Franklin Permit Modification

24 Apr
April 24, 2008

Letter of comment to DEQ concerning permit modification for copper at their Sewage Treatment Plant on the Blackwater River.

Dear Mr. Smithson,

As Riverkeeper for the Blackwater Nottoway Riverkeeper Program (BNRP) I am submitting comment on behalf of the BNRP pertaining to modification of the City of Franklins WWTP permit (VA0023922) for copper. We request that the concerns stated in this letter be entered into public record for this permit modification.
Our Concerns are:
1: The executive summary of the WER study says that with the clean testing techniques that the WWTP was unable to meet their permit limits. This contradicts the paper sent me by the lead at Hazen & Sawyer. That research provided in that paper says that there were no copper exceedances (pg. 10) when the recommended EPA metals translator is used (and only 1 exceedance without the translator). The paper goes on to say that “a WER study of copper is not appropriate at this time. However there may be some benefit to a WER study if a future problem arises.” (pg. 12). No such future problem was identified in any of the documents.

2: The next issue is that WER samples are supposed to be taken at least one month apart. This is not the case, as samples were drawn May 8-9, June 5-6, and June 26-27. It’s just two days difference between the first two samples, but it is 11 days different between the second and third samples. Regardless, not all procedures were properly followed

The BNRP is not asking for a public meeting on the issue but wants our comments on the record in the event that in the future copper issues become a problem. In summary:
1: The WWTP never examined where the copper was coming from. In all likelihood it is coming from the deterioration of infrastructure, and this problem needs to be addressed since it is only likely to get worse over time.
2: The consultants hired to examine copper testing indicated that developing a WER was inappropriate, yet that process went forward anyway.
3: There were procedural errors made in the WER development.

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