At the meeting of the South City Park Neighborhood Association on
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.
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
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
Or stay out of these parks, don’t come into contact with the water of any
Too bad, since many of us moved here to enjoy the "unspoiled" beauty of our state, cities, and parks. Little did we know.