DEQ Proposal to Relax Water Quality Standards


May 28, 2008

Jean Gregory
Dept. of Environmental Quality
P.O. Box 1105
Richmond, VA 23218

Subject: Proposal to Relax the Water Quality Standard for E. Coli

Dear Ms. Gregory:

The Friends of the North Fork of the Shenandoah River is a volunteer organization with 450 members dedicated to protecting and enhancing the River, its tributaries and its watershed. As a citizen conservation organization concerned with water quality throughout the Shenandoah River watershed and the State of Virginia, we are opposed to changing the state water quality standard for bacteria in freshwater.

Virginia has approximately 50,356 miles of rivers and streams. According to the 2006 Water Quality Assessment 305(b) and 303(d) Integrated Report, almost 9,000 miles of Virginia’s rivers and streams are impaired. The number of impaired miles in Virginia rivers and streams increased significantly from 2004-2006. A staggering 81% of all sub-watersheds statewide are impaired and E. coli bacteria is the single largest cause of impairments in the state.

The bacteria water quality standard is designed to protect human health and as such, must be conservative. Raising the standard from 126 colonies/100 ml. to 206 colonies/100 ml. sets the stage for a higher incidence of illness and environmental degradation and is neither prudent nor warranted. Part of the rationale provided for raising the bacteria standard is to make it easier to achieve TMDL goals for stream segments where natural (wildlife) sources of bacteria complicate removing the impairment. While this would probably be a faster and easier way to remove streams from the impaired waters list, it is contrary to the purpose of having water quality standards and achieving them. Such a decision is regressive in terms of protecting both human health and the health of the Commonwealth’s waters and aquatic organisms., which is a primary mission of the Department of Environmental Quality and the State Water Control Board. Instead of relaxing the protection of state-wide waters as provided by the current standard, the sources of E. coli on a case-by-case basis. Because TMDL Implementation Plans are developed for individual stream segments/impairments, DEQ should be able to use that process to address site-specific issues related to bacterial contamination from wildlife.

Raising the standard will mean that persons using the state waters for fishing and swimming will have an increased risk of infection and illness. How can such an action be contemplated by the DEQ and this administration? It will also affect wildlife adversely/ For example, bacterial infections have been identified as a contributing factor in the widespread fish kills we have had since 2004. As estimated 80% of smallmouth bass populations in the Shenandoah River system died in one such kill. Similar fish kills have affected the Potomac and James River systems. Allowing higher levels of bacteria in our waters could well exacerbate this problem and cause even more economic disruption due to the loss of the once thriving sport fishery supported in these rivers.

Additionally, enacting the proposed changes in the bacteria standard would allow higher bacteria limits in  discharge permits for wastewater treatment plants, which would only serve to further degrade waters of the Commonwealth.

Further, in the karst geology that we have throughout the northern Shenandoah Valley, there is a high level of interaction between surface water and groundwater. Surface water enters the subsurface aquifer through sinkhole, caves and other cavities, and can lead to contamination of drinking water. Because so many towns and individuals in the northern Shenandoah Valley depend on wells for their drinking water, increased levels of bacteria in rivers and streams are likely to result in increased incidences of contaminated drinking water sources.

The proposed change would lower the level of protection provided to human health and aquatic resources by increasing the allowable amount of fecal coliform bacteria permitted in our waterways. This certainly would not be a step forward in assuring clean water for the citizens and resources of the Commonwealth, but a step backward. We urge the State not to relax the current standard but to keep the water quality standard for bacteria in freshwater at the current level of 126 colonies/100ml. water.

Sincerely,

Ron Falyar, President
Friends of the North Fork of the Shenandoah River
PO Box 746
Woodstock, Virginia, 22664


cc:
Governor of Virginia, Timothy Kaine
Secretary of Natural Resources, Preston Bryant
DEQ Director, David Paylor



____________________
Orndorff Trout Farm Comments

Mr. Wallace,
 
The Friends of the North Fork is submitting the following comments and requests a public hearing where these issues can be discussed with members of the community before the permit is finalized and issued.
 
