. They are to reopen this area and allow boat-in-camping. 

18.  This writer would also like to know if there are any pending enforcement towards this resort and open cases on file for Pleasure Cove Resort. On June 2, 2005 it changed names to Pleasure Cove Marina.

19.  A significant matter I learned from the Kleinfelder Report, was the water treatment system Backwash of filters drains directly into the lake.
 
Summary

I entertain that your agency should investigate this Resort and see if it is exceeding its NPDES discharge permits? If it is legally under the control of all permits required for sewage and water treatment. The houseboat issue and local review of how sewage waste is being managed and treated from the houseboats must be reviewed analyzed by professionals from your agency. I am most concerned about the overall water quality and the associated effect to the waters of the lake.