POB Membership Meeting Presentation 10/20/2019

1. Protect Our Blanco Membership Meeting October 20th 2019 Water Quality Threats to the Blanco River from Wastewater Discharge David Baker , Executive Director, WVWA Lauren Ice- Counsel POB, Frederick, Perales, Allmon & Rockwell, P.C. Raymond Slade, Jr, -Certified Professional Hydrologist POB Board of Directors JT Morgan, Dobie Benson, Ann Ahrens, Gwen Flory, Joe Day, David Baker, Mark Watson

2. Blanco River is Beautiful

3. The Blanco River is a Place to Swim

4. The Blanco River is Irreplaceable

5. The Blanco River is Our Legacy

6. Current Objective of POB To stop the City of Blanco from discharging treated effluent into the River and to partner with the City in promoting a healthy and productive ecosystem in the Blanco River. The POB strives to protect the River through land application and beneficial reuse of treated wastewater effluent.

7. Municipal wastewater treatment options Fertilizer for fields Bio- solids fertilizer TCEQ permits all wastewater treatment facilities which must follow State standards

8. The effluent is dangerous even when treated to TCEQ standards. Not addressed by TCEQ permits are dangerous toxins such as Endocrine Disruptors, Pharmaceuticals minor elements, pesticides, and herbicides.

9. City of Blanco Discharge Route Impacts Downstream Landowners

10. Blanco Wastewater Plant Unnamed Ditch Discharge Route to The Blanco River Blanco River Discharge point

11. City’s own information, although not consistently documented, shows they began discharging consistently in October 2018: MONTH TOTAL DISCHARGE DAILY AVERAGE October 2018 3,076,000 gallons 99,226 gal/day November 2018 2,057,000 gallons 68,567 gal/day December 2018 3,418,000 gallons 110,258 gal/day January 2019 5,422,000 gallons 174,903 gal/day February 2019 3,985,000 gallons 142,321 gal/day March 2019 ~4,063,000 gallons 131,065 gal/day April 2019 4,132,000 gallons 137,733 gal/day May 2019 ~6,887,600 gallons 222,181 gal/day June 2019 4,191,000 gallons 139,700 gal/day July 2019 3,551,000 gallons 114,548 gal/day August 2019 3,591,000 gallons 115,839 gal/day

12. Results of wastewater discharges spring of 2019 downstream from the Cities discharge Blanco River

13. June, July, August 2019 139,700 gal/day 114,548 gal/day 115,839 gal/day

14. City of Blanco Discharge Oct. 18 2019

15. TCEQ allows nitrogen and phosphorus (nutrients) levels much higher than required to protect health and prevent eutrophication and algae. Downstream flow is expected to dilute effluent and channel vegetation is expected to absorb the nutrients.

16. TCEQ Effluent water quality limits are not protective enough of our Hill Country Streams and Rivers

17. Water-quality Data from Blanco effluent discharges: June-Aug 2019 • Phosphorus: For weekly grab samples, 8 of the 12 samples exceeded Interim 1 levels and 12 of 12 exceeded final discharge limits. • Dissolved oxygen: For daily grab samples, 57 of the 92 values did not meet criteria for dissolved oxygen. The criteria level for D.O. is the same for Interim 1 and final discharges.

18. Blanco WWTP - Compliance Record • Monthly compliance status available from Apr 2016 - Jun 2019 • During that 39 month period the following are reported: • 18 months—significant non compliance— no data reports from plant including every month in 2018 • 2 months—only known compliance • 9 months—unknown compliance status (reason not identified) • 6 months—other violations (mostly no reports) • 6 months—water-quality violation • 1 month—outfall discharge violation Jan 2019 report--188 mgd flowed through the plant (reporting error?) • Last reported sample: Apr. 30, 2019, E. COLI. Bacteria was 687 col/100 mL—4.5 times greater than EPA recommended limit for recreational water • Despite these infractions, the Plant has not had an informal or formal enforcement action during the last at least 5 years https://echo.epa.gov/detailed-facility-report?fid=TX0054623&sys=ICP

19. • Blanco has not responded to FOIA request or TCEQ with required monitoring data for its previous land application, suggesting they have not been tracking how much effluent was irrigated or the pollutant levels of the effluent. The City repeatedly failed to report Discharge Monitoring Reports to EPA on time--often between 100-200 days late. The reports submitted show that Blanco has frequently exceeded permit levels for effluent. • For example, TCEQ sampling downstream from plant shows bacteria levels to exceed safe recreation levels 10 % of time

