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I I , , I 'I . II Ii " II !I I II . . Western States Water Council Water Quality Committee Sheridan, Wyoming October 5, 2006 John: Two last points. EP A crunched the n]lmbers to look at the quality of the Powder River to the stat,e line as to whether it's changed over the, years. Once you adjust it for flow, they've seen no statistii~al change in the water quality. Another point is with respect to permitting. For example, we may issue a permit to someone with 2000 EC and an SAR of 1 0, which would be safe for quality water. However, we are running into the fact that they are not discharging 2000. They may only discharge a 1,000, while we based the SAR on 2,000 - - which means the SAR is 5 rather than 10. The fact that the discharger is discharging EC water of better quality than their permit specified puts them in trouble with SAR. We've talked about a permitting approach, such as floating SAR limit based on what the EC is, but the enforcement and tracking would be a challenge. Comment: I had to miss EP A's presentation in Denver when this analysis you just referred to was presented, but I've talked to two of our folks who were there. We feel the jury is out in terms of whether water quality has really changed for a couple a reasons. First, it's very difficult data to work with and, secondly, we had a period of drought followed by wetter years, etc. My understanding is that the statistical test was found at 5% of 95, which basically sets a high standard. I think there were conversations on how EPA might further explore that data set. We're not saying there is a change, we just think there are some other things that need to be sorted out. A side-bar issue that we've been dealing with relative to this irrigation and non-irrigation standard with TDS - we've gone back and forth on this many times. In Montana, or in Wyoming, there's a pretty well-defined irrigation season. Burifl ask Arizona what their non-irrigation suits are - there isn't one. In the north, we know when irrigation season is and isn't. If you go down to St. George, Utah, which is onthe Arizona border, you've got water use around the clock - - and so any other issues in a non-irrigation season is what if you store this water in a reservoir? If you store water in a non-irrigation season, then when you irrigate, it's of poor quality, a high saline water. Formerly we had a non-irrigation/irrigation standard on TDS, called stock water. In other words, you could use it for stock water, but not put it on crops. It's difficult to try to understand impairment when you've got two standards for the same body of water. Some agricultural individuals say they don't can: as long as the water is wet - bad water is better than no water. That whole issue of competing interests on agriculture irrigation/non-irrigation is like a tennis match. STATES ROUNDTABLE TO DISCUSS CURRENT WATER QUALITY PRIORITIES Kansas: Tom Stiles: The issues we discussed in Breckenridge, for example, ethanol plants and handling the impacts from them on water quality - - salt disposal, etc., are still alive. In recent days, the most pressing thing we've had has been interaction with our region of EP A and trying to help them work through the performance measures that have come down from headquarters, or from OMB. In particular, their perception of how to manage and evaluate performance under the measure, which is to layout a series of what many of you call the Huck 12 scale watersheds - - to basically demonstrate water quality in certain watersheds up to an average of about 5 per state over the next 5 7