Wastewater Discharge - It's Not Good For Lakes (Part 3)

Refuting Those Arguments Made For Discharge Into Our Lakes

The petition filed by Leander and Granite Shoals made a number of assertions about why they  should be allowed to discharge treated wastewater effluent into the Highland Lakes, including Lake Travis. We dispute each and every one of their assertions, as do many others. The City of Austin took on the assertions, one by one, in their response to TCEQ.

With full credit given to City of Austin, we are providing their responses below. Please see COA's full response in pdf format HERE.

from COA Attachment 1
Mistatements in the Highland Lakes Petition

Petition Assertion, Page 2 - Lack of availability and expertise in operating advanced treatment units and unfamiliarity with tertiary treatment units were the reasons for the 1986 prohibitions:
In 1986, industry information was widely available on tertiary treatment. Extended aeration for nitrification, effluent filters for higher solids removal, chemical precipitation for phosphorous removal, and postaeration had been applied at a full scale throughout the country and overseas as well as in Texas. These technologies allowed plants to operate within the tertiary treatment effluent set in 30 TAC 319 of 5 mg/L BOD/5 mg/L TSS/2 mg/L NH3-N, 1 mg/L TP/ 6 mg/L minimum DO. Operators kept these plants running and in substantial compliance throughout this period.

Petition Assertion, Page 2 – Some wastewater treatment facilities treat to a degree where it is “virtually indistinguishable from, or in most cases, of higher quality than local untreated fresh water supplies”:
The untreatable recalcitrant organics that pass through treatment facilities alone would make this statement false. The pharmaceuticals, household chemicals, and undegradable fractions of wastewater can be successfully treated by soil bacteria after irrigation, but not through the short retention times of wastewater treatment facilities. The basic ionic balance of wastewater differentiates it from Highland Lakes water. Results from the United States Geological Survey (USGS) Toxic Substance Hydrology Program, including emerging contaminants from domestic wastewater, should provide ample evidence that the two waters are anything but “virtually indistinguishable” and are rarely “higher quality than local untreated fresh water supplies”. For more information, see the USGS website at: http://toxics.usgs.gov/regional/emc/

Petition Assertion, Page 2 – Treated effluent is now known as “reclaimed water”:
Treated effluent can mean anything from septage to primary clarifier effluent, to industrial wastes, to tertiary treated water. Treated effluent in general is not equivalent to reclaimed water. The degree of treatment for reclaimed water is even specified in 30 TAC 210. TCEQ’s Application to Use Reclaimed Water under 30 TAC 210 asks for the quality of “treated effluent to be used as reclaimed water”. The two are not synonymous and should not be confused in the petition.

Petition Assertion, Page 2– The Commission promotes direct reuse through 30 TAC 210:
The promotion of direct reuse by TCEQ is not at issue because the petition is about putting wastewater into the lakes making any resulting use downstream an indirect reuse.

Petition Assertion, Page 2 – The current prohibition and TLAP rules do not recognize reclaimed water as a “resource”:
TCEQ rules in 30 TAC 309.20 concerning land disposal of sewage effluent makes no judgments about the value of reclaimed water. Likewise, the current 30 TAC 311 rules containing the prohibition to discharge do not mention reclaimed water and are silent on whether it is considered a“resource”. However, 30 TAC 210.2 contains a very clear policy statement that reclaimed water that can be generated from a plant operating under TLAP rules or TPDES rules is considered a resource. Also, the prohibition and TLAP rules are concerned with the requirements for protection of water quality which does not require specific rulemaking to recognize as a resource.

Petition Assertion, Page 2 – Discharging wastewater into the Highland Lakes would recognize reclaimed water as a “resource”:
Reclaimed water is already viewed as a resource, and in fact is already being used as a resource by communities surrounding the Highland Lakes through direct reuse. The proposed indirect reuse by downstream public water supply intakes would make reclaimed water less visible as a resource than finding irrigation uses locally and concentrating efforts to use this resource under 30 TAC 210 as it was intended with the provision for land application.

Petition Assertion, Page 2 – Reclaimed water as a “resource” should make it into water supply:
Irrigation returns the water to the hydrological cycle as does discharge; but the benefits are felt more locally.

Petition Assertion, Page 2 – Unstated assumption that water rights downstream will be satisfied by wastewater thus freeing water supplies upstream for these Highland Lakes communities:
Petitioners have not demonstrated that their proposal actually reduces in any significant way the amount of water taken from the reservoirs. The golf courses, parks and other green spaces in these lake communities will continue to require irrigation from lake water. The proposed petition apparently suggests that rather than utilizing wastewater effluent for this irrigation, which is considered a conservation use, that the communities use either potable water or raw water from the lakes. Rather than promoting conservation the petition proposes a move away from conservation practices. The argument that large amounts of reclaimed water are being used to irrigate cedar is specious. The most significant amounts of irrigation are for golf courses and other green spaces which of course will continue to need a water supply, so the proposal does not reduce demand on the lakes. In addition, Texas water rights are seldom as simple as Petitioners’ assumption would indicate. http://www.twca.org/downloads/newsletters/2006q3-confluence.pdf

