Dear Editor,
I request that you consider publishing a letter to the editor regarding "Shifting Tides" by Lori Lovely, in the July/August issue of Onsite Water Treatment (onsitewater.com/ow_0707_shifting.html). NSF Standard 245 is a standardized product testing and certification program, not a regulatory standard. I am not well enough informed about Standard 245 to answer technical questions or to offer an opinion about Standard 245’s impact on the onsite wastewater treatment industry.
At no time did I intend to offer any opinion about NSF Standard 245, aside from stating that to my knowledge, no regulatory jurisdictions had yet adopted it and that the impacts of the new standard on manufacturers remains to be seen. My subsequent comments were strictly limited to the subject of supposed nitrate health risks, regulatory limits for nitrogen, and how those affect onsite wastewater treatment.
Consequently, I was disturbed to see that the article grossly distorted my message. The article gives the false impression that my criticisms were directed against the NSF's Standard 245 test protocol for nitrogen reduction. In fact, my criticisms were directed against the misapplication of the federal 10-milligrams-per-liter nitrate-nitrogen drinking-water standard by certain regulatory agencies, which (in my opinion) wrongly use it as an effluent standard for wastewater—a practice that they often claim is necessary "to meet the drinking-water standard and to protect public health."
Simply stated, my position is that the federal drinking-water standard is a water supply standard, not an end-of-pipe effluent standard for wastewater treatment systems. It requires suppliers of public drinking water to treat drinking water to 10 milligrams per liter of nitrate-nitrogen or lower. By law, it does not apply to private domestic wells or to onsite treatment system discharges. Moreover, there is no convincing, reproducible evidence that drinking-water nitrate increases health risks. And in my opinion, it is reasonable to ask that regulators consider the increased cost, operation and maintenance demands, and regulatory oversight necessary to meet a 10 milligrams per liter nitrogen effluent standard for treatment systems. In short, I feel that regulators should conduct a proper cost-benefit analysis for wastewater treatment system effluent standards, just as the EPA is required by law to do when adopting drinking-water-supply standards.
Evidently my comments about the federal drinking-water standard were misconstrued as a commentary on the NSF Standard 245 testing standard. Furthermore, the article appears to put me at odds with Ron Suchecki [who is a Standard 245 committee member]. Although controversy can certainly be entertaining, I can assure you that there is no controversy between Suchecki and myself. I have never taken a position "against" Standard 245 as the article infers.
I'm sure you can understand why I was deeply troubled to read the following statement in the article:
"He [Mr. Suchecki] believes zoning restrictions could police that [i.e., could help prevent overdevelopment with septic systems from contributing to water-quality impacts], but that’s the kind of political move Churchill claims Standard 245 targets."
I most assuredly did not imply to mean at any time that NSF Standard 245 is a "political move" designed to promote adoption of zoning restrictions or that it "targets" anything. What I say is that regulators sometimes use exaggerated nitrate health claims and misapply the federal drinking-water standard as a pretext to limit growth or achieve other planning objectives. My comment had absolutely no bearing on Standard 245, whatsoever.
Contrary to the impression left by the article, I recognize that restrictive regulatory standards for wastewater treatment system effluent nitrogen may sometimes be appropriate for ecological reasons (to protect the surface-water ecology against eutrophication). I do not object to appropriate and cost-effective controls to prevent environmental degradation. My objection is to the imposition of highly restrictive effluent standards based on unsubstantiated health claims, where no consideration has been given to cost-effectiveness. Requiring treatment to the 10 milligrams per liter level substantially increases the capital cost, increases design complexity, creates a greater demand for monitoring and maintenance, and demands a higher degree of regulatory oversight to ensure long-term performance.
Forward-looking treatment system manufacturers, recognizing the need for cost-effective nitrogen reduction, are making every effort to optimize nitrogen-reduction efficiency. My view was stated in a recent article printed in the National Onsite Wastewater Recycling Association's Onsite Journal ("Nitrogen Management—We Can Do That!" in the Winter 2007 issue). I wrote:
"Whether the concern is environmental health or public health, and regardless of the validity of public health concerns, it is important that the decentralized wastewater treatment industry be prepared to meet stringent discharge standards where required."
I continue to question, however, whether highly restrictive nitrogen standards are always the most effective use of limited public and private resources.
Sincerely,
Jason Churchill, Ph.D.
Government Relations Representative
Orenco Systems Inc.
Dear Editor,
I was just reading the May/June 2007 issue of Onsite Water Treatment. The article “A One-Two Punch” quotes Jim Keeton, chief executive officer of Keeton Industries with some amazing and outrageous statements. “It’s worth noting the average sewage treatment plant outfall has 250 to 500 milligrams per liter of BOD [biological oxygen demand].” The inflow/influent may have this strength, but if the outfall/effluent does, someone’s going to be fined very heavily for violating his NPDES permit. Keeton is further quoted when talking about aeration: “It’s coming in at 4 or 5 milligrams per liter and going back at 20 or 30, so it’s very high.” How is this possible when the dissolved oxygen saturation is only 14.6 milligrams per liter at 0°C and 9.2 milligrams per liter at 20°C. Even at supersaturation the agitation of aeration would drive off any excess oxygen. I’ve worked in water a long time and never seen water in the environment read 30 milligrams per liter!
I find it amazing that anyone writing about water/wastewater would miss these two glaring errors. It makes me question Keeton’s qualifications or the accuracy of the articles in Onsite Water Treatment. Please have someone check the facts before going to press.
Sincerely,
Mike Perniel
Environmental Division
Minneapolis Park and Recreation Board
Dear Editor,
I am writing to you in response to Elizabeth Dietzmann's most recent column titled “Maintenance/Management of Onsite Systems—To Alarm or Not to Alarm That Is the Question,” Part Two (www.onsitewater.com/ow_0707_legal.html). I always find her column a must-read, but I take exception to part of this edition's piece. In the column Dietzmann infers that the NSF Onsite Monitoring Program is not a comprehensive database management tool since she places it in the remote monitoring device category. The NSF Web site and its secure database are in fact very comprehensive. Not only do they provide all regulatory agencies with the means to load every onsite treatment system (including conventional systems), but they enable agencies, service providers, and property owners to track and manage operation and maintenance of all systems. The NSF Web site and database are stand-alone facilities apart from the NSF communication devices so treatment systems may be managed even when the communication device is not installed. The NSF communication device is meant to provide additional benefits on top of the numerous management facilities of the Web site and its database: independent verification of service/maintenance and automatic alarm notification. Dietzmann's column also infers that the NSF program does not help put the M in O&M by tracking actual work: "Managing onsite systems through the use of a comprehensive database focuses on monitoring via service providers’ reports." This feature has always been a key facility of the NSF program, even allowing service providers to file inspection reports and effluent water-quality sampling/analysis data electronically with their regulatory agency.
I would like to express my appreciation of the fine work done by your publication in getting critical issues and information out to the industry. Your journalists and contributors such as Dietzmann are a great asset to the onsite wastewater community.
Sincerely,
Paul R. Jackson
Program Manager
Water and Wastewater Treatment Units
NSF International
Onsite Water Treatment welcomes letters to the editor. Letters should be the original work of the author, and should include the author’s full name, title (if applicable), profession, and general location (city and state). Onsite Water Treatment reserves the right to edit all letters for length, accuracy, grammar, and clarity. Onsite Water Treatment reserves the right to reject any letter for publication.
OW - September/October 2007 |
