For the Greater Public Interest - 2001

It was early September 2001, just prior to 9/11, two armed security guards escorted me out of my work area the day after my submission of the following, word for word statement to my employer’s purported "unbiased" Public Interest Council.  The incarnation of my antipathy towards public and governmental corruption was born here.

Statement to the Office of Public Interest Council

RE: Public Meeting Notice for Lake Travis II Investments - Permit No. 14257-001, Canyon at Lake Travis Wastewater Treatment Facilities

The Texas Water Code prescribes the duties of the Texas Natural Resource Conservation Commission (commission) relating to the control of pollution including the review and approval of plans and specifications for sewage disposal systems. This authority is found in Texas Water Code, §§5.013, 12.081-12.083, 15.104, 15.114, 26.023, 26.034, 49.181-49.182, 54.024, and 51.333.

In the course of it's duties, the commission recently conducted full plan and specification review on aerobic treatment systems using recirculating media filters, dosing tanks, and subsurface drip irrigation with shallow installation of drip tubing. The facility reviewed, Permit No.14227-001 (WWPR 0701/055) is similar in design and location to the facility proposed for the Canyon at Lake Travis Wastewater Treatment Facilities, Permit No. 14257-001 and was designed by the same consulting firm, Loomis-Austin.

The commission finds:

1.) The likelihood for effluent surfacing from some emitters at "shallow installations of 6 inches" is high

2.) Effluent surfacing from the installed drip tubing does not receive the additional treatment from the soil as designed

3.) Soil moisture sensors may not be helpful in preventing surfacing because the entire soil does not need to be saturated for surfacing to occur

When public access is expected in areas where effluent exposure is high, the commission historically rules citing Texas Administrative Code §309.3(g)(4):

"Except as provided herein, disinfection of domestic wastewater which is discharged by means of land disposal or evaporation pond shall be reviewed on a case-by-case basis to determine the need for disinfection. All effluent discharge to land which the public has access must be disinfected and if the effluent is to be transferred to a holding pond or tank, the effluent shall be rechlorinated to a trace chlorine residual at the point of irrigation application." [Emphasis added]

We understand that the Office of Public Interest Counsel's participation ensures that all relevant evidence on environmental, public, or consumer-related issues is developed and made part of the record for the commission's consideration of permit issuance. As a result, the commission is able to make better-informed decisions and issue permits that are protective of human health and the environment and take into account the greater public interest, as well as the interests of affected parties.

For comments or questions, please contact Gary E. Geraci, E.I.T. at (512) 239-5703.

Sincerely,

Gary E. Geraci, E.I.T.

Wastewater Plan and Specification Review Team (MC 148)

Water Permits & Resource Management Division