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Richard L. Latterell
PO Box 763
Shepherdstown, WV 25443

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:

I offer the following comments on the draft permit 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.

I am very concerned that the conditions of the DEP draft permit will allow significant further degradation of Evitts Run and the Shenandoah River. I 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 and/or the Shenandoah than it would be under the draft permit that is the subject of these comments.

The draft permit will allow significant increases in bacteria, lead, biodegradable materials, and ammonia compared with the April-August 2004 averages. Evitts Run, a trout stream stocked regularly by WVDNR, already shows signs of degradation. Benthic surveys conducted by the Jefferson County Watersheds Coalition (JCWC) from 1998 through 2003 have shown that whereas Benthic communities in all reaches of Evitts Run show evidence of chronic impairment, the most extreme levels of impairment occurred in the mid-reaches downstream from the Charles Town Wastewater Treatment Plant.

Profuse algal blooms observed in these same mid-reaches of Evitts Run are symptomatic of over-nutrification. Further evidence in support of this hypothesis is the reported increase in bacterial (Fecal Coliform) contamination downstream from Charles Town/Ranson (site of the sewage treatment plant). A recent survey by JCWC (Fall, 2004) revealed excessive concentrations of Fecal Coliform at nine stations spanning all reaches of Evitts Run. However, the most striking variation was the 8-fold increase in E. coli concentrations downstream compared with upstream of the Charles Town sewage treatment plant.
Granted these data do not establish a causal relation between over-nutrification indicated by algal blooms and a profusion of Coliform bacteria -- and impairment of benthic communities. Regardless, combined evidence represented by these indicators of impaired water quality suggest that Evitts Run is unable to adequately process and abate the load of pollutants that are currently discharged into it. Increases in pollutant discharges of the magnitudes requested by the permit would overwhelm the system and accelerate further degradation of Evitts Run.

Similar considerations also apply to the Shenandoah River re either direct or indirect discharges of sewage effluent from the Charles Town sewage treatment plant. The Shenandoah River is the most polluted stream in Jefferson County (See USEPA303D list). Some of the highest concentrations of polychlorinated biphenyls (PCBs) in North America have been recorded from lower reaches of the Shenandoah. Mercury is so abundant in food chains of the Shenandoah waters and sediments that advisories against consumption of at least some species of fish have been issued. Recently, USEPA denied a discharge permit to a proposed subdivision on grounds that the proposed receiving stream was so feeble that 70,000 gals. of undiluted sewage effluent would be discharged directly into the lower Shenandoah on a daily basis. Further degradation of the Shenandoah consequent on additional direct or indirect discharges of sewage effluent from the Charles Town facility would be unconscionable.

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

-- "hold the line" on current standards for treated sewage effluent discharges;
-- provide antidegradation determinations for each pollutant (60 CSR 5-5.6);
-- mandate precise measurement and prompt reporting of lead levels in treated effluent;
-- require statistically representative effluent sampling. The current practice 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.
-- Explain how DEP developed the permit. Law requires calculations in the fact sheet.

Thank you for consideration of my comments.

Sincerely,

Richard L. Latterell