December 2009 UPDATE:
Currently, we are waiting for the publication of a draft permit by the VA Dept. of Envinronmental Quality (DEQ) based upon Recyc Systems' application to DEQ in November. Once this draft permit is published, we will have 30 days to comment on the most recent permit and TO REQUEST A PUBLIC HEARING so that Friends and others can air our concerns in front of DEQ and a member of the State Water Control Board.
Please stay tuned for alerts from Friends regarding HOW YOU CAN HELP!
Below are the November alert fo comments (comment period is over) and our concerns related to Recyc Systems Inc.'s latest permit application for your reference.
November 2, 2009 - alert
Dear Friends;
The potential for
spreading biosolids from sources of industrial sewage and sewage
treatment facilities from outside of Shenandoah County AND the
Commonwealth of Virginia has risen again. Recyc Systems Inc. of
Fredericksburg, VA withdrew their initial permit request in March of
this year due to pressure from the public and lack of interest from the
farming community. Recyc Systems has now re-submitted a permit
request to the Department of Environmental Quality (DEQ) and the
permitting process has begun again. We
need you to submit comments AGAIN in order to gain a public hearing in
which a member of the State Water Control Board will be present to hear
our concerns.
The issues we are
confronting are the same, however some landowners have withdrawn their
land and one landowner has been added. We continue to have great
concerns related to the the environmentally sensitive areas still
included in the permit - areas of floodplain, karst geological features
including rock outcrops, sinkholes and shallow soils, and the foreign
nature of the materials originating from out of state and from large
sewage and industrial waste treatment facilities in Washington D.C.,
Philadelphia, etc.
Recyc Systems, Inc. is
applying for a permit to authorize land application of biosolids to 23
fields, totaling 716.5 acres of agricultural land. Seven of the fields
are owned by Wilson G. Eastep and are located near the intersection of
Rt. 796 and Rt. 11; eleven fields are owned by Jonathon E. Day and are
located near the intersection of Rt.11 and Rt. 720 (Meems Bottom); five
fields are owned by Lewis F. Gochenour and are located near the
intersection of Rt. 11 and Rt. 661.
Please take the time
to comment on this revised permit with your own personal concerns and
by using the information to the right in the blue box.
COMMENT PERIOD IS OVER BUT THERE WILL BE ANOTHER OPPORTUNITY SOON!
Friends of the North Fork of the Shenandoah River
P O Box 746
Woodstock VA 22664
540-459-8550
friends@shentel.net
leslie.watson@fnfsr.org
Friends' concerns regarding the spread of out of state biosolids on Shenandoah County agricultural land:
- Much of the land to which
the biosolids would be applied is in extremely close proximity to, or
in the floodplain of the North Fork of the Shenandoah or streams that
flow into the North Fork;
- Much of the application
area identified in the permit is noted to be environmentally sensitive
due to a combination of conditions, including: presence of sink holes,
slopes greater than 15%, shallow soils on fractured or limestone
bedrock, and potential for leaching based on texture or excessive
drainage;
- The current state of
knowledge regarding the movement and effects of biosolids (including
the affects of combination of products including heavy metals like
arsenic, cadmium, copper, lead, and mercury as well as many industrial
and household products like hormones and other drugs, personal care
products, PCBs and other organic chemicals that are not removed during
the sewage treatment process) in the environment is insufficient to
ensure that DEQ can approve this permit and still meet its mission to
protect and enhance the environment of Virginia and promote the health
and well-being of the citizens of the Commonwealth.
More information about biosolids can be found at the Virginia Department of Environmental Quality website:
http://www.deq.virginia.gov/vpa/sewage.html
|
August 3, 2009
Please submit your comments in support of the
Department of Conservation and Recreation’s draft storm water regulations!
http://www.townhall.state.va.us/L/comments.cfm?stageid=5070
WE NEED YOUR HELP!
The Virginia Department of Conservation and Recreation (DCR) has released draft stormwater regulations that will help reduce polluted run-off from developed and developing land. These regulations will help localities protect our groundwater and streams from the dirt, bacteria, fertilizers and chemicals that wash off lawns, roads, and parking lots every time it rains. Public comments are being accepted until August 21, 2009. Please use this link to register your comments today.
Why we NEED these regulations:
- To protect our drinking water: The majority of Shenandoah Valley residents obtain their drinking water from surface waters.
- To protect fishing, recreation and tourism: The hot, dirty water that comes off parking lots, roads, and roofs after a rainstorm damages good fishing and our streams.
- To save our water supply: Improved stormwater management helps recharge groundwater by letting the rain soak into the ground while heavy run-off from developed areas makes periods of flooding more intensive and damaging.
