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Latest News On NBU Fight

Improved Phosphorus Standard Included In New Draft Permits (6/2010)

Thanks to efforts over the years to persuade New Braunfels Utility, NBU, to improve the treatment of their effluent, and a change in their position, TCEQ has established more stringent standards for the Sewage Treatment Plants. With the current renewal of NBU wasterwater permits, TCEQ has included in the draft permits of both the North and South Kuehler plants a phosphorus discharge limit of 3.0 ml/l. This is a giant step forward. We are hopeful that they will be able to attain an even better treatment level, but this is a large reduction from current levels. In the future, even greater reductions will be required as new facilities are built or plants expanded. The permit process is not complete and it is unclear when we can expect the new treatment processes to be completed. We will update that information as it becomes available.

We are also happy to report that a much better relationship has been established with NBU in the last few years working together to protect our water supply and spring flows. This has resulted in a partnership approach with NBU on almost every aspect of water quality and quantity.

FOLM thanks all those that worked over the years to bring this issue to the forefront to improve the water quality of the Guadalupe River and chain of lakes.

NBU Wastewater Permit Finally Approved, NBU Put On Notice

Partial Victory To Limit Nutrient Pollution from NBU (6/2006)
The protracted fight of over 4 years by citizens and the various lake organizations protesting the waste water permit of New Braunfels Utilities (NBU) is over for now. On June 14th, 2006, the commissioners of the Texas Commission on Environmental Quality (TCEQ) considered NBU’s wastewater permit application and the many written requests for a contested case hearing.

While the permit was approved by the commissioners, the good new is that NBU was put on notice that they will be required to treat to limit phosphorus in the next permit when it comes up again in 3 years. We were quite pleased that the Commissioners immediately questioned why another study was needed when they are already requiring limitations in many other permits. The Commissioners made it clear that their attitude was that the nutrient study being conducted as part of their permit requirements would be used to help determine the level of treatment, not whether treatment is even necessary.

The study being conducted by NBU’s contractor on Lake Dunlap has begun this month. We should easily get the results we expect if the weather continues to be dry. This study will cover 2 summers with weekly sampling and monthly during the winter. We will continue to ask the TCEQ staff for updates as the study progresses as it is our understanding that periodic reports are to be made to TCEQ.

Key Points About NBU Sewage Treatment
-High phosphorus concentrations from NBU wastewater plants are directly affecting the amount of algae in the water and adds "fertilizer" for noxious weeds, such as hydrilla. We are asking for tertiary treatment with phosphorus removal to be the standard of treatment.

-NBU affects the quality and expense of treating drinking water. Thousands of families receive their drinking water from Lake Dunlap and the Guadalupe below New Braunfels. NBU takes its water from above its wastewater plants. They altered the Gruene treatment plant to water a golf course to keep that sewage out of the river and their water.

- Excessive algae creates a public nuisance and can be harmful to humans and unhealthy for wildlife and fisheries. The water can be especially unhealthy during periods of low river flow during hot summer months when used the most by swimmers and boaters.

-New Braunfels is growing at a record rate, adding to the amount of effluent that will be discharged into the river over the next several years.

-San Marcos and Kerrville have upgraded their facilities. Why not New Braunfels?