	•	Orndorff Rainbow Trout Farm is not in compliance with the requirements of the TMDL    The Orndorff Spring Branch is severely impaired and that impairment has been attributed to the trout farm’s discharge.  The permit and agency record indicate that the facility was given four years to be in compliance with the TMDL limits.  That period ended on March 5th, 2007.  It is our understanding that this compliance deadline was not met.  The TMDL study listed a number of treatment methods that could have been used to meet the TMDL TSS limits.  It is our understanding that none of those measures have been applied.  Instead, the permittee has proposed to reroute the discharge, with no further treatment, to Cedar Creek but that alternative was not an approved option as of March 5th, 2007.   
 
	•	DEQ has not provided assurances that the relocation of the facility’s discharge will restore the Orndorff Spring Branch or keep from impairing Cedar Creek.  The agency intends to approve the rerouting of the permittee’s wastewater into Cedar Creek but has not provided an adequate ecological evaluation of the impact this will have on either body of water and such an ecological assessment must be done before the permit can be approved.  For the Orndorff Spring Branch, there is the very real question of what the reduced flow in the Branch will do to its benthic recovery and to its final ecological status?  Will the Branch simply disappear?  This would be a very odd and unattractive form of remediation…through waterway elimination?  For Cedar Creek, the issues are just as serious.  The original TMDL study indicated that the creek was already slightly impaired.  What assurances are there that the solids that have been deposited in the branch will not simply be deposited in the creek with the same adverse result?  An ecological assessment of this significant modification of flows and waste patterns needs to be completed and shared with the public before a decision on the permit is made.  In addition, the permit must include benthic monitoring of both the branch and the creek to demonstrate that the selected measures have worked for the branch and that the problem has not simply been transferred to the creek. We are particularly concerned about the agency’s ability to permit fish farms without having dramatic impairments follow.  Throughout  the basin, benthic impairments have been associated with fish farms that have been permitted and stayed in compliance.  We ask that DEQ consider the adequacy of this and other fish farm permitting, with that fact in mind, and take all steps necessary to avoidrepeats of that outcome.
 
	•	The discharge limits and monitoring requirements are incomplete and inadequate.  The agency report and TMDL report states that organic solids are the critical element of the sources discharge but there are no limits on organic solids in the permit.  Instead TSS is limited with an assumption about its relationship to organic solids.  However, the facility is barely required to monitor solids.  The permit requires monitoring only once a quarter or less than half of a percent of the time that the facility is operating.  Given the risk of high solids in the day to day operation of this facility, this is totally inadequate monitoring.  Further the permit contains no other pollutant limits.  Lastly, agency assumes a maximum flow in its analysis of risk but the source is not required to monitor or limit the rate of discharge.  In the past, the permit contained limits on BOD, DO, SS and pH but those limits have been dropped.  This permit should include daily limits and daily monitoring for organic solids, TSS, and discharge flow.  In addition, it should include daily limits on BOD, DO and ammonia, with monthly sampling.  It is not good regulatory policy to decide that limits are not needed because they were not violated in the past.  It is not good regulatory policy to decide that monitoring is not needed except on the rarest of occasions because the agency assumes the source will run normally and in compliance otherwise.  It is not appropriate to fail to set limits for important pollutants simply because the DEQ lacks the needed data and therefore assumes there will be no problem.
 
	•	The O&M Plan requirements are inadequate and unenforceable.  The permit contains an obligation to create and implement an O&M plan.  This is a critical element of the permit given that the facility has no downstream pollution controls in place and the improper operation and maintenance of the equipment could result in dramatic increases in discharge loading and associated ecological damage.  However, the permit does not require that specific measures be adopted.  Instead it says that Best Management Practices must be covered in a “discussion.”    How will a discussion assure that BMPs are selected and implemented?  This section should be amended to require the selection and use of specific O&M BMPs keyed to a schedule.   The permit should also require documentation that they are being applied and reporting when they are not applied or they are found to be ineffective.
 
