Preliminary Technical Evaluation of Three Reports by U.S. Environmental Protection Agency Region 10 on Nitrate in Water Wells, Yakima River Basin, Yakima County, Washington

The Yakima Valley is a large agricultural area where there are multiple potential sources of nitrate in groundwater.  Potential sources are intermingled, i.e., homes with septic systems are on the same properties as the dairies or adjacent to farms and/or dairies.  In 2012, Region 10 of the US Environmental Protection Agency undertook a study to source track and identify nitrogen sources in the Yakima River Basin as part of an enforcement effort focusing on dairies. EPA position was that the targeted dairies did not properly apply nutrients to land application fields at agronomic rates, resulting in groundwater contamination.  The study area is underlain by 3 aquifers, a shallow perched aquifer likely related to irrigation return flows, an alluvial aquifer and an underlying basalt aquifer.  The three aquifers are hydrologically connected either through natural pathways or through wells completed into more than one aquifer.  Because none of the potential sources are isolated, source tracking requires an in-depth knowledge of aquifer properties such as aquifer thickness, groundwater flow direction, hydraulic conductivity, and vertical leakance in addition to understanding localized effects of ditches, drains and production wells on groundwater flow.  EPA focused on groundwater chemistry, assuming that indicators such as pesticides and other trace organic compounds would tie the groundwater nitrate to a specific source.  EPA’s study failed to yield clear indicators pointing to specific sources and did not collect hydrologic data for its 2012 report to gain a detailed understanding of aquifer properties.  This presentation will address how to accurately characterize the hydrogeology below dairy production areas and land application fields, and how to proactively manage nutrients to protect dairies from unsubstantiated enforcement actions

Purpose

Glorieta Geoscience, Inc. (GGI) was contracted by the Washington State Diary federation and Dairy Producers of New Mexico to conduct a technical evaluation of three reports prepared by U.S. Environmental Protection Agency Region 10 (EPA) to identify sources of nitrate in the Yakima Valley.

What did we do?

arial photoWe conducted a scientific peer review of EPA’s project design, methodologies, compliance with EPA’s own Quality Assurance Project Plan/Quality Control procedures, evaluated the overall study design/site selection as described in the three (3) reports, addressed specific data collection concerns and analyzed the results and conclusions drawn from the data as described in the main body of the Report to determine if EPA’s methodology and conclusions were supported by data.  We analyzed the overall study design, hydrogeological characterizations, well completions, sample collection (green water, soils and ground water), geochemistry, stable isotopic and organic compound analyses and EPA’s conclusions from these efforts.

What have we learned?

EPA did not achieve their objectives because the aquifer properties such as groundwater flow direction were not evaluated, not all potential sources at each study site were evaluated and mapped and trace organic compound analyses did not yield reliable data or were inconclusive. As a consequence, EPA did not produce a study with reproducible results that supports its conclusions that specific sources of nitrate in domestic wells the Yakima Valley can be identified.

We learned that EPA does not follow their own QAPP and Quality Assurance protocols and that there was significant lack of supporting technical information for EPA to arrive at the conclusions presented in the report. 

Author  

Jay Lazarus, Glorieta Geosciences lazarus@glorietageo.com

The authors are solely responsible for the content of these proceedings. The technical information does not necessarily reflect the official position of the sponsoring agencies or institutions represented by planning committee members, and inclusion and distribution herein does not constitute an endorsement of views expressed by the same. Printed materials included herein are not refereed publications. Citations should appear as follows. EXAMPLE: Authors. 2015. Title of presentation. Waste to Worth: Spreading Science and Solutions. Seattle, WA. March 31-April 3, 2015. URL of this page. Accessed on: today’s date.

Environmental Protection Agency (EPA) Perspective on Nutrient Pollution

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Why Discuss Regulations and Nutrient Pollution?

Provide EPA’s perspective on nutrient pollution and encourage an open dialogue to help address this problem which is rapidly becoming one of the most challenging environmental problems that we face.

What Did We Do?

Although nutrients, nitrogen and phosphorus in particular, are essential for aquatic life, too many nutrients can create significant problems for our nation’s lakes, streams, and coastal waters.  Nutrient pollution can degrade habitat for fish and wildlife, render water bodies unsafe for swimming and other forms of contact recreation, create a public health concern for drinking water supplies, decrease property values, and negatively impact local economies.  According to national statistics, more than 45% of streams have medium to high levels of nutrients, approximately four million lake acres have been identified as threatened or impaired, and approximately 78% of assessed coastal areas exhibit signs of eutrophication.

Nutrients can be transported great distances and impact areas far downstream.  One of the more prominent examples in the United States is the Gulf of Mexico “dead zone,” which can be larger than the state of Connecticut in some years.  The term “dead zone” refers to waters that have been so heavily impacted by nutrient pollution that oxygen levels are depleted to the point where most aquatic life cannot survive.  Nutrients are transported to the Gulf of Mexico via tributaries of the Mississippi River from as far away as Montana in the west and Pennsylvania in the eastern portion of this large watershed.

Nutrient pollution is not restricted to the Mississippi River Basin or any one region of the country.  Nutrient pollution is widespread, impacting waters across the nation.  As we learn more about the impacts of nutrient pollution, especially the potential for some species of algae to produce toxins that can be harmful to both people and animals, states are becoming more aggressive in reducing sources and even posting health advisories when necessary.

So, what has EPA been doing to address nutrient pollution?

  1. Providing states with technical assistance and other resources to help develop water quality criteria for nitrogen and phosphorus;
  2. Working with states to identify waters impaired by nutrients and developing restoration plans;
  3. Awarding grants to states to address pollution from nonpoint sources, such as agriculture and storm water runoff;
  4. Administering a permit program designed to reduce the amount of nitrogen and phosphorus discharged to the environment from point sources;
  5. Providing funding for the construction and upgrade of municipal wastewater treatment plants;
  6. Working with states to reduce nitrogen oxide emissions from air sources;
  7. Conducting and supporting extensive research on the causes, impacts, and best approaches to  reduce nutrient pollution; and
  8. Increasing collaboration with other federal partners (e.g., USDA) to leverage financial and technical resources.

And although progress has been made over the past decade, much more is needed.  Realizing a need for greater action, In March 2011, EPA issued a memorandum titled “Working in Partnership with States to Address Phosphorus and Nitrogen Pollution through Use of a Framework for State Nutrient Reductions.”  This memo emphasized that nutrient pollution continues to have the potential to become one of the costliest and most challenging environmental problems that we face and reaffirmed the agencies commitment to partner with states and stakeholders to make greater progress in reducing nutrient loading to our nation’s waters.  If you have not already done so, please join us in protecting and restoring our nation’s waters.  For more information visit EPA’s nutrient pollution website at http://www.epa.gov/nutrientpollution/.

Author

Alfred Basile, Biologist, US Environmental Protection Agency Region 8, basile.alfred@epa.gov

Additional Information

www.epa.gov/nutrientpollution

The authors are solely responsible for the content of these proceedings. The technical information does not necessarily reflect the official position of the sponsoring agencies or institutions represented by planning committee members, and inclusion and distribution herein does not constitute an endorsement of views expressed by the same. Printed materials included herein are not refereed publications. Citations should appear as follows. EXAMPLE: Authors. 2013. Title of presentation. Waste to Worth: Spreading Science and Solutions. Denver, CO. April 1-5, 2013. URL of this page. Accessed on: today’s date.