20. Blanco WWTP Quarterly Compliance Summary 2016 2017 2017 2018 2019 https://echo.epa.gov/detailed-facility-report?fid=TX0054623&sys=ICP

21. Algae threat from wastewater • Effluent contains high levels of nutrients—phosphorus (P) and nitrogen (N) which often cause eutrophication*, death of biological species, and algae in streams. • Studies show effluent discharges to be the major source of P and N in Central Texas streams. • Based on EPA, P levels greater than 0.02 and N levels greater than 0.25 can cause eutrophication in Cen Tex streams * Excessive nutrients (N and/or P) in water leading to algae and death of biological species due to lack of oxygen

22. To prevent eutrophication Phosphorus (P) < 0.02 and Nitrogen (N) < 0.25 • However, for Blanco effluent: Currently: no limit for P levels For Interim I stage: P less than 3 (150 times too high) For Final stage: P less than 0.9 (45 times to high) • No limit for current or future levels of N Blanco River below Blanco WWTP

23. Lack of effective TCEQ management of wastewater facilities • TCEQ has a “self audit” program. • TCEQ makes infrequent visits to inspect facilities and announces such visits in advance. • Violators are typically given multiple “Notice of Violation” written warnings, even for the same offenses, and given extended periods to become compliant. The next step is administrative orders which are seldom used. This can be followed by civil enforcements (with fines) and finally criminal charges but these are rarely used. Additionally, some violators pay enforcement action fines rather than becoming compliant– perhaps the fines are cheaper than the cost of becoming complaint.

24. Water quality Impaired Streams (in red) Many if not most likely impaired due to wastewater effluent discharges https://tceq.maps.arcgis.co m/apps/webappviewer/index. html?id=b0ab6bac411a49189 106064b70bbe778

25. Blanco WWTP and the Blanco River Water Quality Monitoring Texas Clean Rivers Program Blanco IH 35 San Marcos headwater

26. Conclusion ● The City of Blanco has been and is discharging and they need to immediately STOP discharging wastewater into the Blanco River. ● The City of Blanco is charged with being good stewards and respectful neighbors to promote a healthy and productive Blanco River ecosystem. ● The City must withdraw the draft permit request that would increase discharge to 1.6 million gallons per day. The permit should be amended to remain at the current level and irrigated or reused on available land adjacent to the treatment plant. ● A comprehensive One Water Land and Water Use Plan should be developed to serve as a model for the Texas Hill Country.

27. Lauren Ice Legal Counsel to Protect Our Blanco Frederick, Perales, Allmon & Rockwell, P.C

28. Why demand more from the City of Blanco? The City has a long history of non-compliance and failure to monitor/report: 1. The City has failed to report and failed to track its discharges. ○ Dec. 2016 – Jan. 2019 - 31 out of 34 months’ DMRs were submitted late, two never at all. ○ 8 incorrectly reported that no discharge occurred. 2. The City is still regularly violating effluent standards. ○ Nov 2018 – City exceeded TSS daily average and multiple low dissolved oxygen levels (TCEQ reported) ○ Dec 2018 – City exceeded TSS daily average ○ Jan 2019 – City exceeded TSS daily average and flow ○ Apr 2019 – City exceed E.coli limit of 399 CFU with a reported 687 CFU! 3. The City is not meeting TCEQ’s new standards for Phosphorus and Dissolved Oxygen. ○ Despite the new plant being up and running, the City’s records indicate effluent is exceeding proposed Phosphorus limits by 8-20 times and dissolved oxygen is regularly too low. 4. We still have no idea how large the problem is. ○ Nov 2018 – TCEQ investigators found evidence of an unauthorized discharge that was never reported. ○ Feb 2019 – City was inaccurately calculating values, and not reporting all required results. 5. The City is not irrigating according to its permit. The City has failed to maintain a long-term contract for irrigated land. ○ The City failed to monitor and retain records when land applying effluent. * Despite these infractions, the Plant has not had an enforcement action in more than 5 years. *

