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Monday, June 18, 2018

Modern History of the Service Authority - Second Quarter 2017

by Neil Richard

Because of the severity and complexity of the issues surrounding the King George County Service Authority (KGCSA) in recent months, we are "jumping the timeline" by giving you an inside look at the operations at five local Waste Water Treatment Plants (WWTPs). These five WWTPs are Dahlgren District, Fairview Beach, Hopyard Farms, Oakland Park, and Purkins Corner. These WWTPs are operated and maintained by KGCSA and are under the enforcement authority of the Virginia Department of Environmental Quality (DEQ).

Continuing our modern history coverage of the King George County Service Authority, you can also read about the First Quarter of 2017.

CAUTION - Some of the links below may show images of human waste.

April 2017

On April 4, 2017, the Board of Directors meeting minutes report that Ruby Brabo and Chris Werle, Chairman, gave detailed reports. Brabo and Werle both reported on the recent tour of the Dahlgren Waste Water Treatment Plant (WWTP) where regional officials were invited to see some of the improvements at the plant. Werle gave a short overview of the recent Oakland Park water emergency but left it to Chris Thomas, General Manager, to give more details.

Thomas said the Virginia Department of Health (VDH) requires that the Service Authority conduct monthly testing of the water supply. In a sample drawn on March 8, 2017, there were no bacteriological elements present. After receiving a customer complaint on March 20, 2017, samples were taken and it was found that the chlorine levels were lower than expected. Thomas said this same sample was also tested for bacteria and there was coliform and E. coli present. A second sample was then collected according to VDH rules on March 22nd and it also tested positive for coliform and E. coli.

Thomas said that VDH directed them to collect more samples and if any tested positive, a boil water notice would be necessary. He said samples were collected on March 23rd with results arriving the next day. Two samples, one taken on French Court and another on Garner Drive, tested positive for coliform and E. coli. Thomas said that VDH then required a boil water notice to be issued and that Service Authority employees hand delivered these notices by late in the day on the 24th.

On April 18, 2017, Virginia Department of Environmental Quality (DEQ) sent an email to Chris Thomas regarding a future visit of the Fairview Beach WWTP to assist in regaining compliance. This email was from DEQ's Office of Water Compliance Manager, Jerome Brooks, who also sent an internal email that day regarding the lack of communication from Thomas. Brooks said "I haven’t heard from Mr. Thomas since our conference call the 21st of last month [March 2017].  At that time Mr. Thomas and his supervisor gave the impression they were accepting of DEQ’s proposal for assistance..." He also added "We will continue to pursue voluntary compliance assistance but at some point will look toward alternatives to regain  compliance at all 5 plants."

That same evening, Thomas gave an another update on the Oakland Park water issue at the Board of Directors meeting. In his update, Thomas said that the required "...samples were collected on Friday April 14th. All samples were absent for both total coliform and E. Coli."

Within a few days, Chris Werle gave the public two updates via Facebook. In his first update on April 20th, he said new water lines and hydrants were being installed along Mount Rose Drive as part of the project to extend water to the Route 3 and Route 301 intersection. The following day, April 21st, he gave an update regarding the presence of E. coli in the water in the Oakland Park system. In this update, he gave various potential reasons for the E. coli being in the water but no clear source was found.

On April 25, 2017, DEQ issued five Notices of Violation (NOVs) for each WWTP; Dahlgren, Purkins Corner, Oakland Park, Fairview Beach, and Hopyard Farms. Again, all five were cited for their lack of responses since November 2015.

Additionally, Oakland Park was cited for high levels of Total Suspended Solids (TSS), Total Kjeldahl Nitrogen (TKN), and Total Recoverable Copper. The February 2017 Discharge Monitoring Report (DMR) recorded the following levels with applicable limits:

  • TSS - 19 mg/L weekly average (limited to 10 mg/L)
  • TKN - 3.6 mg/L weekly average (limited to 3.0 mg/L)
  • Total Recoverable Copper - 33 ug/L weekly average (limited to 20 ug/L)

Dahlgren was also cited for not filing the industrial user survey by June 9, 2015 and Fairview Beach was also cited for not filing the February 2017 DMR by March 17, 2017.