- Please support the proposed stormwater regulations now because:
- Runoff from poorly designed development contaminates drinking water sources and adds to the cost of providing clean drinking water. The karst topography in the Shenandoah Valley leaves our water resources particularly vulnerable to contamination.
- Most of the rivers and streams in the Northern Shenandoah Valley are already impaired. If run-off caused by land development is not reduced now, pollution will continue to harm our water quality and fishery resources.
- While pollution from municipal waste water treatment plants and agriculture have been reduced considerably, pollution from stormwater run-off is rising at an alarming rate.
- More needs to be done to prevent increased pollution from stormwater run-off. While local residents are paying higher fees to construct new sewage treatment plants, run-off pollution from developed land is increasing. The proposed regulations require developers to join the agricultural community, industry and local governments in taking additional steps to reduce pollution in our streams and rivers.
Please see below for important points to include in your comments (deadline is August 21) along with your personal concerns for clean water.
Thank you for your time and commitment to healthier water.
Leslie Mitchell-Watson, Executive Director
DEADLINE FOR COMMENTS
Date: Friday August 21, 2009 Website: Virginia Regulatory Town Hall
IMPORTANT POINTS to make in your comments:
**Please** let the Department of Conservation and Recreation know that you support the following:
1. Strengthening of the stormwater regulations to improve water quality in Virginia.
2. Adoption of the proposed development design criteria limiting runoff from developed and developing land to 0.28 pounds of phosphorus per acre.
3. Regulations that support smart growth development strategies and do not provide disincentives for redeveloping previously developed land or high-density projects in more urban areas.
Click here or type in http://www.townhall.state.va.us/L/comments.cfm?stageid=5070 in your browser to submit your personal concerns about protecting water quality in Virginia
Contact Friends:
Friends of the North Fork of the Shenandoah River
P O Box 746
Woodstock VA 22664
540-459-8550
friends@shentel.net
leslie.watson@fnfsr.org
2009 Draft Stormwater Regulations - Joint Letter of Support from Friends and Shenandoah Forum.
Please add your support by commenting at
http://www.townhall.state.va.us/L/comments.cfm?stageid=5070.
July 27, 2009
Dear Editor
After more than three years of research and development, the Virginia Department of Conservation and Recreation (DCR) has released draft stormwater regulations that will allow local governments to regulate polluted run-off resulting from land development. These regulations will help localities protect our groundwater and streams from the dirt, bacteria, fertilizers and chemicals that wash off lawns, roads, and parking lots every time it rains.
Why do we need regulation?
- We need healthy drinking water: The majority of Shenandoah Valley residents obtain their drinking water from surface waters.
- To protect fishing, recreation and tourism: The flash of hot, dirty water that comes off parking lots, roads, and roofs after a rainstorm decimates good fishing streams.
- To save our water supply: Improved stormwater management helps recharge groundwater by letting the rain soak into the ground while heavy run-off from developed areas makes periods of flooding more intensive and damaging.
No time to wait!
Only 31.3% of the Commonwealth's total of rivers and streams are monitored by the Virginia Department of Environmental Quality. However, more than half of these waterways are already impaired. Increased stormwater run-off will only continue to worsen pollution and have a heightened impact on our already unhealthy streams and rivers.
The agricultural community and municipalities have made progress in cleaning up our waterways -- almost every form of point source and agricultural related pollution in the Chesapeake Bay watershed shows a downward trend. However, pollution related to stormwater run-off is rising at an alarming rate.
Now is the time!
The construction industry needs to do its share to prevent increased pollution from stormwater run-off. While local residents are paying higher fees to construct new sewage treatment plants, run-off pollution from developed land is increasing. The proposed regulations require developers to join the agricultural community, industry and local governments in taking steps to reduce pollution in our streams and rivers.
Surveys leave no doubt. Virginians want clean water. We urge DCR to adopt and implement the proposed regulations now. You can submit comments in support of these regulations by visiting Virginia's Townhall website -
http://www.townhall.state.va.us/L/comments.cfm?stageid=5070.
Sincerely,
Kim Woodwell - Executive Director Shenandoah Forum www.ShenandoahForum.org
Leslie Mitchell-Watson - Executive Director Friends of the North Fork of the Shenandoah River
_________________________________________________________________________
"Comments regarding Biosolids permitting in Shenandoah County" March 31, 2009
Tim HiggsValley Regional OfficeDepartment of Environmental Quality4411 Early RoadP.O. Box 3000Harrisonburg, VA 22801
Dear Mr. Higgs,
These comments on the permit application to allow land application of biosolids in Shenandoah County are being filed on behalf of the Friends of the North Fork of the Shenandoah River, which is a community-based volunteer organization representing 400 members dedicated to protecting and enhancing the North Fork of the Shenandoah River.
