Don't Worry, Be Happy

At the meeting of the South City Park Neighborhood Association on July 16, 2008, Doug Woods of Denver Parks and Rec said he would get back to us regarding my question on Regulation 84. As far as I know, he didn’t. I have emailed him since the meeting but never got an answer. Oh well, I guess I’ll just add him to my growing list of City Officials Who Do Not Answer (COWDNA).

But in preparing the video clip above, I listened closely to what he had said, which was something like “There are one set of regulations for water coming directly from the pipe and another regulation for water being dumped to a body of water.”

Ok, something to work with here. I had learned of Regulation 84 - Reclaimed Water Control Regulation, directly from the Denver Water web site . Of course, by its number alone Reg 84 implies that their must be other Regs and I found this, a list of many Regs. Sure enough, if you click on Regulation 31 - The Basic Standards and Methodologies for Surface Water, (for the pdf file) it seems to be the one Doug is talking about.

Oh my. Reg 31 contains a list of substances allowed in our lakes and streams. If you have the time, go to page 31 (p27 in the document itself), where you will find a list of 152 Parameters (note they are not called Pollutants as they are in the Permit). I won’t bother to reprint the list here, except for the radionuclides.

Radionuclide Standards

Parameter --- Picocuries per Liter

Americium 241* --- 0.15

Cesium 134 --- 80

Plutonium 239, and 240* --- 0.15

Radium 226 and 228* --- 5

Strontium 90* --- 8

Thorium 230 and 232* --- 60

Tritium --- 20,000

Some of the Lowry Landfill Superfund Site (LLSS) Permit levels exceed these standards. But that is not a problem, as Reg 31 states: (31.11 (1)) "All surface waters of the state are subject to the following basic standards; however, discharge of substances regulated by permits which are within those permit limitations shall not be a basis for enforcement proceedings under these basic standards". And best of all this statement (31.11 (2)): "The radioactive materials in surface waters shall be maintained at the lowest practical level."

I think I’m starting to get it – the recycled water is not used “directly from the pipe” as Doug puts it, but is “dumped to a body of water” (Ferril Lake) first, and then a different set of regulations (Reg 31) is in effect. Then the lake water is pumped to the fields for irrigation, thereby avoiding the Reg 84 rules (posting when the water is in use, or avoiding aerosol spray, for example).

How naive was I when I first learned of Permit No. 2360-3-1A, to assume that this might be illegal? I was shocked and outraged only because I was uninformed. How stupid of me.

I should have known that the CDPHE and its advisory committees, stocked with former employees, lawyers and lobbyists of the polluters as it is, would have prearranged to make all of this legal and in full compliance with the Regs. That apparently is why this one sign (at City Park) is sufficient to explain it all.

So I guess I should apologize to those of you who got upset when you learned of the Permit. Don't be alarmed. Everything is OK. The hand fits perfectly into the glove. This is, as I’ve been told repeatedly, the “current state of the art” in water recycling.

Learn to live with it now, and we will learn what the long term effects of spreading these carcinogens around are in another 20 years or so, when our babies and children, whom we innocently let play on the pollutant-laden grass at City Park, grow up. I sincerely hope that they are healthy.

Or stay out of these parks, don’t come into contact with the water of any Colorado stream or lake (and don’t let your pets do it either), and maybe you can avoid the consequences of these policies.

Too bad, since many of us moved here to enjoy the "unspoiled" beauty of our state, cities, and parks. Little did we know.