From: Mayor John Moser
Date: 1/2/02
Time: 9:33:01 AM
Remote Name: 208.193.186.91
Perhaps a short review of the situation is in order.
Several years ago, the U.S. Environmental Protection Agency (EPA) became involved in evaluating conditions of the Bosque River because of pollution concerns about Lake Waco. The EPA conducted tests and determined that the Bosque River had excessive concentrations of soluble phosphorus. The river was placed it on their Impaired Waterways (303d) list. This triggered a required corrective action. The EPA forwarded the matter to the State of Texas to develop a proposed plan to return the Bosque to acceptable water quality standards. The state's responsible agency is the Texas Natural Resource Conservation Commission (TNRCC). The TNRCC, in turn, created an informal group of "stakeholders" to develop a plan. These "stakeholders" included municipalities and industry groups in the Bosque River watershed who would be impacted by any corrective plan. Included in this group were the cities on the Bosque, dairy industry and other farm and ranch representatives. This group was known as the Bosque River Advisory Committee (BRAC). The group met at least monthly for more than three years. The group received technical assistance from various state agencies. Regrettably, the group was ultimately unable to reach consensus on a plan. All the research data generated by the BRAC's efforts were then forwarded back to TNRCC, whose responsibility it then became to develop a plan.
The "plan" they developed is known as a Total Maximum Allowable Load (TMDL). It is expressed in maximum amounts of various pollutants which may be released into the watershed (and ultimately into the river) by various entities. There are two basic types of "sources" of pollutants. These are "point sources", such as wastewater treatment plants (WWTP), and "non-point sources", such as agricultural operations. There are six "point-source" WWTP on the Bosque. These are at the cities of Stephenville, Hico, Iredale, Meridian, Clifton, and Valley Mills. These WWTP all operate under individual licenses issued by TNRCC. These licenses specify the quality and amount of effluent which may be released into the Bosque. Stephenville's WWTP was constructed in 1994 and designed to meet all known and anticipated state and federal requirements. It cost city taxpayers $4.6 million. The plant has consistently met all state and federal requirements. It operates at about 60% capacity and should have met the city's needs for many years to come. The city's license to operate the plant contains no CURRENT requirement to monitor, much less control, the amount of soluble phosphorus in the treated water released into the Bosque. We know from testing (voluntarily conducted), that in recent years city's WWTP phosphorus outflow currently ranges between 8 and 13 mg/ltr, depending on the season and weather. The annual average is about 10 mg. per liter. TNRCC's stated goal in the TMDL is to reduce phosphorus in the Bosque by 50%. To require a reduction from 10 mg/ltr to 1 mg/ltr is appreciably more than 50 percent.
Last year, the TNRCC forwarded its proposed TMDL to the EPA for review and approval. In December of last year, the TNRCC announced it's approval of TNRCC's recommended TMDL. This new TMDL contains a specific limit, in pounds per day, of soluble phosphorus which may be released into the river by the city's WWTP. The TMDL makes no provision for that quantity to ever be increased, for any reason. The amount is about 24 pounds per day. How did TNRCC arrive at this number? Good question! Our WWTP is licensed for a maximum flow of 3.0 million gallons per day (MGD). If one assumes a maximum allowable phosphorus concentration of one milligram per liter (mg/ltr) times our permitted flow (3.0 MGD), the result is about 24 pounds. This means that we cannot expand future flow above 3.0 MGD without a comparable reduction in phosphorus concentration to something less than one. We're told that, currently, the best technology can reasonably achieve (regardless of cost) is about one mg/ltr. The cost to achieve this level is estimated to be about $235,000 annually. This includes about $25,000 to amortize the $1.2 million capital construction costs; plus $210,000 annual operating and maintenance costs.
The city's WWTP license is scheduled for review and renewal late this year (2002). Based on the newly released TMDL, we anticipate that the revised license will reflect a new soluble phosphorus limit of one mg/ltr. TNRCC has not yet released their schedule to receive comments on the TMDL. They have also not released an implementation plan or timetable. Both actions are likely to occur this spring and summer.
The city's concerns about this matter have been conveyed to state regulatory agencies repeatedly over the past three years. As a result of the EPA/TNRCC decision to approve the TMDL, those concerns have now been communicated to the highest levels of state government.
Respectfully,
Mayor John Moser