Serving Kerr County with a Conscience

​An Unsafe Septic System

The septic system under construction for Old River Road RV Resort bypasses safeguards for public health and safety. An onsite septic facility (OSSF) is being installed with tanks and drain-fields designated for servicing 25 people or less. OSSF’s are the usual residential systems.

The RV park’s septic system lies over the Guadalupe River’s recharge zone. Installing a septic system on the RV park site is not contraindicated. However, the Texas Commission on Environmental Quality (TCEQ) has specific rules and precautions for RV septic systems, they are more expensive than an OSSF. The Environmental Protection Agency refers to such systems as large capacity septic systems (LCSS). The TCEQ standards are based on the 5000-gallon rule—any project producing 5000 gallons of sewage per day requires a large capacity septic system application and oversight by the TCEQ. The RV developers evade this rule and TCEQ oversight by dividing the 240 unit development into three sections, each needing less disposal capacity than 5000 gallons.

RV parks present specific problems for septic systems. In addition to the higher volume produced by the convergence of people within a small area, the waste is more concentrated because less water is used in RVs. Toilet contents are made more caustic by strong chemicals and deodorants used to control tank odors. These conditions accelerate corrosion and septic system failures. The LCSS rules are designed to extend the life of a septic system from the usual 15 years to 30 years. Still, RV septic systems often fail prematurely.

The septic permit issued to the RV park compromises the health of the Guadalupe. The riverbank, adjoining terrain and fields serve as a sponge, absorbing water during wet weather. Referred to as riparian, its water continually migrates through the soil toward the river. Seeps and springs from riparian zones replenish the river during drought and are essential to its continuous flow and health.

The RV park’s septic tanks and drain-fields are embedded in this riparian sponge. We can expect the heavier than normal bacterial count and untreated caustic chemicals percolating from the septic system to mix with the naturally migrating water and seep into the adjacent Guadalupe. The predictability of early tank corrosion and system failure presents the risk of surface pollution draining directly into the river. The health and safety of RV park occupants is in immediate danger with such surface contamination.

Survival of the adjacent public recreation area, Brinks Crossing, is questionable. This Guadalupe swimming hole named the third best in the state in a 2008 edition of Texas Monthly and again hyped in 2012, receives the runoff, seeps and migrating water directly from the RV park’s septic system. Additionally, the river will carry any fecal and chemical contaminants the short distance downstream to Lions Park Dam, a busy swimming destination for children. Is it possible river contamination at this site could sacrifice the Guadalupe as a statewide recreational attraction?

There are no public safeguards such as inspections for breakdowns, measuring river contamination or ensuring repairs when failures occur. Kerr County’s Environmental Health Department who issued the OSSF permit is not staffed for such monitoring. The department depends upon the public and owners to self-report failures. Can we expect this owner who is avoiding the safety of an LCSS system and TCEQ oversight to self-report?

Many Texas counties have specific rules for construction of RV park septic systems. Kerr County has no guidelines, nor do we have a licensed sanitarian available to counsel our county employees tasked with issuing the RV park’s OSSF permit. Of course, the accepted path of following the 5000 gallon rule would assure TCEQ oversight of planning, construction and maintenance through an LCSS permit.

Our county officials spent untold time and energy plus $3 million on the Kerrville South Wastewater Project designed to replace failing residential septic systems polluting a Guadalupe tributary. A similar plan, the Center Point Wastewater Project, will cost an estimated $44 million to replace deteriorating OSSF’s threatening the river. Now county officials ignore the RV park’s immediate source of contamination—drain fields leeching into the riparian’s recharge. The septic tanks and connecting systems are at high risk for failure long before their 15-year lifespan is reached.

Elected officials are aware of the project’s health and safety issues. They also know that TCEQ oversight of this septic system could prevent much of the damage. Does it seem reasonable for authorities to ignore or perhaps support the creation of another site, sure to require taxpayer funding for cleanup, while the Center Point project is still in the planning stage? Is it possible the RV park site will need cleanup before the Center Point project is completed?

Frances Lovett

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