Page 8 - the NOISE January 2013

TENQUESTIONS
INTERVIEW WITH ADEQ
BY CHARLES SEIVERD | chuck@thenoise.us On Thursday, November15, after months
of waiting to hear whether Charles Graf, Senior Hydrologist at ADEQ would comment on studies completed at three uni- versities linking the death of native plants to the salinity found in reclaimed wastewa- ter, I made my way to the department’s new headquarters on Washington Street in the State Capitol district of downtown Phoenix. Previously, I had corresponded with Mr. Graff, both with phone calls and emails, asking him the department’s response to various questions raised in this series, such as the classifications of A+ and B class reclaimed wastewater, the department’s response to dying juniper trees on Route 89a near Se- dona, and whether it is a treatment plant’s own filtration process that dictates water quality gradient or whether the monitoring of chemical elements is endeavored by an independent entity.
Neither Mr. Graff, nor his superior, ADEQ Director Henry Darwin, returned request for comment on the Schuch study from the University of Arizona, the Xiang report from Colorado State University, or the Salinity Brochure produced by Texas A&M Univer- sity; requested on separate occasions via email, telephone message (in voicemail and secretarial notation), and certified mail.
When I arrived, the Department was celebrating its annual “Enviro Quality” em- ployee award ceremony, and Mr. Graff and his Water Quality Division Director, Michael Fulton, were gracious to oblige me a nearly hour long sit-down session, in which we politely discussed recent highlights in the area of reclaimed wastewater, including the department’s assumed liability to the pub- lic, its commitment to private interests, the responsibilities of the end user and provider when interpreting ADEQ’s water policy, and the truths of ADEQ being “ahead of the curve” when it comes to water policy, as recent statements to the press have implied.
The following is a portion of our conversa- tion.
Here’s the Schuch study [presented for comment to Mr. Graf in June 2012 and Mr. Darwin in September 2012], it’s from the Uni- versity of Arizona, dated 2005.
Essentially what it says is that the salinity of reclaimed wastewater is 500 magnitudes higher than potable water, and that’s based on Tucson’s A+ reclaimed wastewater. Her study looked at how it effected native plants and
found stunted growth as well as death among the plants she used.
Since coming across that study, the EPA turned me on to this study, from the University of Colorado, and this point blank states that re- claimed wastewater leads to necrosis among Ponderosa Pine trees.
Fulton: Did it talk about the reason?
It’s the salinity.
Fulton: Did it link it to salt?
Yes.
Fulton: M’kay. Hmm.
My question is — is it still prudent, with these studies that are coming forth, to ap- prove reclaimed wastewater on a pristine envi- ronment like the San Francisco Peaks?
Fulton: As far as what effect it has on trees? I don’t know. I would have to look at the studies. But it is one of many permitted uses of reclaimed water. I’ll look at the studies.
I’ll give you time to look through the studies, but I would like your comment.*
Fulton: Okay.
Graf: The one thing is the approved use of snowmaking up there.
That’s what it is. I’ve come across some in- formation that ADEQ relied on California’s ap- proval for snowmaking. And in that instance, the reclaimed wastewater for snowmaking that was approved was for pig slurry — to dis- pose of pig slurry over the winter months.
Graf: I don’t think that we relied on that study, because I don’t recall that study. We relied on a study in New England at the time that they were using for skiing — or, no! They were using it in snowmaking for winter disposal in New England ...
In Vermont —
Graff: — I think it was in Vermont, yeah ...
— it was later struck down by a municipal court; they indeed found it was too toxic to deal with.
Graf: You say toxic, but toxic is a very non- specific term.
These studies show the toxicity level of re- claimed wastewater on Ponderosa Pines.
Graf: Based on salinity, you’re saying.
Based on salinity.
Graf: Are you familiar with the new EPA Re- use Guidelines that just came out? The 2012 guidelines just came out about a month ago,
ADEQ’s new headquarters, in the backyard of the Old Governor’s Mansion.
it’s a revision of the ‘94 and 2004. It’s like this thick, it’s like 650 pages. There’s two sec- tions that relate to snowmaking, and it pulls together a lot of studies that have actually been done with snowmaking and reclaimed wastewater. I can actually forward that doc- ument to you, a PDF, which is about 30MB.
[The EPA record on file, in fact has only a one-page report on snowmaking with re- claimed wastewater, an article written by environmental engineer, Don Vandertulip, whose statements on its use at ski resorts have been shown to not involve skiing.]