29. Deadline or Event April 24, 2015 City of Blanco issued CWA/TPDES permit Nov 10, 2016 City of Blanco submitted Application for a major amendment to increase capacity to 1.6 MGD and remove irrigation component July 18, 2018 Staff issued Notice of Application and Preliminary Decision (NAPD) and Draft Permit Aug 23, 2018 Staff held public meeting. Sept 24, 2018 Public comment period closed. Aug 7, 2019 Staff issued the Response to Comments (RTC) and their final decision letter. Sept 6, 2019 POB and others submitted requests for Contested Case Hearing. About two weeks after hearing request Notice of upcoming TCEQ Commissioners’ public meeting on the hearing request is usually 35-45 days before the Commissioners’ meeting to consider the hearing requests. In the meantime, Applicant and Staff will file responses to hearing requests. Requestors may file replies. 30 to 60 days after Commissioners order Public notice of a preliminary hearing will be mailed and published. An Administrative Law Judge (“ALJ”) from SOAH will name parties and set a procedural schedule. ~ 4 months after prelim hearing Hearing on the Merits. 30 to 60 days later Recommendation by ALJ called Proposal for Decision (“PFD”), which recommends either denial of permit, granting of permit, or granting of permit with special conditions. 30 days later (or more) Meeting of the Commissioners to consider the PFD, and approve, deny, or modify PFD. 25 days later Deadline to file motion for rehearing - a prerequisite to any appeal of the decision to district court. 30 days after motion for rehearing is denied, is the deadline to file appeal in district court.

30. General threats to water quality and human health from proposed municipal wastewater discharges by the City of Blanco By Raymond Slade, Jr, Certified Professional Hydrologist

31. Mixture of natural streamflow and wastewater for Blanco River https://waterdata.usgs.gov/ nwis/uv?site_no=08171000 Flow upstream from WWTP varies from near 0 to billions of gpd. 25% of time, flow upstream from WWTP less than 1.6 mgd IH 35 Blanco WWTP outfall Final Permit request to discharge 1.6 mgd Therefore, if permit request approved, total flow in river downstream from WWTP dominated by (at least half) effluent 25% of time. Wimberley Current permit 225,000 gpd. Permit request would increase outfall 600 percent which would likely increase health threat and algae.

32. Little if any vegetation in typical Hill Country stream channels and almost every stream is dry on occasion. Therefore dilution and uptake of WWTP nutrients limited.

33. Barton Creek below Lost Creek effluent irrigation Blanco River below Blanco WWTP

34. E. Coli. bacteria immediately downstream from Blanco WWTP outfall Best fit linear trend indicates 75% increase from 1997-2018 EPA recommended limit for recreational waters (126): 4% illness at this level 10% of samples exceed EPA limit All water-quality data from TCEQ sampling site 12668 https://www80.tceq.texas.gov/SwqmisWeb/public/crpweb.faces

35. Year Total suspended solids during low-flow conditions on the Blanco River immediately downstream from the Blanco WWTP outfall Best fit linear trend All water-quality data from TCEQ sampling site 12668 https://www80.tceq.texas.gov/SwqmisWeb/public/crpweb.faces Based on trend line, TSS values have more than tripled since 1997 3

36. USGS streamflow studies show 9 mgd lost in Blanco R. channel from Chimney Valley Road to San Marcos Within 1/2 mile of river from WWTP to San Marcos are at least 200 water-supply wells including 13 public water-supply wells Public Water Supply Number of wells LSR WSC 1 John Knox Ranch Camp 1 El Rancho CIMA 3 Cedar Oak Mesa WSC 2 Wimberley 4 Granite Creek WSC 2 Wells within 1/2 mile of the Blanco River downstream from WWTP could received effluent from the river. Blanco Water wells in upper part of Blanco River area Wells within 1/2 mile of river shown in green https://pubs.usgs.gov/of/2002/ofr02-068/

37. Wells within 1/2 mile of the Blanco River in lower part of Blanco River area San Marcos Wimberley https://www2.twdb.texas.gov/apps/waterdataint eractive/GroundwaterDataViewer/?map=desal

38. Emerging contaminants • Wastewater discharges contain many pharmaceuticals, personal care products, surfactants, various industrial additives, and numerous organic chemicals identified as Endocrine Disrupting Chemicals (EDCs). • U.S. Geological Survey studies downstream from 10 wastewater treatment plants documented 78 EDCs in wastewater discharges, of which 37 are prevalent in most such discharges. http://digitalcommons.unl.edu/usgsstaffpub/66 https://toxics.usgs.gov/highlights/whatsin.html

39. Large portion of many drugs not metabolized thus are excreted Unused drugs often disposed by flushing 2

40. Stream or reservoir Emerging contaminants not removed by conventional WWTP or WTP. However, technology exists for removal.