There was a small sewage spill on or about April 25, 2017. According to the report filed with DEQ, there was a clogged main at Oakland Park WWTP and technicians had to use industrial equipment to unclog it. Less than 500 gallons was spilled in the woods where a manhole cover is located.

May 2017

Chris Werle began May with several updates for the general public via Facebook. They included details on the debt service fee, clarifications from a recent article in the Free Lance-Star, and an update on the water line expansion to the Route 3 and Route 301 intersection.

Also in early May, DEQ was once again trying their best to work with the Service Authority to bring the WWTP systems into compliance. In a May 11 email, Jerome Brooks said "Since we have been forced to go with the unannounced approach I think this will start off very similar to an inspection but end as a diagnostic evaluation in terms of us trying to work with the Service Authority through compliance assistance versus enforcement in our attempt to improve DEQ’s working relationship with them and the operation of that facility." The next day, he emailed colleagues at DEQ stating he again attempted to contact Chris Thomas but was unsuccessful.

DEQ made good on their plans to make an unannounced visit to the Fairview Beach WWTP on May 15, 2017. The Diagnostic Inspection report was detailed and lengthy. In it, there are several occurrences of parts or equipment that is either broken, difficult to use, repaired but yet to be placed back into service. This is plainly obvious in the Plant Maintenance section of the report which begins with "There was considerable evidence of maintenance problems at the facility."

On May 22nd, DEQ issued a Referral of Potential Violation for all five WWTPs; Dahlgren, Purkins Corner, Oakland Park, Hopyard Farms, and Fairview Beach. Three days later on May 25th, each of the same plants received a Notice of Violation. Dahlgren was again cited for failing to submit the industrial user survey. Oakland Park was cited for the March 2017 DMR reported value of 3.3 mg/L of TKN (the limit is 3.0 mg/L).  Purkins Corner, Fairview Beach, and Hopyard Farms were only cited for their lack of required responses dating back to November of 2015.

The Board of Directors met on May 2nd and May 16th, but neither meeting included any information on the above activities. Chris Thomas did mention a planned upgrade at the industrial park pump station and both he and Werle gave updates on the Route 3 and Route 301 intersection project.

June 2017

The Service Authority reported a sewage spill on June 6 of unknown amount. The report stated that the main pump station at Fairview Beach WWTP lost power. The generator appeared to be functional but the battery backup unit was not.

The minutes for the June 6th Board of Directors meeting are currently unavailable. On June 7th, Chris Werle entertained several officials for a tour of the "Fairview Beach Riverbank Stabilization Project site."

On June 13, 2017, Rebecca Johnson, DEQ Water Compliance Inspector, sent Chris Werle an email stating that DEQ has been unable to effectively communicate with Chris Thomas and that Werle would become the new point of contact for the Service Authority.

Personal information has been redacted.


To his credit, Werle responded to the email within four hours stating he would have Thomas respond to the backlog with the required responses by June 30, 2017 and respond to the NOVs that were attached to the email by June 16, 2017. Even before responding to DEQ, Werle responded to Thomas telling him that "Not responding to these notices eventually catches up with us, could result in substantial fines and penalties, and if the BOS end up getting involved/upset, I might not be able to protect you." While Werle wouldn't inform the Board of Directors of the severity of the issue until March of 2018, he clearly was not pleased with the contact from DEQ.

The NOVs were issued the same day as the email, June 13th. In brief, the NOVs repeated the same citations as in the past. In summary, they were:

Dahlgren
- "The industrial user survey information was due to DEQ by June 9, 2015 but has not been received as of the date of this letter."
- "DEQ has not received the required responses from compliance documents sent from November 18, 2015 to May 22, 2017."
- "This facility had 12.0 points in the Compliance Auditing System at the end of April 2017."

