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November 8, 2004


WV Department of Environmental Protection
Public Information Office

Attn: Anne Howell
601 57th Street
Charleston, WV 25304

RE: Comments on draft WV/NPDES permit, Appl. No. WV0022349


Dear WV Department of Environmental Protection:


Please accept the following comments on the draft WV/NPDES permit WV0022349 applied for by the City of Charles Town to discharge additional effluent into Evitts Run as a result of the expansion of the current sewage treatment plant.


We are very concerned that the conditions of the DEP draft permit will allow significant further degradation of Evitts Run. We urge the DEP to revise the draft permit to tighten restrictions forcing the Charles Town Sewage Plant to treat effluent in such a way that it will be much cleaner when it flows into Evitts Run than it would be under the draft permit that is the subject of these comments.


The draft permit will allow the following increases in treated effluent compared with the April - August 2004 averages:

--95 times as many bacteria

--43 times as many pounds of lead

--more than 9 times as many pounds of total suspended solids

--more than 5 times as many pounds of biodegradable materials

--nearly 3 times as many pounds of ammonia.


These changes will lead to serious degradation in Evitts Run, an important county stream near which citizens live and which is used by farmers whose fields adjoin it, and will also add to the pollution problems already harming the Shenandoah River, into which Evitts Run empties.


We urge that the DEP redraft and strengthen the permit and redraft the fact sheet to:


--provide antidegradation determinations for each pollutant (60 CSR 5-5.6)


--explain how DEP developed the permit. Law requires calculations in the fact sheet but they are not present in this instance and are needed, since DEP's results are baffling.


--provide limits for effluent clarity (turbidity), as required by law (47 CSR 10-6.3 implementing 40 CFR 122.44(d)(1)). To meet the standards of the law and prevent illnesses among County citizens in the vicinity of Evitts Run and the Shenandoah River, the plant needs to monitor turbidity continuously.


--require statistically representative effluent sampling; a sample size of four samples per month, only on Wednesdays, has too much variance to be "representative" as required by law, and allows too much delay to help the plant or the public fix problems before they harm citizens.


--require a description of contingency plans for situations where the volume of sewage arriving to be treated exceeds the plantís capacity. Sending the extra sewage into Evitts Run untreated is not an adequate plan.


--require monitoring to identify pipe leaks from all the new pipes that are part of this permit. Leaks pollute the groundwater, which in turn pollutes people's wells.


--require reporting of pipe leaks and spills.


Thank you for your consideration of these comments.




Susan Rissler Sheely††††††††††††††††

142 Long Marsh Lane†††††††††††††††

Charles Town, WV 25414†††††††††


Patricia Rissler

443 Long Marsh Lane

Charles Town, WV 25414


Jane Rissler

6V Plateau Place

Greenbelt, MD 20770


Cathryn Smith

P. O. Box 675

Charles Town, WV 25414


Jennifer Miller
265 Creekside Lane
Charles Town WV 25414


Wm. Kelly Baty
4704 Kabletown Road
Charles Town, WV 25414


Barbara Fry

224 Frys Lane

Charles Town, WV 25414


Mary L. MacElwee

20 Fairview Drive

Charles Town, WV 25414