Guest Column from 4/17/02 NB Herald-Zeitung
    I implore the citizens of New Braunfels to petition your city council to upgrade the water quality standard of the effluent of your sewage plants without waiting for the TNRCC to wade through the permit process.  Preserving The River Is The Right Thing To Do.  Dumping chemicals into the Guadalupe River uses the river as an extension of your sewer system. The concept of using American Rivers to dispose of sewage and industrial waste has been soundly rejected by the American people in the past few decades. At the same time, New Braunfels is bucking this trend by polluting the Guadalupe River and lakes below the city.
    At the April 9, 2002,  TNRCC hearing on the NBU water quality permit, the strongest testimony I have ever heard was presented that leaves no doubt that NBU is the culprit messing up the lakes.  While the NBU and TNRCC representatives squirmed in their seats and claimed they just were not sure that the NBU facility was at fault, over a dozen studies performed from 1981 to present were cited that pointed to NBU as the polluting culprit. All agree that your sewage effluent meets a minimum TNRCC effluent standard but consider that the same standard also applies to the Houston Ship Channel.  In an attempt to put this problem in perspective, I asked the NBU representatives if they would have any objection if 4 million gallons of sewage effluent meeting the NBU water quality standard were dumped into Landa Lake each day. The question was diverted to the TNRCC as though it were a technical question. The real intent of course was to ask a citizen of New Braunfels if they would treat your pristine Comal River in the same manner you are treating the Guadalupe and its lakes downstream of your city.  I firmly believe that once the citizens of New Braunfels have all the facts they will want to do the right thing by their neighbors.
Preserving The River Is In Best Interest Of New Braunfels¹ Economic Future. At the TNRCC hearing an NBU representative stated that the rated capacity of the sewage plants was good for another 4 years at the projected population growth. When a plant is overloaded, it simply acts as a big filter. The water coming out is clear, but deadly I can assure you that the only way to prevent NBU from adding pathogens to the Guadalupe River, along with the phosphorus you are now dumping, will be to stop adding connections to the sewage plants when they are at full capacity. That means zero growth, which personally I find appealing but I doubt your business community feels the same.
    It takes time to design, build and finance such a project and you should start now. The reason I mention this is that I gave testimony in a hearing on a sewage plant permit in June of 2001 and the TNRCC has not responded. That was a second hearing, six months after the first hearing. At the April 9 hearing on the NBU permit, the moderator indicated there would be a second hearing.  If a contested case hearing (a court trial on the issue) is granted the plaintiffs, it becomes a long, drawn-out process. Any application for a new plant or plant expansion would meet the same opposition from downstream residents, and friends of the Guadalupe River like myself, if they designed to have a proper water quality standard. It may easily take four years to resolve this issue. Win or lose on the permit, your city could lose economically.
    If NBU were to agree to reduce the phosphorus in the effluent as the cities of Kerrville and San Marcos have done, then the permit problems go away. This is not blackmail, it is just the way the permit process works, and I am pointing out the possible problems it can cause your city in this case.  Those of us who believe in clean rivers are going to continue to protest. Another point to consider is that New Braunfels is about to become a city downstream of considerable sewage effluent flow. There are several sewage plants around Canyon Lake dumping effluent into the lake now using the same water quality standard as NBU.
GBRA is in the sewage plant business and wants to expand it big time. At a GBRA/Canyon Reservoir Water Quality and Regionalization Study Stakeholder Committee Meeting, one suggestion to avoid polluting the lake with effluent was to dump it downstream of the lake.
    In summer of 2000 the flow out of Canyon Lake was 50 cfs. At that flow rate, between 5 percent and 10 percent of the water could eventually be sewage effluent if that proposal were implemented. Also in summer of 2000, thanks to an additional 150 cfs from Comal Springs, only 3 percent of flow into Lake Dunlap was NBU sewage effluent and that lake is a disaster area.  I encourage New Braunfels to join Kerrville and San Marcos in preserving the pristine rivers God has given the hill country for the sake of your neighbors downstream. Short of that, do it to make it easy for us to propose a similar clean water standard for the TNRCC to apply to GBRA sewage plants and all the small substandard plants planned for developments along the upper Guadalupe, like Rebecca Lake and River Crossing.
    If you feel that a heavy concentration of phosphorus in the river flowing through New Braunfels is ok, then forget it. However, if you can imagine the Guadalupe between Canyon Lake and New Braunfels loaded with algae and smelling like Lake Dunlap in summer, and if you can imagine what that will do to water recreation, then I suggest that you join the cities of Kerrville and San Marcos in preserving our rivers.
    Preserving The River Is Economically Feasible for New Braunfels. There was testimony at the April 9, TNRCC hearing that NBU had released to the press cost estimates on retrofitting the existing NBU sewage plants for phosphorus reduction that stated that construction would cost between $5 million and $10 million and operations would cost $1 million a year. (These numbers are from memory.) There was very credible counter testimony that such construction would be less than $3 million and the total cost would result in about a $1 increase in the monthly bill for each connection.  Further, NBU admitted that their estimates were very preliminary and that they had not considered the operating and construction experience of Kerrville and San Marcos. While Kerrville constructed a new plant, San Marcos retrofitted an existing plant. Operational costs would be similar in both cases.
   Demand of the city council that NBU produce a sound economic study of plant construction and operation before allowing any more public rhetoric on the cost of reducing phosphorus in the effluent your city is dumping into the Guadalupe River.
(Steve Grigory, PE, SGA Consulting, Spring Branch)