	•	 Certain limits in the permit have no associated monitoring and reporting   
	•	 The permit requires that sampling be done during harvesting, unit cleaning and solids removal.  There is no mechanism to enforce this provision.  The permit should be amended to require a listing of which activities were underway at the time of sampling with the associated times and it should require that the owner sign a certification of that information that would be submitted with the DMR.
	•	The permit places a prohibition on the discharge of fish offal, dead fish, floating solids and foam.  There is no mechanism to enforce these provisions.  The permit should be amended to require a daily inspection, a report on the inspection and a certification of conformance with this requirement.
	•	The permit states that organic solids shall not be discharged in amounts that cause bed accumulations but there is no mechanism to enforce this requirement.  The permittee should be required to do weekly inspection of the waterways below the discharge, note any accumulations of solids, certify the report, retain the report and contact the DEQ whenever settled solids are observed.
If you have any questions on these comments, please let me know.
 
Sincerely,
 
John G. Holmes
Friends of the North Fork of the Shenandoah River
PO Box 746
Woodstock VA 22664
 
Comments on the KOA Campground proposal at “A Way to Play” on Route 11 just South of Woodstock, VA
April 5, 2007
TO: PLANNING COMMISSION, SHENANDOAH COUNTY
SPECIAL USE PERMIT REQUEST - KOA
CAMPGROUND
        We are concerned about the effects the proposed campground will have on water quality in the North Fork.  Narrow Passage Creek, which runs through the site and which will receive the treated wastewater from the campground, is already listed by the State as an impaired stream because of high fecal coliform levels.  The section of the North Fork that the Creek runs into is also impaired.   If the campground owners receive a special use permit from the County, they will then apply for a discharge permit from the Department of Environmental Quality (DEQ) to install a package plant to treat 15-20,000 gallons of wastewater per day.   Based on DEQ estimates, each campsite and cabin would use about 50 gallons of water per day.  That alone adds up to 12,500 gallons.   In addition, the plant will need to treat water from a proposed swimming pool,  store, laundry facilities and  Recreational Vehicles.  Most KOA campgrounds provide pump stations for RVs  which will increase the amount of water that needs to be treated.  We believe the owners may need to build a treatment plant with more capacity than proposed.  Therefore, if the County approves a special use permit for this campground, it should include a condition that would prohibit any soil disturbance until DEQ agrees that the capacity applied for is adequate.  
	Another concern is erosion and run-off from the development of the campground.  The trees that will need to be cut for this extensive development, the hard surfaces from 250 campsites and cabins, RV parking and an extensive road system will result in considerable run-off  which is not addressed in the site plan.   Also, a  good portion of the run-off will be petroleum based.    Therefore, we ask the County not to approve the special use permit until they have a detailed site plan and an erosion and sediment control plan. Currently, the County is requesting these plans only before construction begins, and that is too late to fully analyze the effects of this development.       
	We ask the County  to look at the larger issue of approving private and commercial developments that require package treatment plants.  The County should know  how many of these are currently operating, learn about the problems associated with these plants and then develop a policy for future approvals of developments that require package treatment plants.   We review and comment on most renewals and requests for these package plants and would be happy to provide our comments to the County.   
Thank you,
Margaret Lorenz, Policy Chair, Friends of the North Fork of the Shenandoah River

