This is the presentation from the POB meeting on 10.20.2019. This slideshow was delivered by: David Baker, Lauren Ice, and Raymond Slade.

2. 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

3. Blanco River is Beautiful

4. The Blanco River is a Place to Swim

5. The Blanco River is Irreplaceable

6. The Blanco River is Our Legacy

7. 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.

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

9. 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.

10. City of Blanco Discharge Route
Impacts Downstream Landowners

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

12. 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

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

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

16. City of Blanco Discharge Oct. 18 2019

17. 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.

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

19. 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.

20. 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

21. • 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

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

23. 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

24. 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

25. 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.

26. 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

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

29. 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.

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

31. 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. *

32. 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.

33. 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

34. 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.

35. 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.

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

37. 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

38. 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

39. 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/

40. 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

41. 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

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

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

44. 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

45. 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

46. Links to additional information follow this slide
Questions?

47. 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.

48. 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

49. Supplemental information

50. 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

51. 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

52. 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

56. 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

57. 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

60. • 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.

62. 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

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

64. 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.

65. 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.

66. 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

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

69. 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

70. 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

71. 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

72. 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

73. 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.