Emails (excerpted), responses to PolitiFact Texas, Daryl Slusher, assistant director, Austin Water Utility, Jan. 8-14, 2013
1209 pm Jan. 8, 2013
The statement is based on the Texas Surface Water Quality Standards (promulgated by TCEQ and approved by EPA). It classifies Lady Bird Lake and Lake Austin as “High” quality segments of the Colorado River and classifies the section downstream of Lady Bird Lake (where Austin discharges most of its treated wastewater) as “Exceptional.” This is one of the very rare instances where the overall water quality in a river segment downstream of a major urban area is classified as better than that of the upstream segment.
Assistant Director of Environmental Affairs and Conservation
Austin Water Utility
2:01 pm Jan. 8, 2013
...as we discussed, Lake Travis is rated Exceptional while Lake Austin and Lady Bird Lake are rate High Quality. Then the segment of the Colorado River below Lady Bird Lake goes back to Exceptional. It stays that way until around La Grange and then goes back to High Quality.
We believe that a major reason for the improvement in quality in the segment where Austin’s discharge goes in is our high level of treatment, in particular Austin’s dissolved oxygen treatment levels.
From: Selby, Gardner (CMG-Austin)
Sent: Wednesday, January 09, 2013 5:56 PM
To: Slusher, Daryl
This make sense?
From: Andrea Morrow
Sent: Wednesday, January 09, 2013 5:06 PM
To: Selby, Gardner (CMG-Austin)
Subject: RE: Reporter inquiry
Ok, Gardner. Here’s the summary. This answer is compiled from staffers in TCEQ’s Wastewater Permitting and Surface Water Quality sections.
Ok, there are six water quality parameters or constituents that are directly comparable (Austin treated wastewater effluent vs. lake water near surface water intakes). I’ve attached a spreadsheet that summarizes data from Austin’s seven wastewater treatment plants and shows corresponding data from a composite of surface water quality data from areas around the City’s surface water intakes on Lake Austin (2) and Ladybird Lake (1). The effluent data is recent and is collected in a controlled environment, the lake data is a composite over a ten-year period based on “snapshot” sampling. There is a lot more variability in nature.
Here’s how they compare:
total suspended solids (TSS)
This can be thought of as a measure of water clarity. On average, the effluent had lower TSS (better clarity).
Form of nitrogen that can be toxic to aquatic life in high enough concentrations but more typically serves as a nutrient for plant and algae growth. Effluent had higher concentrations than the lake water.
total phosphorus (TP)
Another nutrient needed for plant and algae growth. Too much can potentially over-stimulate growth. Only two of the Austin treatment plants monitor phosphorus, and the effluent had higher concentrations.
Measure of how acidic or alkaline the water is (scale of 0 to 14). Generally want to be in midrange without extremes. Both effluent and lake water were in reasonable ranges.
Breathed by fish and other aquatic organisms. Effluent and lake values are acceptable. Low levels can naturally occur at/near the bottom of lakes (zeroes in the lake data minimums), but raw drinking water is not drawn from that depth generally.
Type of bacteria used as an indicator of water quality. Found in the intestinal tract of warm-blooded organisms, it’s presence can indicate fecal contamination and the potential for waterborne disease. The effluent generally had lower E. coli numbers.
These are only a fraction of water quality parameters that could potentially be compared between the two water types, but the reality is that available data allows only a handful to be evaluated. With the parameters above, the effluent tends to be clearer and lower in bacteria levels, while the lake water is generally lower in nutrient concentrations. Dissolved oxygen and pH were comparable between the two types. So with respect to the statement that the effluent quality is higher than the source water, for some things it’s true, for others it’s not.
TCEQ Media Relations
12:17 pm Jan. 10, 2013
We don’t disagree with any of the TCEQ analysis of individual constituents. I believe their analysis brings us back to the larger point that Austin Water regularly makes and that the Mayor was also making, which is that, overall, the stretch of the river where Austin discharges its treated wastewater is rated, under EPA/TCEQ standards, as having better water quality than the water upstream -- that being Lady Bird Lake. I cannot speak for TCEQ, but I think if you ask them they will tell you that the constituents that you asked them to compare individually go into the overall rating.