Petition Attachment A, Letter Dated February 6, 2009 from City of Leander – This letter was referenced on Page 3 of the Highland Lakes petition concerning an earlier petition from the City of Austin and Barton Springs Edwards Aquifer Conservation District to prohibit discharges into the contributing zone of the Barton Springs segment of the Edwards Aquifer. This petition was to protect the water quality and uses of streams in the contributing zone prevent further degradation of Barton Springs and groundwater
resources. Leander proposed that the petition would encourage “thousands of failing septic systems” in the contributing zone and would mandate irrigating “golf courses and tracts of cedars”
www.tceq.state.tx.us/permitting/water_quality/stakeholders/barton_onion.html. Neither of these allegations were factual as any central collection and treatment system that can discharge to a stream can be used in a land application system. Also, irrigation of golf courses and cedars is not mentioned in the petition and are only two of a myriad of land application uses for the wastewater generated in the contributing zone. The letter also likened the Hill Country streams covered under the Barton/Onion petition to the discharge and indirect reuse of communities downstream from Dallas-Fort Worth on the Trinity River. Obviously, these two systems are not comparable in either hydrology or background water quality. Also, neither of these systems is comparable to the Highland Lakes chain addressed by the current petition.

Petition Assertion, Page 5 – Granite Shoals regional wastewater study depends on ability to discharge into the Highland Lakes for feasibility and efficacy:
The subject report (Freese and Nichols, August 29, 2008) makes reference to the possibility of discharge into Lake LBJ, but does not depend upon it for feasibility of replacing some 2,000 septic tanks with a centralized collection system. The major limitation to efficacy and feasibility in this plan is the use of a conventional gravity wastewater collection system in the topography of Granite Shoals. The alternative design of grinder pumps and pressure collection system components is independent of subsequent treatment or land application options. The combined treatment and collection system cost is estimated at $6,572,686 in this report. The irrigation system and land costs for effluent disposal are estimated at $1,430,428. The remaining cost of the project is $3,788,328 for construction of lined storage ponds for the effluent. The ponds are 191 ac-ft in volume or 62 MG for a 300,000 gpd plant. It appears that the storage pond may be oversized as this allows 207 days of storage when the most conservative estimates would require a quarter of this cost. The facilities would be placed on the recently purchased 131 acres at the corner of Phillips Ranch Road and FM 1431. It does not appear from this report that the project is either infeasible or not in the best interests of Granite Shoals. In fact, with the apparent error in storage volume, the facilities may be more economical than presented in this report. http://www.twdb.state.tx.us/RWPG/rpgm_rpts/07048304730_GraniteShoals.pdf

Petition Assertion, Page 2 – The costs for land application are prohibitive and the costs for discharge are significantly less:
If there were neutral or beneficial water quality impacts of the proposed petition, choosing the least cost alternative would be warranted. However, it is not really a given that land application at a secondary or even tertiary treatment level will be more expensive than the treatment necessary to meet water quality standards in Lake Travis. This situation is similar to that of Hays County WCID No. 1 where a 0.25 MGD treatment facility (Phase 1) was permitted at an estimated cost of $1.6 Million capable of nutrient removal to the current industry technological limits (0.1 mg/L TP, 3 mg/L TN) www.soah.state.tx.us/pfdsearch/pfds/582/08/582-08-0202-pfd1.pdf.
This level would not be sufficient to prevent degradation of water quality in Lake Travis, but it is the best feasible using current technology that the petition relies on to have improved significantly since 1983. Using the above Granite Shoals costs and ratio of storage volumes, the irrigation system and storage pond would be around $ 500,000. However, treatment to this level is seldom necessary for land application disposal, and secondary treatment without nutrient removal would make the treatment cost closer to that proposed for Granite Shoals. Using both the Belterra (HCWCID No. 1) and the Granite Shoals cost estimates, the differential would be discharge of 0.25 MGD at $1,600,000 vs land application at $1,692,026. Although both of these estimates are preliminary, the savings of discharge may have been overestimated.

Petition Assertion, Page 2 – The discharge would benefit downstream users of the Highland Lakes:
The LCRA has conducted a water quality modeling study of Lake Travis that included scenarios for discharge of wastewater from communities that are currently land applying effluent. The included a 20 year projection of 10 MGD wastewater disposal at treatment levels with and without nutrient removal. This flow rate is approximately 0.99 % of the average flow of the Colorado River below Austin. However, if discharged, this wastewater has potential to degrade water quality to a degree that Lake Travis would become nutrient rich thus drastically increasing the problems of nuisance algae in the coves and ultimately the entire lake.
www.lcra.org/library/media/public/docs/water_WQ_LakeTravisFutureScenarios.pdf.
If algal growth is increased in the Highland Lakes, not only would there be adverse impacts to the contact recreation use of these lakes, but also annual operating costs of drinking water treatment will significantly increase. More activated carbon must be utilized to remove the objectionable taste and odors produced by the algae. In addition, expanded testing and treatment will be needed for the new classes of pollutants such as  pharmaceuticals and personal care product residuals that could enter the lakes.