Comments on Mount Jackson Sewage Treatment Plant VPDES Permit No. VA0026441
 
The Shenandoah River is at a critical juncture.  It has had several years of unexplained wide spread fish kills, it exceeds EPA water quality standards in many parts of the river and there is widespread evidence of intersex traits in the bass population that is being attributed to manmade pollutants in the watershed.  Unfortunately, it is no surprise the Shenandoah River was named this year as one of the five most endangered river systems in the United States.  These are exceptional and troubling times for this watershed and now is not the time to relax requirements applicable to sources discharging wastewater into this river system.  Rather, all discharges must be held to the highest standards of pollution control and monitoring.  In particular, under these circumstances, relaxed monitoring requirements should not be adopted based on general agency policies or past performance of the facility.  Knowing what is being discharged and knowing when the discharge is exceeding limits is too important to protecting the river.  With that in mind, the Friends of the North Folk of the Shenandoah River asks that the DEQ make the following changes to the draft permit:
	1.	Require Daily Monitoring of Suspended Solids and BOD in the Discharge  Part I.A.1 and 2 contain weekly and monthly limits on the suspended solids and BOD in the discharge of this facility.  However the draft permit requires only monthly testing for suspended solids levels in the discharge and three tests per week for BOD.  The minimum required monitoring for both of these important parameters should be daily.  Daily monitoring is the only reasonable way to ensure compliance with the weekly average limits that are in the permit and, importantly, it is the best way for the operator, the DEQ and the public to know that the treatment plant is operating properly.  Without daily testing, the facility could operate out of compliance for days in the case of BOD and weeks in the case of solids. 
	2.	Require Daily Demonstration of Conformance with the 85% Control Requirement  Part I.A.1.d and Part I.A.2.d state that the plant must control both BOD and Suspended Solids by at least 85%.  However, the permit has no monitoring or reporting provisions to ensure that this is happening.  Daily monitoring of inflow and discharge for these parameters should be required and the percentage control determined.  The results should be reported monthly to the DEQ and the DEQ should be notified whenever the 85% performance limit is not being met.  This requirement is important but, as presented in the draft, it is meaningless as there is no demonstration of compliance.
	3.	Require Daily Demonstration of Compliance with the Restrictions on Floating Solids and Foam in the Discharge  Part I.A.1.e and Part I.A.1.i state that the plant must have no floating solids or foam in its discharge.  However, the permit has no monitoring or reporting provisions to ensure this is happening.  At a minimum, daily inspection of the discharge for these parameters should be required and the results recorded and certified by the operator or manager making the observations.  The results should be reported monthly to the DEQ and the DEQ should be notified whenever solids or foam are present.  This requirement is critical  to knowing if the treatment plant is operating properly.  As presented in the draft, it is meaningless as there is no demonstration of compliance.
	4.	Require the Posting of All Monitoring Reports on a Website  The community needs ready access to information on the performance of this treatment plant.  With the ease of posting data on the Internet, this permit should require that the operator post all monitoring results on the Internet for access by the public at the same time the results are submitted to the DEQ.
	5.	Prohibit New Connections:  Because the Mt. Jackson treatment plant regularly exceeds its capacity during rainy weather and there is increased loading from new connections, the permit should prohibit new connections to the plant if it exceeds 95% of the capacity authorized in this permit for each month of any three consecutive month period.  This prohibtion should be lifted only after the expanded treatment plant is on line and in compliance with the new permit.    

These are deficiencies in the draft permit that must be addressed.  Please make these needed revisions.  Also, let us know if a public hearing or meeting will be held on this permit.
 

