Max Dodson, EPA Region VIII, Director Water Management Division issued Rocky Flats its 1984 National Pollutant Discharge Elimination System permit that allowed Spray Irrigation. There were to be no discharges with the exception of weather conditions.The EPA did not consider the enormous volume of sewage treatment plant effluent compared to available surface area or what comprised the sewage treatment plant effluent. The EPA also did not consider Spray Irrigation operations, volume, and potential impact at Rocky Flats and off-site. More about the NPDES permit at https://rockyflatsambushedgrandjury.com/3165-2/.
The February 6, 1991 report of interview with Mike Bartleson, Kathy Schnoor and Dan Mayo, all of Broomfield, Colorado provides background why the EPA conducted an NPDES permit review at Rocky Flats in the mid-1980s. The Broomfield drinking water supply, Great Western Reservoir, was fed by Walnut Creek and adversely influenced by Rocky Flats discharges. https://rockyflatsambushedgrandjury.com/3171-2/.
The December 11, 1987 report of George H. Setlock, Rockwell, documents Spray Irrigation issues concerning “zero discharge” goal and the enormous 70 – 80,000,000 gallons per year of sewage treatment plant effluent that was spray irrigated. https://rockyflatsambushedgrandjury.com/wp-content/uploads/19871211-George-Setlock-Spray-Irrigation-Rocky-Flats-Plant.pdf.
The 1987 Waste Stream Identification and Characterization (WSIC) report conducted at Rocky Flats was required for Rocky Flats to obtain a Resource Conservation and Recovery Act (RCRA) Part B permit and to operate as usual. The WSIC report detailed radioactive and hazardous waste production facility effluent to the sewage treatment plant. The WSIC Overview document, a portion of the 39 volume set, is available at https://rockyflatsambushedgrandjury.com/overview-rocky-flats-waste-streams-1987/.
It was not possible for Rocky Flats production effluent to be stored in Pond B-3 on South Walnut Creek for more than about four (4) days. Due to the limited capacity of Pond B-3 and that Rocky Flats production effluent was between 70-80,000,000 million gallons per year, Rocky Flats spray irrigated as often as possilbe. Rockwell International spray irrigated plant effluent despite impacting radioactive burial sites (903 Lip Area, East Trenches, contaminated groundwater areas) at Rocky Flats. See photo above, a Rockwell photo submission to EPA demarcating (with grids) evidencing they knew where to not spray irrigate. Spray irrigation also was conducted during storm events, freezing temperatures, that caused sheet-runoff at Rocky Flats and to downstreamers. An example of Rocky Flats spray irrigating during freezing temperatures is at https://rockyflatsambushedgrandjury.com/3196-2/ and https://rockyflatsambushedgrandjury.com/rocky-flats-lone-sprayer-plant-effluent-circa-1987/.
In 1992 Rockwell International pled guilty to mismanaging the Rocky Flats sewage treatment plant and spray irrigation abuses to include spray irrigating in the areas of the 903 lip area, East Trenches and contaminated groundwater. The federal filing describing the Plea Agreement is available at https://rockyflatsambushedgrandjury.com/rockwell-international-charged-federal-environmental-crimes-rocky-flats/.
In the late 1990s Great Western Reservoir was no longer utilized as a drinking water supply for Broomfield, Colorado due to Rocky Flats contamination. U.S. Department of Energy contributed about $100,000,000 to Broomfield’s quest to secure other drinking water sources. Broomfield water resources presentation of August 2011 at http://www.broomfield.org/DocumentCenter/View/7968.