THE BUCK SHOULD HAVE STOPPED WITH THE PEOPLE, BUT...

The saying "the buck stops here" derives from the slang expression "pass the buck" which means passing the responsibility on to someone else. Prominence of this saying belongs to President Harry Truman, who on more than one occasion referred to the desk sign in public statements. For example, in an address at the National War College on December 19, 1952 Mr. Truman said, "You know, it's easy for the Monday morning quarterback to say what the coach should have done, after the game is over. But when the decision is up before you -- and on my desk I have a motto which says The Buck Stops Here' -- the decision has to be made."
17 OCTOBER 06

MS. JOAN CARD
DIRECTOR WATER QUALITY DIVISION
AZ DEPT ENVIRONMENTAL QUALITY
1110 WEST WASHINGTON
PHOENIX, ARIZONA 85007

Re: Bella Terra Project
APP Permit # P-105588
Place ID 23400, LTF35294
Draft Permit 9/2/06

Greetings Ms. Card:

It appears your division has the responsibility to render the decision on the pending Bella Terra APP application. In all honesty, I, along with many others, empathize with you on the enormity of the implications of the decision you are required to render on this project. Your decision impacts not only the financial position of the owners and developers of this proposed project, but current and future residents in the Sedona area. And moreover, your decision has far reaching implications on the health of Arizona citizens not only in the immediate area but those down stream who will be impacted by any form of environmental pollution which might emanate from this project, whether that pollution happens today, tomorrow, next year or in the next 20 years.

Bella Terra is the subject of much discussion by folks in the Sedona area who will be impacted as a result of this project. Since the last public hearing in Sedona and a further review by ADEQ staff, this project has added to its treatment train a sand filter. Are we to understand ADEQ considers the addition of a sand filter sufficient to render the effluent from this SANTEC WRF to be “potable” water quality..? I note specifically “potable” as at the most recent Sedona public hearing ADEQ presentation noted the designation of Oak Creek a “unique” water calls for all water entering to be of equal or greater quality. The question posed at that hearing by Paul Trotta, P.E., Ph.D. @ NAU remains in the space and unanswered by ADEQ. Is ADEQ going on record that A+ sewage effluent is equal to and meets current “potable” water standards…?

Ms. Card, over the years I have had experience with “package” wastewater treatment plants, like the SANTEC unit proposed for Bella Terra. It has been my understanding a portion of the rationale utilized by ADEQ for permitting “package” plants it that at some point someone has documented the chemistry, the math, the biology, using for example a residential device, ORENCO unit, model XXXX which when consistently fed at the rate of (SPECIFIED) gpd of (SPECIFIED)BOD influent strength will produce an effluent quality in the range of (SPECIFIED). All extended aeration package wastewater treatment plants share an Achilles heel. Successful treatment of any form of domestic sewage is a function of time, air, temperature, elevation, volume coupled with gallons per day at a specific BOD influent strength. Most all package treatment plants were “tested” usually by an agency such as NSF under specific conditions, consistently fed with specified volume of sewage from a municipal sewer line, under controlled conditions and the effluent quality to meet a specific standard, not anywhere equal to A+ effluent. Their Achilles heel is their inflexibility, their limitation to produce only under conditions approaching those for which they were tested.

I have not at the moment seen any documentation for the Bella Terra project, but I doubt any chemistry, math or biology has been submitted to document the SANTEC model designed for this project. Moreover, like any package extended aeration unit, it is highly vulnerable to fluctuations in gpd and BOD loading rates, which given the nature of this project should be expected by all parties, owner, regulators, general public, as it is highly doubtful from the outset the plant will receive 25,000 gpd of sewage at the specified BOD loading rate. Therefore, like any extended aeration system this SANTEC plant can not consistently produce the specified effluent quality noted in the draft permit.

Moreover, Ms. Card, under the best of conditions from experience, that to attempt to cobble together one process on top of another for a proprietary device like SANTEC is not always viable as often the cobbled together pieces are often not compatible rendering a less than satisfactory effluent quality.

I rise in concern over the use of unspecified coagulating agents in the SANTEC process. Use of coagulating agents usually result in a more difficulty form of sludge which if not properly compensated for can easily blind off most sand filters. A formal design layout of all the devices and their placement in the SANTEC treatment train is hereby formally requested for presentation at the next public hearing. I am also for the record requesting SANTEC produce documentation on the chemistry and biology the current process they propose. In this manner they can lay to rest once and for all any misconceptions which I or others have respecting the ability of this system they propose to consistently handle the fluctuation in the daily flow rates both in gallons and in BOD strength.

Respecting financial capability … I ask for the record for a breakdown on how ADEQ arrived at the determination that $31,458.00 for closure cost and $35,000.00 for plant O&M were sufficient amounts to protect the citizens of Arizona.

There is no question the owners and developers of Bella Terra feel, or certainly have every right to feel, they are being held to a standard different than that to which other older though reputedly similar projects in their locale were held to. As I noted in prior correspondence to the agency, if these other projects were allowed to slip under the radar that is not valid reason for ADEQ to permit continuation of pollution to the waters of Arizona whether above or below ground. That residents in the area did not previously rise up in protest over these “older” projects is moot to the issue at hand.

ADEQ current rule stipulates there shall be no pollution to Oak Creek. Let it begin here and now, with this project or ADEQ by choice to permit this project to proceed as currently proposed, you abdicate your responsibility and should no longer be trusted to act in an honorable manner to protect the environment of Arizona. Indeed, Ms. Card, the buck does stop with ADEQ, and we acknowledge the legacy of this pending decision.