Comments on 
Edinburgh Sewage Treatment Plant permit
	Date: 	December 15, 2006


Subject: Town of  Edinburg Sewage Treatment Plant VPDES Permit No. VA0020508
 
The Shenandoah River is at a critical juncture.  It has had several years of unexplained widespread fish kills.  It exceeds EPA water quality standards in many parts of the river and there is widespread evidence of intersex traits in the bass population that is being attributed to manmade pollutants in the watershed.  Unfortunately, it is no surprise the Shenandoah River has been named this year as one of the five most endangered river systems in the United States.  These are exceptional and troubling times for this watershed and now is not the time to relax the requirements applicable to sources discharging wastewater into this river system.  Rather, all discharges must be held to the highest standards of pollution control and monitoring.  Because of these circumstances, relaxed monitoring requirements should not be adopted based on general agency policies or past performance of the facility.  Knowing what is being discharged and knowing when the discharge is exceeding limits is too important to protecting the river.  With that in mind, the Friends of the North Fork of the Shenandoah River asks that the DEQ make the following changes to the draft permit:
	1.	Require Daily Monitoring of Suspended Solids and BOD in the Discharge  Part I.A.1 contains weekly and monthly limits on the suspended solids and BOD in the discharge of this facility.  However the draft permit requires only monthly testing for suspended solids levels in the discharge and three tests per week for BOD.  The minimum required monitoring for both of these important parameters should be daily.  Daily monitoring is the only reasonable way to ensure compliance with the weekly average limits that are in the permit and, importantly, it is the best way for the Town, the DEQ and the public to know that the treatment plant is operating properly.  Without daily testing, the facility could operate out of compliance for days in the case of BOD and weeks in the case of solids. 
	2.	Require Daily Demonstration of Conformance with the 85% Control Requirement  Part I.A.1.d states that the plant must control both BOD and Suspended Solids by at least 85%.  However, the permit has no monitoring or reporting provisions to ensure that this is happening.  Daily monitoring of inflow and discharge for these parameters should be required and the percentage control determined.  The results should be reported monthly to the DEQ and the DEQ should be notified whenever the 85% performance limit is not being met.  This requirement is important but, as presented in the draft, it is meaningless as there is no demonstration of compliance.
	3.	Require Daily Demonstration of Compliance with the Restrictions on Floating Solids and Foam in the Discharge  Part I.A.1.e states that the plant must have no floating solids or foam in its discharge.  However, the permit has no monitoring or reporting provisions to ensure this is happening.  At a minimum, daily inspection of the discharge for these parameters should be required and the results recorded and certified by the operator or manager making the observations.  The results should be reported monthly to the DEQ and the DEQ should be notified whenever solids or foam are present.  This requirement is important to knowing if the treatment plant is operating properly but, as presented in the draft, it is meaningless as there is no demonstration of compliance.
	4.	Require the Posting of All Monitoring Reports on a Website  The community needs ready access to information on the performance of this treatment plant.  With the ease of posting data on the Internet, this permit should require that the Town post all its monitoring results on the Internet for access by the public at the same time the results are submitted to the DEQ
	5.	 Prohibit New Connections:  The permit should prohibit new connections to the plant if it exceeds 95% of the capacity authorized in this permit for each month of any three consecutive month period.  This prohibtion should be lifted only after the expanded treatment plant is on line and in compliance with the new permit.    
These are important deficiencies in the draft permit that must be addressed.  Please make these needed revisions.  Also, let us know if a public hearing will be held on this permit.


Chemstone Update
June 24, 2006
An update on the Chemstone mining issue near Middletown in Frederick County (receiving stream is Cedar Creek).  The earliest the Frederick County Board of Supervisors will consider the request from Chemstone to rezone ag land to extractive mining is July 26, so I will prepare a letter in the next couple of weeks to send.  I talked to the Deptuy County Admin. today and the County only prints notices of public hearings in the Winchester Star which I don't see on a regular basis.  I asked him to consider putting it on their web site and he thought a good idea!  Although the state dept. of mining has turned down Chemstone's request for a  permit and the County Planning Commission has recommended denial of the zoning permit, there is always a possibility that the project can go forward (e.g., Island Farm!).    Also, Chemstone is in the process of answering all the comments from the State and expects (according to the Free Press), a good response!  



FNFSR Comments to DEQ on Strasburg STP
June 27, 2006

Trevor H. Wallace
Environmental Engineer
Virginia Department of Environmental Quality
Valley Regional Office 
Harrisonburg, VA

Dear Mr. Wallace:  

Below are the comments of the Friends of the North Fork of the Shenandoah River regarding the draft Strasburg sewage treatment permit (VDES No.VA0020311).  As a group of more than 450 landowners in the Nork Fork watershed, we are extemely concerned about the quality of the river.  Major parts of the river exceed the standard for bacteria and the levels of nutrients coming into the river from manmade sources are damaging the local water quality and the Chesapeake Bay.  Also bass and sunfish are dying of lesions and bacteria infections.  With the river in such a fragile state, the Department of Environmental Quality (DEQ) must use its authority to insure that sources of water pollution are minimized and that permit holders are held to the highest standards of water quality protection.  Towns with permits must comply with those standards through proper operation, frequent discharge monitoring and complete reporting on performance of permitted waste water treatment systems. 