See Preserve Lake Dunlap Web Site Also
More Information:

It has been well documented in Central Texas over the years that phosphorus is the nutrient that causes algae to flourish. It has also been well documented over the years that New Braunfels wastewater treatment plant is the main source of phosphorus entering into Lake Dunlap. NBU discharges approximately 5 mgd (million gallons per day) of treated sewage or waste water into Lake Dunlap from their North and South Kueler plants combined. Phosphorus is a nutrient that exists in sewage and treated wastewater. Treated waste water, called effluent, wouldn’t be a problem IF NBU WWTP treated for phosphorus, also referred to as tertiary treatment.

It has been documented over and over again through studies done on Lake Dunlap since the 70’s that Lake Dunlap has high levels of phosphorus and that New Braunfels WWTP is one of the main contributors. A review of some of the literature and previous studies done on Lake Dunlap states over and over again that phosphorus is the “limiting nutrient” that “feeds” the macrophytes (rooted plants) and microphytes (algae and other phytoplankton) and that NBU WWTP is the point source contributor of phosphorus. So why hasn’t NBU done something to eliminate phosphorus from their treated sewage water? NBU has taken no action because it would not be “cost effective” to treat for phosphorus. A study done in 1998 claimed there would still be enough phosphorus in the sediment to cause the macrophyte (hydrilla) problem even if NBU treated for phosphorus. Well, the hydrilla problem is currently under control thanks to grass carp! And it goes to reason that the Phosphorus in the sediment would eventually be used up over time if NBU would stop supplying fresh phosphorus every day. The 1998 study and all-previous studies clearly substantiate the fact that if NBU WWTP implemented tertiary treatment (phosphorus removal) it would “SIGNIFICANTLY” reduce the algae levels in Lake Dunlap as well as in the downstream lakes. Especially when flows are low to moderate. Go to (or click link below) and read the 1998 study “Analysis of Aquatic Plant and Nutrient Conditions in Lake Dunlap.” It will shock you at how many years it has been established that Lake Dunlap’s high levels of phosphorus is the cause of our algae problem and could be significantly reduced if NBU treated for phosphorus.

And yet GBRA and others continue studying Lake Dunlap. The most recent study, commissioned by GBRA, was conducted over the years 2000 and 2001. This study measures phosphorus and chlorophyll levels (a measure of algae) at various sites along Lake Dunlap. It shows the chlorophyll levels (algae) during a dry year and during a year with average rainfall. It shows the phosphorus levels above NBU WWTP and below the WWTP. This study clearly shows that the WWTP is the primary source of phosphorus. So with all this data, why hasn’t GBRA or NBU done anything about the water quality of Lake Dunlap? NBU will not commit to phosphorus treatment because of the cost involved. Preserve Lake Dunlap hopes that this year, 2002, the city of New Braunfels will be willing to implement tertiary treatment at their WWTP. It may be expensive at first, but can we afford not to? The cities of San Marcos, Kerrville, and Comfort all use tertiary treatment. Their citizens felt like it was worth the cost to preserve and clean up their precious water source. TNRCC knows how important it is to reduce phosphorus in all Central Texas rivers and lakes.

New Braunfels has been growing rapidly and NBU is already discussing enlarging the New Braunfels facility. One of the main reasons for opposition against annexation is the estimated cost of extending sewer lines to each homeowner. It is believed that council will grandfather septic systems and at least 95% of the septic systems do not meet current TNRCC rules and will be outlawed at a future date (source: Herald-Zeitung, July 19, 2001, “Annexation”) Hence, all areas to be annexed will ultimately be tied into NBU and end up in Lake Dunlap!