41. What EDCs Influence? ● Endocrine Systems Produce: ○ hormones ○ chemicals ○ messengers Source: University of Maryland Medical Center • Regulates: – mood – growth & development – tissue function – metabolism – sexual function – reproductive processes Greater concern to fetuses and newborn babies because they are the most vulnerable. https://www.epa.gov/endocrine-disruption

42. Emerging contaminants (cont.) ● Some EDCs detected in wastewater represent estrogenic pesticides and pharmaceuticals, which operate through estrogen receptors in their target cells--their effects are additive. ● Therefore, a minimally safe exposure level does not exist because any dose adds to natural estrogens already present. ● Wastewater contaminated water supplies will produce continued exposure and cumulative levels of estrogenic hormonal chemicals in humans. http://www.awra.org/impact/issues/0705impact.pdf https://www.sciencedirect.com/science/article/pii/S2405665016300361

43. Links to additional information follow this slide Questions?

44. CALL TO ACTION 1. Reach out to the mayor and city council and State Reps, let them know that you are a member of POB and fully support the efforts of POB and: 2. Make it clear the current dumping of effluent into the Blanco River is not acceptable and should immediately be replaced with irrigation and reuse; 3. Encourage the City to work with POB and the Meadows Center for Water and the Environment to improve the irrigation potential on the City’s 110 acres 4. Urge the Blanco City Council to adopt the attached One Water resolution; 5 Write to the Blanco View; report what you have seen as far as deterioration of the Blanco and emphasize the importance of that waterway to our city, county and state; 6. Insist the City lowers the permit to a number that will accurately reflect our growth over the next 10 years; we have no need to jump from 225,000 gallons to 1.6 MILLION gallons daily.

45. Blanco City Council Members Mayor Martha Herden mayor@cityofblanco.com Councilmember Tony Vela tonyvela@cityofblanco.com Councilmember Matthew Lewis mattlewis@cityofblanco.com Councilmember Martin Sauceda martinsauceda@cityofblanco.com Councilmember Keith McClellan keithmcclellan@cityofblanco.com Phone: (830) 833-4525 Blanco County News: editor@blanconews.com *Is your representative not listed? Visit: https://wrm.capitol.texas.gov/home & find out.* Blanco County Commissioners Tommy Weir tweir@co.blanco.tx.us (830) 833-5331 Emil Ray Uecker blcomm2@co.blanco.tx.us (830) 868-4471 Chris Leismann blcomm3@co.blanco.tx.us (830) 825-3270 Paul Granberg pgranberg@co.blanco.tx.us (830) 833-1077 State Officials Representative Erin Zwiener District45.Zwiener@house.texas.gov (512) 463-0647 Senator Dawn Buckingham dawn.buckingham@senate.texas.gov (512) 463-0124

46. Supplemental information

47. E. Coli bacteria in the Blanco River immediately upstream from Wimberley All water-quality data from TCEQ sampling site 12663 Site is about xx miles upstream from mouth of Cypress creek Xx of yy samples exceed 126 cfu/100 mL—value recommended by EPA as max level for bodily contact water. At this level 4% of people in contact with water became ill. 399 and 126 https://www.epa.gov/sites/prod uction/files/2015- 10/documents/rwqc2012.pdf EPA recommended limit for recreational waters (126): 4% illness at this level

48. Trends in total suspended solids in the Blanco River immediately upstream from Wimberley Best fit linear trend Linear trend documents values to have increased 58% since 2003 https://www80.tceq.texas.gov/SwqmisWeb/public/crpweb.faces All water-quality data from TCEQ sampling site 12663

49. The Blanco River losses up to 9 mgd thus possibly impacting hundreds of wells proximate to the river. The impacted wells represent more than a dozen public water-supply wells which include Wimberley

50. Blanco River flow varies—on average for 3 months each year, river flow will be at least one-half effluent if Blanco plant expanded to discharge 1.6 mgd

