Tuesday, July 12, 2016

County’s letter to TCEQ

The morning after the Commissioner’s Court unanimously passed a Resolution opposing the Denali permit application, Judge Paul Pape sent this strongly worded letter to the TCEQ. Kudos to the Court for standing up to this ill-conceived proposal! Well done, one and all!!

Another citizen speaks

At Monday’s Commissioner’s Court session, Chris Denison read this comment that was submitted to the TCEQ regarding the Denali Permit Application.

The area of Bastrop County being considered for sewage dumping is underlain by a rock unit called the Calvert Bluff Formation. This unit consists of layers of sands, shales and lignites, sometimes cut by sand-filled channels. All of the aquifer sands are connected to some extent, vertically and laterally. Water wells can produce from the layered sands at fairly low rates, but if you are fortunate enough to have a well that produces from a channel sand, copious amounts of water can be produced.

The Calvert Bluff dips (is inclined) to the southeast at about 100 feet to 200 feet per mile. For example, I have property on Lone Star Road, to the southeast of the intended dumping area, and I am producing water from a sand at 300 feet. That sand comes to the surface somewhere between 3 and 6 miles away, which is where the sludge will be dumped. That is where my aquifer sand is recharged.

Surface water soaks into the ground and slowly moves through the aquifer, spreading vertically and laterally, reaching my well possibly years to decades later. Any pollutants on the surface of the recharge area will be transferred into the aquifer and will eventually reach my well. Hundreds of household wells down-dip from the proposed dumping area are potentially at risk.

As an illustration of what will happen, during WWII what is now Livermore Labs in California was an airbase. On grassed areas of the airbase, oil-coated aircraft engines were washed with carbon tetrachloride (dry-cleaning fluid), which “disappeared”. Decades later, a plume of contaminated groundwater is moving towards Livermore City water wells.

Sewage sludge is notorious for containing pharmaceuticals flushed down toilets and heavy metals, including lead, mercury, arsenic and cadmium, from various household cleaning products. Complex molecules from the pharmaceuticals will break down, but the surviving molecular fragments and the heavy metals will be washed into the aquifer. I will have to pay for tests to determine when the pollutants reach my well. When this toxic chemical soup eventually appears, I will not be able to use the water in my house, for my animals, or for irrigation. What do I do then - move?

Monday, July 11, 2016

A citizen speaks

This comment was read at today’s Commissioner’s Court session by the author of this website.

Let’s start at the beginning. The guidelines for the sludging of America are contained in the EPA’s 503 sludge rule which was implemented in 1993. The TCEQ is just being a good foot-soldier reinforcing the EPA’s big lie that sludge is nothing but ordinary fertilizer and perfectly safe.

In case you’ve bought into the EPA’s greenwashing and think this is an OK idea, please look at the handout listing contaminants that have been found in sludge. Out of all those, only nine heavy metals and one pathogen – fecal coliform - are monitored for Class B biosolids. All the rest of those contaminants may legally be present.

Yes, the TCEQ knows exactly how unsafe Class B biosolids are. Just take a look at the excerpt from the Texas Administrative Code TAC 30 regulations. That section specifies how many days, weeks, months, years must pass before sludged land can be used for certain purposes. And that caution relates to only one pathogen - E. Coli.

So what does this mean for Bastrop county and its residents? The most pressing concern with this permit proposal is water resources. Please look at the two graphic handouts. The Wallace Farm, which has signed up for the free sludge, lies almost entirely over the Wilcox outcrop where rainwater replenishes the aquifer. Toxic components in that sludge would inevitably leach into the aquifer and also Cedar Creek when it rains heavily. That contaminated water would then radiate from the Wallace Farm by the aquifers’ underground streams. The creeks would move those pollutants into the Colorado river. And surface runoff would flow downhill to pollute neighbors’ land and water sources.

But, neither the TCEQ nor Denali Water Solutions would bear any responsibility for testing of neighboring wells that may become contaminated OR for maintaining county roads OR or compensating neighbors for loss of property value. There are Commercial Liability and Environmental Impairment policies in place for ten million dollars per occurrence. But how exactly does one unimpair toxic pollution? Interestingly, this policy is issued to the Wallace Farm in a mythical BAXTER county, Texas.

When Denali Water Solutions withdrew their application for a similar permit in Fayette county a few weeks ago, they emphasized that the residents had an “emotional attachment to the Colorado river”. Well, my attachment is to water that isn’t polluted by heavy metals and pathogens and chemicals and pharmaceuticals and and and . . . Those nasties have no business being dumped over an aquifer outcrop or in the Cedar Creek floodplain or on a site that has higher elevation than neighboring properties. Period.

The Resolution before you today would be an important step in the process of putting an end to this before it starts. It’s unthinkable that our precious water resources could be jeopardized by one landowner’s misinformed and naive idea that sludge is just harmless, “free-fertilizer”.

Video: Cedar Creek flood

This video was taken from the north side of Cedar Creek looking across the creek toward the northwestern corner of the Wallace Ranch. The flood meets the treeline about 25-30 feet above the creek-bed. If you could see under the treeline, the ranch pasture used to grow oats would be visible. This is by no means the highest the creek gets during floods.

Tuesday, July 5, 2016

How safe is sludge?

The Texas Administrative Code (TAC) addresses “Pathogen Reduction” in sludge with the following restrictions. That should tell you something about how “safe” sludge is:

(3) Site restrictions.

(A) Food crops with harvested parts totally above the land surface that touch the sewage sludge/soil mixture must not be harvested from the land for at least 14 months after the application of sewage sludge.

(B) Food crops with harvested parts below the surface of the land must not be harvested for at least 20 months after application of sewage sludge when the sewage sludge remains on the land surface for four months or longer prior to incorporation into the soil.

(C) Food crops with harvested parts below the surface of the land must not be harvested for at least 38 months after application of sewage sludge when the sewage sludge remains on the land surface for less than four months prior to the incorporation into the soil.

(D) Food crops, feed crops, and fiber crops must not be harvested for at least 30 days after application of sewage sludge.

(E) Animals must not be allowed to graze on the land for at least 30 days after application of sewage sludge.

(F) Turf grown on land where sewage sludge is applied may not be harvested for at least one year after application of sewage sludge when the harvested turf is placed on either land with a high potential for public exposure or a lawn.

(G) Public access to land with a high potential for public exposure must be restricted for at least one year after application of sewage sludge.

(H) Public access to land with a low potential for public exposure must be restricted for at least 30 days after application of the sewage sludge.

Texas Administrative Code
RULE §312.82 Pathogen Reduction

Download PDF

But even the supposedly “safe” sludge - Dillo Dirt - that you can buy at Home Deport is not so safe. You may remember that before the Austin City Limits Music Festival in 2009, Dillo Dirt was applied to the Zilker Park turf. When it rained and the turf turned to muck, the pathogens in the sludge sickened a number of people. This was not Austin’s finest hour thanks to a substance that is potentially very dangerous. You can read about that fiasco here.

Unfortunately pathogens are not the only danger lurking in sewage sludge. There are other contaminants in sludge from household use AND industrial waste AND agricultural/road runoff etc. that may include - heavy metals, synthetic chemicals & pesticides, hydrocarbons, petrochemicals, organochlorines, pharmaceuticals, steroids & hormones etc. Monitoring of these substances is limited. Regulatory ‘truth’ once again in denial of reality.