The Friends of the North Fork of the Shenandoah River opposes the issuance of this permit and requests a public hearing on this matter to be attended by a member of the state water control board (rep from the TAC anybody else?).
The subject permit would allow the application of biosolids to over 1,750 acres of farmland in Shenandoah County. Many of the fields identified in the permit application are in extremely close proximity to the North Fork of the Shenandoah or streams that flow into the North Fork. The majority (55%) of the fields identified in the permit application are noted to be environmentally sensitive due to a combination of conditions, including: presence of sink holes, slopes greater than 15%, shallow soils on fractured or limestone bedrock, and potential for leaching based on texture or excessive drainage. Habitat of State-listed endangered species including the brook floater (Alasmidonta varicose) and wood turtle (Glyptemys insculpata) may occur near several of the proposed fields.
Permitting application of biosolids to the proposed sites is not prudent. Given this local situation and the many unknowns regarding the fate, transport and effects of many of the chemicals that have been found in biosolids, DEQ cannot confidently predict what level of harm will occur as a result, nor can they conclude that this action is protective of public health and the environment.
Although land application of treated sewage sludge is legal in Virginia, because the regulations governing such use are based on out-of-date or insufficient information, they are not adequate to protect the environment or human health. Due to the uncertainty surrounding the effects of land application of sewage sludge to the environment and human health, in 2007 the Virginia General Assembly instructed the Virginia Departments of Health and Natural Resources to convene a Panel of Experts to study the impact of land application of biosolids on human health and the environment. In its final report, the Panel stated that except for nutrients and metals, very little is known about the other chemicals in biosolids. There is very little research on the transport mechanisms for many of these chemicals and how they might affect water quality. The Panel concluded that because so much is unknown about the effects of biosolids on water quality they were unable to reach a conclusion. The report recommends the need for additional research regarding 1) the additive or synergistic effects within the complex mixture of biosolids, 2) effects of antibiotics, hormones, flame retardants, pharmaceuticals and personal care products, and other organic compounds, 3) what buffers are adequate to protect water bodies, and 4) long-term environmental effects. The Panel also recommended that a Technical Advisory Committee (TAC) should examine DEQ regulations regarding identification of environmentally sensitive sites and that particular attention should be paid to applications on slopes greater than 7%, karst topography and soils with high runoff potential. Finally, the Panel recommended the review and analysis of the most recent literature on the effects of biosolids on health and the environment to facilitate more informed decision-making by DEQ. The recommended Technical Advisory Committee has not completed its work.
Biosolids have been treated to reduce (but not eliminate) the levels of disease-causing organisms and odor. However, under federal and state regulations, they are allowed to contain heavy metals, including arsenic, cadmium, copper, lead, mercury, and numerous other potentially harmful chemicals at certain levels. Today’s sewage treatment plants are not designed to remove many of the chemicals that are currently entering the wastestream. As a result, many industrial and household products including hormones and other drugs, personal care products, PCBs and other organic chemicals are being found in waterways across the country. Because these chemicals are not removed in the treatment process, they also end up in the sludge that is used as fertilizer.
In it’s recently released “Targeted National Sewage Sludge Survey Report” (Jan. 2009), the U.S. EPA reports on the presence of 145 different chemicals in sewage sludge samples from 74 sewage treatment plants in 35 states. In addition to nitrates and phosphorus, almost every sample collected in 2006 and 2007 contained metals, organics and hydrocarbons, pharmaceuticals, steroids and hormones and flame retardants. Overall, 28 different metals were detected (27 of them were present in every sludge sample analyzed), 57 different pharmaceuticals (3 were present in every sample), 25 steriods and hormones (9 of which were found in 95% of samples), 6 organics and hydrocarbons and 4 flame retardants. While not much is known about the environmental effects of many of these chemicals, it is well documented that prolonged exposure to metals such as cadmium, mercury and lead can cause serious health problems in animals and humans.
Insufficient information exists to assess the effects of some of these chemicals on water quality. As a result, there are no regulatory controls on the levels of these chemicals that can be present (allowed?) in biosolids used as fertilizer. Even less information is available regarding the effects of any number of potential combinations of these chemicals in the environment.
Virginia State Code Section 62.1-44.19:3.B requires that the State Water Control Board, “… adopt regulations to ensure that …ii)land application, marketing, and distribution of sewage sludge is performed in a manner that will protect public health and the environment; and iii) the escape, flow or discharge of sewage sludge into state waters, in a manner that would cause pollution of state waters … shall be prevented.” As was concluded by the Panel of Experts and reinforced by the EPA study on sewage sludge, much additional information is needed to ensure protection of health and the environment.