51. USGS has been presenting online current and historic streamflow discharge and water-quality data for many years at many sites. The water quality data can be used to assess current and historic stream degradation due to WWTPs. The current streamflow discharge data can be used to identify current mixture percent of runoff and effluent which identifies dilution of effluent thus current water-quality conditions. https://maps.waterdata .usgs.gov/mapper/inde x.html?state=tx

52. • Proper irrigation on adequate soils provides natural filtration of contaminants thus reducing chance of illness from permitted and non permitted pollutants. TCEQ is currently working on rules to make it easier to beneficially reuse wastewater, without having to set aside as much land under a TLAP, which Blanco could take advantage of, but only if it kept its land application provisions in its permit. TCEQ expects to implement the rules by the end of the year.

53. https://texaslivingwaters.org/ensuring-one-water-delivers-for-healthy-waterways/ https://www.cgmf.org/blog-entry/303/One-Water-The-Future-of-Land-and-Water-in- Central-Texas.html https://www.cgmf.org/p/one-water-report.html http://uswateralliance.org/initiatives/listening-sessions/seven-big-ideas

54. https://texaslivingwaters.org/one-water-in-action/

55. Land application and beneficial reuse are the Land application and beneficial reuse are preferred method of disposal for the City of Blanco and the Blanco River. ● Even though the new plant is supposed to treat to a better standard than the old plant, it is not designed to (nor does any version of the current or Draft permit require it to) treat the wastewater to levels that would protect the Blanco River in the case of a direct discharge. ● Proper irrigation on adequate soils provides natural filtration of unwanted contaminants. ● Proper irrigation also provides a buffer from pathogenic bacteria and parasites that can cause disease and illness when ingested, or from other emerging contaminants that are not currently regulated. ● TCEQ is currently working on rules to make it easier to beneficially reuse wastewater, without having to set aside as much land under a TLAP, which Blanco could take advantage of, but only if it kept with its land application provisions in its permit. They expect to implement the rules by the end of the year.

56. https://waterblogue.com/2016/09/26/lets-compare/ The decentralized concept of “waste” water management is the idea that “waste” water is most effectively and efficiently managed by treating it – and reusing it – as close to where it is generated as practical.

57. In many situations, the decentralized concept offers a “waste” water management system that is: • More fiscally reasonable • More societally responsible • More environmentally benign The “triple bottom line” of sustainability

58. https://therivardreport.com/zero-net-water-sustainable-alternative/ https://waterblogue.com/

59. Alternatives and solutions Preferred wastewater treatment technology in the Hill Country http://wimberleywatershed.org/wp-content/uploads/2019/04/PartenReport.pdf Water reuse https://therivardreport.com/zero-net-water-sustainable-alternative/ City of Austin proposed rule changes for wastewater discharges http://www.austintexas.gov/department/proposed-wastewater-management-rule-revisions Wastewater discharge issues and solutions by the Greater Edwards Aquifer alliance https://aquiferalliance.org/waste-water-discharge/ Senate bill to restrict wastewater discharges in Cen Texas streams https://www.kut.org/post/bill-seeks-restrictions-dumping-treated-wastewater-central-texas-creeks

60. References for additional studies (cont.) Decentralized systems and threats from wastewater systems • A city of Austin report entitled "Wastewater disposal practices and change in development in the Barton Springs Zone" http://www.hillcountryalliance.org/uploads/HCA/WastewaterBartonSprings.pdf • A report by Dr. Lauren Ross entitled "Land Applied Wastewater Effluent Impacts on the Edwards Aquifer" http://www.hillcountryalliance.org/uploads/HCA/EAWastewaterImpact.pdf • US. Geological Survey website on toxic substances in wastewater https://toxics.usgs.gov/investigations/cec/wastewater_treatment.html • Information by David Venhuizen about decentralized non potable reuse of wastewater http://www.venhuizen-ww.com/ and https://waterblogue.com/ • A report by Susan Parten entitled "Analysis of Existing Community-Sized Decentralized Wastewater Treatment Systems” http://www.ndwrcdp.org/documents/04-DEC-9/04DEC9RD_Research_Digest.pdf • EPA interactive website presenting information on wastewater violations https://echo.epa.gov/facilities/facility-search/results • KVUE TV report on "Should treated wastewater be dumped into Central Texas waterways?" https://www.kvue.com/article/news/should-treated-wastewater-be-dumped-into-central-texas- waterways/269-588834547 and • KVUE TV report on threats from wastewater discharges https://www.kvue.com/article/news/investigations/defenders/the-dirty-truth-about-texas- water/269-342366238 • TCEQ webpage on existing and pending municipal wastewater permits https://www.tceq.texas.gov/permitting/wastewater/municipal/WQ_Domestic_Wastewater_Permi ts.html

