INFORMAL POSITION STATEMENT Louisiana Department of Environmental Quality Water Permits Division I have taken a look at the proposed design, talked with RV Louisiana, and conducted some research into gray water as associated with RV’s. LDEQ would support any effort made in this state to utilize gray water for the irrigation of flowerbeds, gardens, surface irrigation (overland flow) or other recycling and conservation activity. The showcasing of such a gray water system at any Louisiana state park would provide an opportunity not only for those utilizing the RV spaces, but for all park visitors to witness a step forward in water conservation and recycling, something that is sometimes foreign to us in water plentiful Louisiana. But as usual (with regulators) there are conditions and concerns that we would expect to be considered and addressed. Under LAC 33:IX.2311.A.1, the Louisiana Pollutant Discharge Elimination System (LPDES) requires permits for the discharge of pollutants from any point source into waters of the state. The key terms here that would allow the utilization of the proposed gray water recycling system would be point source and waters of the state. If the gray water recycling system is designed such that there is no point source discharge to waters of the state, i.e. large enough to handle the expected inflow, then LDEQ would not require permitting under the LPDES program. However if the flowerbed/garden/irrigation area was designed such that an overflow of gray water would drain into a ditch or other waters of the state via any discernable, confined or discrete conveyance, then an LPDES permit would be required. Either way the project as proposed could be constructed and a permitting decision would be made based on the design and potential (yes/no) to discharge. If a permit would not be required under the LPDES program, then regulatory authority would wholly rest with LDHH. We would expect the park to require those utilizing the gray water recycling spaces to abide by a few conditions as to what they put down their drains. The utilization of gray water for irrigation purposes should not contain any chemicals derived from activities such as cleaning car parts, washing greasy or oily rags, disposing of waste solutions, or soiled or infectious garments. Fairly common sense, but the fundamental principal here is to promote the growth of plant life (don’t put chemicals down the drain) and to eliminate the potential for human waste to cause a public health concern (don’t wash contaminated items down drain). We would also expect the park to minimize human contact with the areas receiving the gray water irrigation, i.e., don’t put a playground or walking path on the irrigated area. The other item that needs to be considered is under the LPDES program, the material contained in an RV black water tank (human waste) is defined as septage under LAC 33:IX.2313; the solid or liquid material pumped from a septic tank, cesspool, or similar domestic sewage system, or a holding tank when the system is cleaned or maintained, and regulated a bit differently. The difference being the BOD5 levels in septage is about 5x that what is expected in domestic sanitary wastewater due to dilution by gray water in a collection system. Under normal circumstances a full RV hookup or RV dump station would provide for both black water and gray water tanks to drain into the sanitary wastewater treatment system, creating the same influent as expected in domestic sanitary wastewater. Our concern is that small sanitary wastewater treatment facilities (as present at most state parks) are not designed to properly treat an excessive load of introduced septage, without the gray water also being introduced. We would have to work with LDHH to ensure the design of the treatment facility is adequate to handle an increased loading of BOD5 in order to maintain compliance with effluent limitations and conditions as required by the LPDES permit issued to the park’s sanitary wastewater treatment facility. We wouldn’t want to create one environmental problem while trying to promote another. If anyone has any questions or wants to further discuss, please feel free to give me a call at 225-219-3073. In Louisiana we don’t always think in concepts related to the recycling and conservation of water because we are not yet forced to do so; water is plentiful, cheap, and its use is unregulated. This project certainly moves to promote and develop that understanding. Aimee’ Killeen LDEQ – OES – Water Permits Division