Under those standards Lake Travis is rated “Exceptional” for “Aquatic Life” while Lake Austin and Lady Bird Lake are rated “High”, the next step down from exceptional. Then, in the stretch just below Lady Bird Lake, which includes Austin’s treated wastewater discharges, the rating goes back to Exceptional. This holds until near La Grange where the rating goes back to High and stays that way down to the Gulf.
So, the segment where Austin releases its treated sewage and the segment immediately downstream are the only segments between Lake Travis and the Gulf that are rated exceptional. (Lake Travis is rated exceptional.)
You can find this in the documents and links I sent a couple of days ago, the ones with which you said you had difficulty understanding. I certainly understand that because the numbered segments of the river do not necessarily correspond to upstream and downstream, plus the descriptions of the segments are in a different section of the document, and there is no accompanying map. I did find a corresponding map and sent you a link to that, which is also included below again. You probably will want to go through this yourself, but given the above challenges, I will try to help by working through it here myself.
Section 1429 is “Lady Bird Lake/Town Lake.” It is rated “H” or “High” water quality in the chart on page 81 of the document titled “Chapter 307 - Texas Surface Water Quality Standards (the same as I sent the other day and attached here as well).”
The segment immediately below is 1428 and is titled “Colorado River Below Lady Bird Lake/Town Lake.” That is the segment where discharge from both of Austin’s major wastewater treatment plants (Walnut and South Austin Regional) enters the river. That segment is rated “E” or “Exceptional,” a grade up from H. The E rating holds from the next segment downstream, 1434, titled “Colorado River Above La Grange.”
The rest of the way to the Gulf is rated H. (The descriptions and boundaries of the segments are on pages 115-118 of the same report.)
Going back upstream, Lake Austin, 1403, is rated H while Lake Travis, 1404, is rated E. Overall, the point is that the segment of the river where Austin discharges its treated wastewater is rated, under EPA/TCEQ standards, to be of higher water quality than the water immediately upstream, that being Lady Bird Lake.
The high rating in the segment where Austin discharges its treated sewage is no accident. It results from investment and years of implementation by Austin Water and its employees, who were carrying out policies of City Councils and City Management dating back to the mid to late 1980s. As you likely recall, and the Statesman reported extensively at the time, during the early and mid-1980s the same segment of the river, and consequently going on downstream, was heavily polluted by discharge from Austin -- discharge that was nowhere near the quality it is now, to say the least. This was largely the result of Austin’s wastewater system not keeping up with growth.
I suggest that you talk to Raj Bhattarai, Division Manager of the Environmental and Regulatory Services at Austin Water. He is a leading national figure in the wastewater field and was with the utility throughout the time Austin cleaned up its discharge. I would have put you in touch with him yesterday but he was at a conference. Raj can tell you about the history, answer questions about wastewater treatment, and discuss the TCEQ reporting if you wish. He is out sick today, but would be glad to talk to you on his cell phone, 512-699-5321.
Link to map:
From: Selby, Gardner (CMG-Austin) [mailto:email@example.com]
Sent: Thursday, January 10, 2013 12:22 PM
To: Slusher, Daryl
Subject: RE: ?
My summary of your note a moment ago is that the utility does not disagree with the commission staff analysis, though it thinks the big picture remains that the river downstream is of higher quality than the “high” quality of Lake Austin. ...
W. Gardner Selby
Jan. 10, 2013, 12:25 pm
That’s correct. I would reiterate my suggestion about asking the TCEQ about using the individual constituents to determine the overall rating.
From: Selby, Gardner (CMG-Austin)
Sent: Monday, January 14, 2013 10:13 AM
To: Bhattarai, Raj; Slusher, Daryl
Cc: Buchman, Kevin
Subject: Following up, engineer's thoughts and conference call suggestion
Please point me to whoever you please per responding to what follows—and to close out my inquiries from last week?
I am pasting below thoughts from engineer Lauren Ross, who says it’s evidence that Austin's wastewater effluent quality is not higher than Lake Austin water quality.
This is a link to LCRA water quality monitoring data: http://www.lcra.org/water/quality/state.html. Open the reports for August 2012 or June 2012. Go to page 6 of either of these reports. The top part of the page is measurements, the bottom a summary status. Looking first at Status for June, you can see that where Lake Austin is "low" for nitrogen, the Colorado below Austin is "high/crit". That is true for both June and August.
