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October 29, 2004

 

Director, Division of Water & Waste Management, DEP

ATTN: Anne Howell, Public Information Office

601 57th Street, SE

Charleston, WV 25304-2345

 

REF: Old Standard, LLC - WV0105724

 

Dear Ms. Howell:

 

We, the undersigned, being citizens of Jefferson County and users of the Shenandoah River, respectfully request a public hearing on the matter of Old Standard, LLC.

 

We raise the following issues that need to be clarified and resolved in a duly noticed public hearing:

 

  1. There is extensive confusion as to the discharge location.  Several different longitudes and latitudes are in the DEP submission, and none track to public notice S-93-04.
  2. There is extensive confusion as to the location of the plant and the location of the line from Sheridan Estates to the plant. 
  3. There is extensive confusion over the number of people to be served.  The projected population for Sheridan Estates subdivision is between 500-750 people, but the ad states that 3,570 people will be served. As there are no other subdivisions planned for this rural zoned area of Jefferson County, we are at a loss of why the projection needs to be so large. If the plant is designed for more than Sheridan, the legal notice must be reissued, since the public notice states the plant will only serve persons in Sheridan.
  4. The permit is silent on what safeguards will be used to monitor leakage and breaks in the sewer line from Sheridan to the plant and from the plant to the Shenandoah River.  Any rupture in this area would devastate the ground water.
  5. The baseline sampling of the Shenandoah River needs to be completed.  The six-month baseline test was never completed.
  6. The permit needs antidegradation determinations for each pollutant.
  7. The permit needs limits for effluent turbidity, and continuous measurement of effluent turbidity.

 

            [this was signed by about half a dozen people; I do not yet have the list of names & addresses]