Purkins Corner
- "DEQ has not received the required responses from compliance documents sent from November 18, 2015 to May 22, 2017."
- "This facility had 6.0 points in the Compliance Auditing System at the end of April 2017."

Oakland Park
- "DEQ has not received the required responses from compliance documents sent from November 18, 2015 to May 22, 2017."
- "The April 2017 DMR reported values of 4.2 mg/L and 6.5 mg/L for both the monthly concentration average and weekly concentration average maximum limits for TKN, respectively."
- "The April 2017 DMR reported a value of 18 mg/L for the weekly concentration average maximum limit for Total Suspended Solids (TSS)."
- "This facility had 6.0 points in the Compliance Auditing System at the end of April 2017."

Hopyard Farms
- "DEQ has not received the required responses from compliance documents sent from November 18, 2015 to May 22, 2017."
- "This facility had 7.0 points in the Compliance Auditing System at the end of April 2017."

Fairview Beach
- "DEQ has not received the required responses from compliance documents sent from November 18, 2015 to May 22, 2017."
- "The April 2017 DMR reported a value of 31 n/100mLs for the monthly concentration average limit for Fecal Coliform."
- "This facility had 7.0 points in the Compliance Auditing System at the end of April 2017."

In a flurry of emails between Chris Werle, Chris Thomas, and numerous employees at DEQ, the general feeling was one of progress. One email in particular from Jerome Brooks to his fellow DEQ counterparts summed it up nicely; "It appears something occurred to spark collaboration and communication that previously didn’t exist. ... Purely speculation but possibly Chris was given instructions to work with us after our conversation a couple months ago, by his supervisor, but didn’t follow through. Something has helped bring about this quick change.”

In the June 20th meeting minutes of the Board of Directors, Chris Werle's report consisted of the following short paragraph:

"I have a very short report. On June 12th, I prepared a newsletter article on fire hydrant operation and maintenance. On June 15th, I met with the general manager to review the DEQ-issued discharge permit for the Dahlgren Wastewater Treatment Plant. That’s all I have there."

While Werle made no mention of the new developments with DEQ, Thomas gave a longer update, which was a short update on the Route 3 and Route 301 water line extension project, but still neglected to share any updates related to the recent developments.

On June 23, 2017,  DEQ issued a Compliance Inspection Report for Oakland Park WWTP. In it, several tasks are listed as needing corrective action and a response was required by July 21, 2017. The report cited several of the previously documented issues in previous NOVs.

On June 29th, Chris Thomas responded to both the Dahlgren and Hopyard Farms NOVs. These responses included many of the items that DEQ had cited as violations over the recent months, including the industrial user survey responses and the liner repairs at Dahlgren. On the same day, DEQ conducted a Diagnostic Inspection of the Oakland Park WWTP and Daniel Powell, an employee of the Service Authority, sent an email to DEQ about a "plant upset" at Oakland Park earlier in the week that was related to an excessive delivery of Bio-Carb. The inspection report noted "...several critical areas of the plant that required maintenance..."

The next day, June 30th, DEQ closed out the month by sending two Compliance Inspection Reports, one for Dahlgren and one for Hopyard Farms WWTPs. As with the similar report issued for Oakland Park WWTP a week prior, these reports noted previous issues and requested corrective action be taken. Dahlgren's biggest issue was the liner in the lagoon having fallen into disrepair while Hopyard Farms had a smaller issue of biological growth in the sampling tube.

Also on the 30th of June, Chris Thomas responded to outstanding questions from DEQ related to previously issued NOVs. There was also in internal DEQ email related to potential future enforcement. Within this email, DEQ worked to set the timeline of past events to better aid them in providing a way towards getting the Service Authority within compliance. Once again, DEQ shows an overwhelming willingness to help the Service Authority.

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