Going to the top table on the same page, nitrogen in Lake Austin is 0.008 milligrams per liter. Colorado River below Austin is 8.8 milligrams per liter. That is an increase by a factor of more than a thousand. The concentrations differences between Lake Austin and the Colorado River downstream from Austin's wastewater effluent discharges are similar for August 2012. The relationships between phosphorus concentrations in Lake Austin compared to below the City's discharge are also similar.
So there could be other sources for that nitrogen and phosphorus increase other than the City's wastewater effluent. But these were both dry months, so no storm runoff. Storm runoff nutrient concentrations are not as high as those Colorado River measurements.
This is the link to the City of Austin wastewater effluent self-reporting data: http://www.austintexas.gov/department/wastewater-reports-discharge-monitoring-reports-dmr. If you can decipher the report for June 2012, not an easy task, you will see that there are very few measurements. There is no information on either nitrogen or phosphorus. So the City isn't measuring the constituents required to compare wastewater effluent to Lake Austin to even know whether the water they are discharging is a clean as what they are pulling out of the lake.
The reported measurements for ammonia nitrogen are <0.2 mg/l, 1.8 mg/l (May 2012), <0.1, and 0.1 mg/l (June 2012). All of these measurements in the effluent are significantly higher than the measurements for total nitrogen (of which ammonia would be only a part), indicating that Austin's wastewater effluent is polluted with nitrogen compared to the water they are pulling out of the Lake.
Attached is the City's wastewater permit from TCEQ. Page 2 of the file gives the allowed discharge concentrations. Under this permit the City is allowed to discharge ammonia nitrogen at a concentration of 5 (7 day average), 10 (daily maximum) or 15 (single grab sample) milligrams per liter. There is nothing in the terms of their permit with TCEQ indicating that Austin's wastewater effluent is better than the quality of Lake Austin water.
Finally, there is lots of evidence that the City fails to meet criteria 4 on page 2 of the permit: "There shall be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil. Attached are photographs of foam discharge from the South Austin Regional Plant. These foam discharges have often occurred.
Jan. 14, 2013, 3:07 pm
To reiterate, the point that Austin Water has made and that I believe the Mayor was also making is that under EPA/TCEQ standards related to aquatic life, the segment of the river where Austin releases its treated effluent is rated higher quality than immediately upstream. Austin Water’s effluent discharge is better in some parameters and worse on others, depending on the individual parameters. For example on total suspended solids (TSS) and E. coli (an indicator of danger for human contact and ingestion) the TCEQ staff said that the effluent is higher quality than Lady Bird Lake. As you and TCEQ have noted, however, on certain other parameters the water in Lady Bird Lake rates better than Austin Water’s effluent discharge.
Jan. 14, 2013
I am including in the table below the metals results for the 4th quarter of 2012 for Ullrich intake, Walnut effluent and SAR effluent.
The water lab stopped running ammonia and nitrates for the lakes in the latter part of 2008. All analysis of Town Lake; except for some sporadic bacterial testing, ceased when Green was taken offline in 2010. I am including nitrate and ammonia data for the Ullrich intake from the 4th quarters of 2007 and 2010 for comparison purposes with the 4th quarter of 2012 wastewater plant effluent ammonia and nitrate.
SAR effluent ammonia (NH3-N) average for the 4th quarter of 2012 - 0.14 mg/L
Walnut effluent ammonia (NH3-N) average for the 4th quarter of 2012 - 0.35 mg/L
Ullrich intake ammonia (NH3-N) average for the 4th quarter of 2010 - 0.0375 mg/L
SAR effluent nitrate (NO3-N) average for the 4th quarter of 2012 – 30.2 mg/L
Walnut effluent nitrate (NO3-N) average for the 4th quarter of 2012 – 26.7 mg/L
Ullrich intake nitrate (NO3-N) average for the 4th quarter of 2007 - 0.031 mg/L
Metals Averages for the 4th Quarter of 2012
R-3 (Lake Austin at Ullrich intake)
Please let me know if I may be of any further assistance.
Dana L. White M (ASCP), CQA (ASQ)
Wastewater Regulatory Manager
Environmental and Regulatory Services Division
Austin Water Utility, City of Austin