Public Hearing:  We are requesting DEQ to hold a public hearing on this permit in the town of Strasburg so that members of the community can present their concerns to the DEQ staff and a representative of the State Water Control Board.

Public Information:  Reports should be readily available to the public.  This includes compliance information such as monthly and annual reports, plans submitted and approved as well as reports of upsets, bypasses or exceedances.  The permit should contain a provision requiring the town of Strasburg to on a timely basis all reports and submittals to DEQ on a publicly accessible website or make them available via email to any one requesting information.

Prohibition on New Hookups:  Because the Strasburg treatment plant currently is experiencing increased loading from new connections and the permit is being issued with a throughput just below 1 MGD, the permit should include the following additional requirements:   A prohibition on all new connections to the plant if the .95 MGD figure is exceeded, with the prohibition lifted only after the expanded plant is on line and in compliance.  Also, as soon as the flow exceeds the .95MGD figure, a provision that automatically imposes the requirements that would apply to a facility operating at over1 MGD.  

Part I.A.1 describes the discharge limits and monitoring requirements that will apply before DEQ issues a Certificate to Operate the expanded plant.  The following changes should be made to this tabulation:
All of the weekly average limits in this portion of the permit should be imposed as daily average limits.  If the facility only has to meet a weekly limit, very high hourly and daily levels that damage the river may be allowed.


BOD and Suspended Solids monitoring should be done daily and the samples should be 24 hour composites rather than 8 hour composite samples. The monitoring of these two important parameters must be done with enough frequency and coverage so that any high levels are detected and corrected.  The schedule in the proposed permit will yield non-representative samples, which we believe conflicts with the regulations governing operations of STPs.   A very high level of BOD or Suspended Solids could easily go undetected if days pass with no samples taken or analyzed.
The lowest ammonia limit achievable should apply year round.  At a minimum the limit of 4.9 that is specified for June to December should apply in the January to May period.  Ammonia contributes to algae blooms and bacteria growth in the river and may contribute to fish health problems.  In that context, the lowest possible limit should be imposed year round.
TRC sampling and analysis should be conducted three times a day, every day of the year.  Chlorine levels are the only assurance of bacteria control and this river already suffers from high bacteria levels.
The 85% control requirements in footnote g should be made practically enforceable with testing and reporting requirements at least monthly.

Part I.A.2 describes the discharge limits and monitoring requirements that will apply after DEQ issues a Certificate to Operate the expanded plant.  The following changes should be made to this tabulation:
All of the weekly average limits in this portion of the permit should be daily average limits.  If the facility only has to meet a weekly limit, very high hourly and daily levels that damage the river may be allowed.
Monitoring for BOD, CBOD, Suspended Solids and Ammonia should occur daily.  This plant should not be allowed to operate without sampling on the weekends and that is the situation that is being created by the draft conditions.
Limits on BOD/CBOD should be the tightest limits possible and should be applied year round.  While the permit package does not explain why the limit for half the year is BOD and the remainder is CBOD, the limit should be the more stringent of the two.  It appears from the permit that a monthly BOD limit of 15 and a daily limit of 22 should apply year round.
The lowest ammonia limit achievable also should apply year round.  At a minimum the limits specified for Jun-Dec should also apply in the January to May period.  Ammonia contributes to algae blooms and bacteria grow and may contribute to fish health problems.  In that context the lowest possible limit should be imposed year round.
TRC sampling and analysis should be conducted three times a day, every day of the year.  Chlorine levels are the only assurance of bacteria control and this river already suffers from high bacteria levels.
The 85% control requirement in footnote g should be made practically enforceable with testing and reporting requirements at least monthly.


Part I.A.3 footnote b. contains an important requirement for sludge pathogen control.  That provision should appear more prominently in the permit with specific requirements presented and the reporting of compliance should be monthly rather than annually.

Part I.B imposes requirements for TRC or E. coli levels.  The monitoring frequency for all limits and compliance alternatives should be daily.