The current state of knowledge is insuffient to ensure that DEQ meets its mission to protect and enhance the environment of Virginia and promote the health and well-being of the citizens of the Commonwealth. Given an incomplete analysis of what is in the specific biosolids and the lack of scientific information regarding the fate, transport and environmental effects of many of the chemicals that may be found in sewage sludge, DEQ cannot confidently determine what an adequate setback distance will be to protect water quality, aquatic organisms, endangered species or human health.
Given the lack of environmental effects information that currently exists for this kind of material, existing water quality problems in the North Fork of the Shenandoah River and the prevalence of steep slopes and karst topography in the areas covered by this permit application, the Friends of the North Fork of the Shenandoah River recommends that this permit not be issued. DEQ should suspend granting permits for land application of biosolids until such time as adequate information is obtained to thoroughly assess the potential for effects on water quality and human health and the state appointed technical advisory committee (TAC) completes its review of DEQ regulations pertaining to the land application of biosolids.
We further request that DEQ convene a public hearing on this permit request and request the attendance of a member of the State Water Control Board and Technical Advisory Committee. Such hearing should be held in Shenandoah County.
Thank you for consideration of these comments.
Sincerely,
Leslie Mitchell-Watson
Executive DirectorFriends of the North Fork of the Shenandoah River540-459-8550leslie.watson@fnfsr.org"dedicated to protecting and enhancing the purity and flow of the North Fork of the Shenandoah River"_________________________________________________________________________
Friends of the North Fork of the Potomac ConservancyShenandoah River 19 West Cork Street,P O Box 746 Suite 201Woodstock, VA 22664 Winchester, VA 22601
October 27, 2008
Dear Shenandoah County Community Planning Steering Committee and Board of Supervisors:
We commend the Shenandoah County Community Planning Steering Committee for sponsoring the ongoing community forums. These gatherings are valuable for collecting community input as you develop a set of tools to preserve the rural character of our county.
In the Shenandoah County Comprehensive Plan’s vision statement, protection of natural resources tops the list of priorities needed to maintain the rural character of the county. This priority was confirmed in the first community forum, when the importance of natural resources and their protection was specified by residents no less than 23 times (as recorded by the facilitators) in the small group discussions. Almost every group listed waterways as a vital component of the county’s rural character. Clearly, the citizens of Shenandoah County value the preservation of our streams, rivers and forests as part of this community planning process.
It is surprising then, that these citizen concerns for natural resources have not been explicitly addressed in the tools presented for community consideration. Tools that preserve the county’s rural character can be beneficial to the environment, depending on the tool and how it is implemented. For example, farms and forests, when managed appropriately, are better for the environment than sprawling streets. Putting land in conservation easement (whether donated, purchased, or a mix of both) commits property to remain in farming or other low-intensity use. Let’s talk openly about how these tools will preserve the natural environment.
When development does occur in rural areas (as we know it will), the tools selected should include measures to reduce impervious surfaces. Impervious surfaces reduce the recharge of our groundwater aquifers, and could cause the water table to drop. The increased runoff would flow quickly to overloaded streams and rivers picking up pollutants and eroding stream banks along the way. Additionally, the county and its residents would not have the opportunity to use that water (for drinking, irrigation or other uses) before it flowed out of the county.
The tools used to manage development should require low impact development (LID) methods in rural areas. LID is a design process that prevents excess stormwater from running off a property, allowing it to soak into (and filter through) the soil. This recharges the groundwater and reduces pollution in our rivers. LID implementation would serve the dual purpose of protecting our water resources and discouraging excess housing on farmland and forests. Providing vegetation along stream banks further cleanses the runoff before it enters our waterways.
These are the type of issues that should be explicitly addressed in the solutions implemented by the county. We ask the Steering Committee to consider how each of the tools selected will preserve the natural resources that are so highly valued in the rural areas. We look forward to the final community forum on October 29th, and the design of a full complement of tools that preserves the rural character of the county while protecting our precious natural resources.
Sincerely,
Leslie D. Mitchell-Watson, Patrick Felling
Friends of the North Fork of the Policy Associate
Shenandoah River Potomac Conservancy
SiteDesign_ShenValley.pdf
_________________________________________________________________________
DEQ Proposal to Relax Water Quality Standards
May 28, 2008
Jean GregoryDept. of Environmental QualityP.O. Box 1105Richmond, 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 RiverPO Box 746Woodstock, Virginia, 22664
cc:Governor of Virginia, Timothy KaineSecretary of Natural Resources, Preston BryantDEQ 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 avoid repeats 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.
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.
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Comments on Edinburgh Sewage Treatment Plant permit
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.
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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!
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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
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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.
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Biosolids in Shenandoah County
Shenandoah County Comprehensive Plan
DEQ Proposal to Relax Water Quality Standards
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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