The EPA representative I talked to, he agreed with the CSU study, but said ultimately the EPA does not regulate the use of reclaimed waste- water, it’s up to you guys. That ADEQ essen- tially makes the determination as to how that wastewater will be used.
Fulton: Well, we’ve established permis- sible uses — it’s certainly up to the end user — and the supplier to decide how they want to use the water and where they want to use it. We don’t actually, in cases with Snowbowl or any other end user, we don’t approve the
end use, we have a “list of approved end uses.” So, obviously, the end user and the suppli-
er have their own obligations to see that it’s used wisely and safely. Over-application of anything could lead to problems with trees. You can drown them too.
To Chuck’s point on snowmaking, it’s cer- tainly not going to be a level of intensity — of I think you were talking about Sedona and trees irrigated with reclaimed wastewater, is there any way to understand what caused those trees to be stressed and die? I’m not sure what the question was. But could it be too much salt? Could it be too much water? You can drown trees.
But it certainly is up to the end user to ap- ply according to rules, in a way that doesn’t — In the case with the rules, they’re written in
a way to make sure the reclaimed wastewa- ter doesn’t leave the site. We don’t really talk much about how the reclaimed wastewater might be beneficial to the end use, snow- making or otherwise.
Graff: As Mike said, it is between the sup- plier and the end user of reclaimed wastewa- ter, and if the end user is seeing some nega- tive impacts, from whatever type of use that could be, which could be irrigation turf or other end users that are allowed in our rule. It’s really between them and the supplier to resolve that issue.
Fulton: Here’s a real world example. Re- claimed wastewater is useful and usuable for turf irrigation, but some golf courses won’t take it because it’s too salty. So that’s the judgment applied by the end user. Not just because it’s allowed — “will we, should we” — it certainly is up to the end user and the supplier.
But in the wake of these studies, it just seems there’s an amount of pollutive effects
FROM LEFT: ADEQ’s Water Quality Director Michael Fulton & Senior Hydrologist Charles Graff
that ADEQ would say, “Hey, wait a minute, we should probably take a look at this substance once more, before we start to allow anyone to use it for ‘these’ kinds of activities?”
Graff: Right, and I think we should take a look at those studies too. But by the same token, we know that saline reclaimed waste- water burns turf on golf courses. And our rule allows the use of reclaimed wastewater to be used for turf irrigation, it’s used all over the state, on schoolyards, parks, you name it, residences.
So to be consistent we’d have to take a look at every single plant out there and try to make a determination as to what the im- pact of reclaimed wastewater would be*. I’m not saying there might not be an impact, but again, it is between the end user and the sup- plier of reclaimed wastewater. There’s some suppliers of reclaimed wastewater who are using RO in order to be able to keep that re- claimed wastewater as a resource. Using RO to cut just a bit of salt out of it, before they send it out, or at least they’re considering it before they send it for turf irrigation now. And actually the Sedona situation isn’t truly reclaimed wastewater, that’s a disposal, you could say it is equivalent to reclaimed waste- water, that’s part of their process, so we don’t classify that as reclaimed wastewater.
It is B+, not the A+ that’s coming out of Flagstaff. The B would mean it’s got some level of co-
liform in it but still pretty good, but it doesn’t meet the A level. The + means it’s denitrified, which is actually a ‘plus’ because it means the nitrogen’s been removed. So maybe there’s not enough fertilizer in that water, not enough nitrogen in that water, I don’t know. There’s a lot of factors when you’re looking at the content of what’s in water.
... the guys at Snowbowl are wanting to make that snowpack higher and higher every day, and if it’s not snowing out, it’s going to be supposedly cold enough out to make a big snow riff. You have all that reclaimed waste- water going to this environment that has not had a touch of salt in millions and millions of years.
Fulton: Well, there’s salt in every water. There’s salt in the water you get from the faucet.
In rainwater it’s less than a percent. So you see what I’m saying: as ADEQ is essentially the state arm of the Environmental Protection Agency, don’t you have an obligation to look into what may be a substance that causes pol- lution?
Fulton: I’ll look at these reports. I’ve not seen them.
Graf: Yeah, I’ve never saw this one, and I read that one, but it was six months ago. I did note she was attributing it to something of salinity ... Again, I’ll read it again.*
* As of press time, neither Mr. Graf nor Mr. Fulton had returned comment.
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