Montana DEQ has a proposed wastewater discharge permit for the town of Gallatin Gateway out for public comment until September 16, 2015.
Click here to download the proposed permit and read the state’s rationale for allowing this new wastewater facility.
Since our initial review of the permit we’ve had the opportunity to talk with both the Dept. of Environmental Quality permitting office and the local sewer district concerning the proposed GWPDES permit. We’ve also examined a good deal of new science and technological support for the updated, proposed system design. Based on those conversations and the new 2014 studies concerning the proposed facilities’ capacity and treatment capabilities, we have submitted a comment letter to the Montana DEQ supporting the approval of a permit for the Gateway Sewer District.
Our letter also requested that the final permit include a requirement to monitor, down-gradient, of the facility to ensure that groundwater discharges are in fact being sufficiently diluted before reaching any community wells or the Gallatin River. We feel an additional representative monitoring of discharges downgradient, combined with a permit requirement to optimize operations if data shows excellencies of pollutant parameters, is the best way to help Gateway proactively address its longstanding infrastructure challenges while using sound science to ensure operations remain a benefit, and protective, of the local community and water resources.
Click here to read our comment letter to the Dept. of Env’tl Quality.
The proposed facility would be located on a recently purchased piece of property behind the Buffalo Station off Cottonwood Rd., SE of Gallatin Gateway.
In short, the DEQ is proposing to allow Gateway to build a sewage treatment plant. The proposed facility would discharge to local groundwater that, in theory, would dilute all pollution. Gateway currently doesn’t have a centralized wastewater disposal system and, instead, has dozens of small little septic systems individually discharging wastewater into local groundwater. Diffuse septic systems, like Gateway’s, can cumulatively pollute local groundwater because they don’t offer the same level of treatment as a centralized facility.
Building a new wastewater treatment plant for a community that doesn’t have any centralized treatment system is good, right? Well, it will be a good thing IF the discharge limits are based on sound science, IF local groundwater and local wells aren’t harmed, and IF the facility is built to appropriate technological standards. Otherwise, speaking strictly from the scientific perspective of the local Gallatin River’s nutrient loading capacity, a hundred diffuse septic systems may be better than a new facility that doesn’t offer good treatment. This isn’t to say existing, failing septics aren’t a problem – they are – but we should all make sure that a new facility will be a positive benefit for the local community and river.
Therefore the question is: will the proposed Gateway wastewater facility help, and not hurt, local water resources?
Our initial review shows that the proposed limits may allow too much wastewater pollution in our local groundwater. Specifically, we’re concerned that a final permit limit of 7 mg/L total nitrogen isn’t stringent enough to protect downgradient drinking water in Gateway. Groundwater in the area flows directly NW, meaning any wastewater discharges from the proposed facility will likely end up near, and potentially in, local drinking water wells, and can accumulate in soils over time becoming more potent. EPA’s maximum safety standard for total nitrogen in drinking water is 10 mg/L, at which point actual health impacts can occur. Our goal is, therefore on one hand, to see if best available science for the area, the proposed facility, and nitrogen limits indicate that a final permit limit for nitrogen should be 7 mg/L, or lower (more stringent).
On the other hand, we want to make sure appropriate funding is in place so that if built, a wastewater treatment facility has the necessary technology to functionally, and consistently, achieve strict discharge limits. The last thing we want to see is a situation where a sub-condition new facility could be built, that won’t do a good job of treating wastewater. In tight economic times and for small towns like Gateway, its in everyone’s best interest to make sure sound science – and good economic investments – are made to do the job right, the first time.
We’re watchdogging new proposed wastewater permits like Gateway’s proposed facility because the lower Gallatin watershed is already being harmed by excessive amounts of nutrients in our waterways. You know, too much nitrogen and phosphorus in our surface waters. Nutrients come from a bunch of places, a lot of it from local farm fields, a lot from natural sources, and another good bit from diffuse septic systems. Harmful nutrient pollution can also come from treatment facilities IF their discharges aren’t sufficiently minimized.
We watchdog pollution permits because, unfortunately, experience has shown that sometimes good science isn’t followed by our decision makers; we want any treatment facility for Gateway to succeed, thus we are diligently reviewing the permit and examining good wastewater science to ensure any final permit is properly protective of drinking water and local water resources.
Indeed, because the proposed Gateway facility is less than a half mile from the Gallatin River, we want to make sure any groundwater discharges of pollution are properly treated because local groundwater will, in short time, make its way into the Gallatin River. Its very important to the future health of our waterways and communities that any type of new wastewater discharges meet stringent pollution limits that protect local groundwater, connected surface waters, and local fisheries.
We’ll continue reviewing the proposed Gateway wastewater permit with the intention of submitting technical comments that can improve a final permit’s limits, all on the basis of sound science and the law. If you’re interested in learning more, email our Executive Director, Guy, at Guy@UpperMissouriWaterkeeper.org.