61. References for additional studies Organic compounds in wastewater and water supplies • Occurrence of Selected Pharmaceutical and Organic Wastewater Compounds in Effluent and Water Samples from Municipal Wastewater and Drinking-Water Treatment Facilities in the Tar and Cape Fear River Basins, North Carolina, 2003-2005 http://pubs.er.usgs.gov/usgspubs/ofr/ofr20091046 • Water-Quality Data for Pharmaceuticals and Other Organic Wastewater Contaminants in Ground Water and in Untreated Drinking Water Sources in the United States, 2000-01 http://pubs.er.usgs.gov/usgspubs/ofr/ofr20081293 • Effect of On-Site Wastewater Disposal on Quality of Ground Water and Base Flow - A Pilot Study in Chester County, Southeastern Pennsylvania, 2005 http://pubs.er.usgs.gov/usgspubs/ofr/ofr20071253 • Occurrence of organic wastewater contaminants, pharmaceuticals, and personal care products in selected water supplies, Cape Cod, Massachusetts, June 2004 http://pubs.er.usgs.gov/usgspubs/ofr/ofr20051206 • Water-quality data for pharmaceuticals, hormones, and other organic wastewater contaminants in U.S. streams, 1999-2000 http://pubs.er.usgs.gov/usgspubs/ofr/ofr0294 • Occurrence of Organic Wastewater Compounds in Selected Surface-Water Supplies, Triangle Area of North Carolina, 2002-2005 http://pubs.er.usgs.gov/usgspubs/sir/sir20075054 • Organic compounds downstream from a treated-wastewater discharge near Dallas, Texas, March 1987 http://pubs.er.usgs.gov/usgspubs/wri/wri934194

62. References for additional studies (cont.) Water quality threat from phosphorus • North Bosque River: A TMDL Project for Phosphorus https://www.tceq.texas.gov/waterquality/tmdl/06-bosque.html • Effect of the restricted use of phosphate detergent and upgraded wastewater- treatment facilities of water quality in the Chattahoochee River near Atlanta, Georgia http://pubs.er.usgs.gov/usgspubs/ofr/ofr9499 • Review of Phosphorus Control Measures in the United States and Their Effects on Water Quality http://pubs.er.usgs.gov/usgspubs/wri/wri994007 • New Technologies Aim to Remove Excess Phosphorus http://twri.tamu.edu/newsletters/newwaves/nw-v16n3.pdf • Nitrogen and Phosphorus in a Stretch of the Guadalupe River, Texas, with Five Main- Stream Impoundments http://www.springerlink.com/content/t2h511051312n772/ • Handbook of Detergents: Environmental impact http://books.google.com/books?id=WM0fiQuH7w0C&printsec=frontcover&source=gbs _v2_summary_r&cad=0#v=onepage&q=&f=false • Phosphorus-free Fertilizer http://www.american-lawns.com/grasses/phosphorus.html

63. References for additional studies (cont.) Wastewater irrigation Studies have shown that the long-term application of wastewater onto land can be done without damage to the environment. One such study “Impact of long-term application of wastewater” available at http://www.webpages.ttu.edu/cfedler/research/landapps/asae-2055.pdf presents such an example. The EPA conducted 8 studies at 8 sites in 7 states, each entitled “Long-term effects of land application of domestic wastewater” and found no adverse impacts on the environment. An example of one of the reports (Vineland New Jersey) is at https://books.google.com/books?id=K22aKDQB42UC&printsec=frontcover&source=gbs _ViewAPI#v=onepage&q&f=false 40 The other studies were conducted in Camarillo, California; Dickinson, North Dakota; Hollister, California; Mesa, Arizona; Milton, Wisconsin; Roswell, New Mexico; and Tooele, Utah.

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