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Comments on Permit for "Old Standard" Treatment Plant WV0105724

paul burke, box 1320, shepherdstown wv 25443

These comments on "Old Standard" are brief, since the supporting information would duplicate my comments on the Charles Town modification. Those comments are attached, to avoid repetition.

1. The permit needs antidegradation determination for each pollutant. The statement that "The agency has made a determination that the proposed activity will not cause significant degradation to the receiving stream" is not supported by any calculations.
2. The permit needs limits for effluent turbidity, and continuous measurement of effluent turbidity.
3. The permit needs statistically representative testing. One test per month is not representative.
4. The permit needs to describe what will happen when more volume of effluent arrives than the hydraulic capacity of the plant.
5. The design flow needs to be reduced to a flow commensurate with 178 houses approved in Sheridan Subdivision, i.e. 17,800 gallons per day. Shepherdstown finds an average water use of 109 gallons per house per day for houses on water and sewer. Water use is declining all the time, with water-saving fixtures. Sewer use is less than water use. Little or no allowance is needed for infiltration, since the pipes are above the water table, so leakage out will be the problem, not leakage in.
6. Alternatively if phase 1 is designed for more than Sheridan, the legal ad and fact sheet need to be re-issued, since they say the plant will only serve "persons in the Sheridan Subdivision."
7. Condition C.19 does say that any pipe leak which releases raw sewage is a permit violation. It needs to require monitoring to identify pipe leaks. "Don't ask, don't tell" is not effective.
8. DEP's area list for Jefferson County needs to be notified of this permit, with a 30-day comment period (47 CSR 10-12.1.c.1.F.2). This has not been done. The comment period cannot close until 30 days after public notice to the list (47 CSR 10-12.1.b.1).
9. The permit needs to require diffusers on the outlet, sufficient to create instantaneous mixing, or alternatively the permit needs to specify zones of mixing and dilution.
10. The Fact Sheet needs to be reissued with fuller calculations, citations, and legal questions, to comply with federal regulations. It also needs to correct "privately owned sewage treatment plant" to acknowledge that Old Standard has a sales agreement to sell it to the Jefferson County Public Service District after construction.
11. The applicant should not be given a permit since the same principals, as Sheridan LLC, have been violating the Construction Storm Water registration WVR100139 for many months. They have not posted the required entrance sign and outlet marker, in spite of registered letters, and the Jefferson County Planning Commission has raised concerns about other violations.