Part I.E.1.a calls for biological monitoring that would apply after the expansion is completed.  That monitoring should be imposed now and should be done quarterly with no option to reduce the frequency.  We are experiencing fish kills at present.  We know that the influent to the STP will change over time with the introduction of new chemicals and pharmaceuticals.  Only periodic biological monitoring will alert us to problems in a timely manner before irreparable damage occurs.

Part I.F.2 imposes a requirement to notify the DEQ but it places no time limit on when the notice is to occur.  It should state that the notice is to be made within 2 work days of the STP becoming aware of such an indirect discharge condition.

Part I.F.5 calls for the creation and approval of the O and M manual for the STP.  That section should address the minimum operator requirements for the plant before and after the expansion.  This is a complex plant and proper operation can only be assured by round the clock presence of a qualified operator.  Therefore, round the clock staffing should be specified in this part of the permit.

Part I.F.8 addresses water quality criteria monitoring.  Initial monitoring should not wait for three years.  It should be done within one year of permit issuance and annually thereafter both before and after the expansion.  In light of the prevalence of intersex conditions in the fish in this part of the river, estrogenic compounds should be added to the list of chemicals to be analyzed under this requirement.

Part I.F.12 calls for the creation and submittal of an Interim Optimization Plan.  The permit should be amended to state that the DEQ will have the authority to approve and amend that plan, the permit holder will be required to implement the plan as soon as practical, and compliance with the plan will be an enforceable condition of the permit, with periodic certification of compliance and records of compliance submitted at the time of certification.

Part I.G addresses the land application of sludge.  As written, certain records are to be retained.  A reporting requirement should be added.  The plant operator should be required to report and certify compliance with all aspects of sludge management in this subsection, on an item by item basis each month.  Self enforcement is at the heart of effective waste water point source permiting.  It is time to extend that effective principle to sludge management as well.

Part I.G.5.b places restriction on land application where other sources of PAN exist.  The permit should require a certification of compliance from both the STP and the land owner for this provision before sludge is applied, with submittal of those certifications to the DEQ. 

Thank you for your consideration of our comments regarding the permit for the operation of the Strasburg sewage treatment plant.  We appreciate DEQ's past efforts to work cooperatively with Friends on issues concerning the health of the river and we look forward to working with you in the future.    

Sincerely,


Ron Falyar
President 


Edinburg Town Council
September 1, 2006
Edinburg Town Council meeting - June   No Planning Commission Meeting

 
DEQ is setting new criteria for water and waste water treatment.  Town will comply.
 
3 new filters will expand capability to process water and facilitate maintenance when it is necessary to clean them.
 
Sewage is spread in beds to dry and then is shipped to the landfill.
During the winter it is difficult to dry sludge so it is shipped to the Aileen plant where county takes care of it for a fee.  The town is thinking of purchasing a fan press which would allow it to take care of the problem in house.
 
The town is acquiring an intern for during the summer  who will map water and sewage lines.
 
The town fees for water and sewage hook up fees will increase July 1st.  Water fees will go up from $2000 to $4000,  Sewage will go from $3000 to $6000. Out of town fees will be 50% higher,  $7500 for water and $1000 for sewage.
 
After the completion of Madison Village (Rose Hill town houses and two condos), 117 units, Edinburg Square 61 units,  Shenandoah Avenue 30 units and a few parcels in town,  the town will reach its sewage capacity and will need to upgrade.  New requirements by the state will force the town to upgrade in any case.
 
Town Council granted water and sewer hookups to Irwin"s (five acres) and several adjacent private residences which are located outside town limits.  There was one dissenting vote.  This council member questioned granting a permit to Irwin when it was not known how this property was going to be used in the future. 


 
 
 
 
 
 
 
 
 
 
Orndorff Trout Farm
 
“A Way to Play” on Rt. 11 in Woodstock
 
Mt. Jackson Sewage Treatment Plant
 
Edinburgh Sewage Treatment Plant
 
Chemstone Update
june 24, 2006
 
FNFSR Comments to DEQ on Strasburg STP
Tues., june 27, 2006
 
Edinburg Town Council Meeting
Friday, September 1, 2006
 
 
 
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