To add to the insults against Lake Dunlap, remember when the NB council did not want treated sewage water from the NorthCliff subdivision to be released into the Dry Comal? (Refer to Herald-Zeitung articles throughout May and June 2001 “Not In My Dry Comal”). The City of Schertz and the City of New Braunfels agreed to send it to the New Braunfels facility instead. Folks, the New Braunfels facility is the Kuehler plants, which discharge into Lake Dunlap! We are going to be getting an additional 300,000 gal/day of treated sewage water from the NorthCliff subdivision! When the NB city council stated at these negotiation meetings to “send it to Lake Dunlap, I don’t care” what are we to think? I am starting to understand the old expression “The character of a man/city can be measured by the quality of the water down stream from him/her and their constituents.” Lake Dunlap has been “dumped on” over the years with little regard for the consequences.

This kind of an attitude is a direct insult to all the hundreds of thousands of people that get their drinking water from Lake Dunlap. Did you know that the Canyon Water Regional Authority’s (CWRA) pumping station is at Lake Dunlap’s Dam where the water is the greenest? CWRA supplies water to Spring Hill, Green Valley, and Crystal Clear. These water companies then supply water to 11 entities. Lake Dunlap is an important source of drinking water for the rural areas of nearby towns, including San Marcos, Seguin, Marion, New Braunfels, etc.. If you live inside city limits, then you get your drinking water from NBU, whose own pumping station is above the NBU WWTP. Isn’t it ironic that in NBU’s 2001 Water Quality Report, NBU states “It is important to protect your drinking water by protecting your water source.” Yet NBU continues to neglect the water source of the rest of us?

PLDA will no longer accept excuses from NBU as to why they will not implement tertiary treatment (phosphorus removal). Lake McQueeny and Lake Placid have joined Lake Dunalp in efforts to clean up the algae problem in Lake Dunlap. PLDA sent a letter to TNRCC regarding the permit to send the NorthCliff sewage water to NBU. PLDA stated that we do not approve of using up capacity in the NBU WWTP and encourages the city of Schertz to look for other alternatives. We also stated that we intend to protest any future WWTP permit renewals or requests until NBU implements tertiary treatment. We requested that the city of New Braunfels and TNRCC have the same concern about the water quality of Lake Dunlap and the lower lakes on the Guadalupe as they have with the Comal River.

WHAT CAN YOU DO? Because the public uses Lake Dunlap and the lake is a source of drinking water for so many, there is immediate public concern. Call or write to New Braunfels city council members and NBU’s board of directors. Let them know you are dissatisfied with the water quality of Lake Dunlap and you want NBU to implement tertiary treatment (with phosphorus removal). Be specific when describing water quality. Specifically refer to the algae and other phytoplankton that turns the water green. Let them know that it is phosphorus that feeds the algae and that NBU WWTP contributes the bulk of phosphorus in Lake Dunlap. Refer them to the GBRA website which has summaries of studies done on Lake Dunlap if they need more convincing that Lake Dunlap’s phosphorus problem has been well documented over the years. The Taste of the water is affected, and costs to treat it are greater. Clean water is deserved by the public for fishery health, recreational use and aesthetic reasons as well. We need lots of public letters and phone calls! NOW IS THE TIME because NBU is in the process of discussing the expansion of their WWTP and they still will not commit to phosphorus treatment. The South Kuehler WWTP permit expires this February. We are protesting the renewal of their permit.

NEW STUDIES: Recent new water studies continue to point to NBU's waste water as the primary cause of water quality problems in Lake Dunlap and downstream. These studies will add ammunition to the fight for cleaner water.

Write Them:
City Council Members
NBU Board Members
Read About The San Marcos Experience
(opens a PDF file, click on "How To Sweep Away Algae with Clean Water Act")



Friends of Lake McQueeney •  P.O. Box 781, McQueeney, Texas, 78123