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).
To give a little background on the documents below from the DEQ and the KGCSA, the analogy of a speeding ticket seems to work best. If you break the law by speeding, you might get a warning or a speeding ticket. If you get a ticket, it may be a simple one that you can pay online or it may be a harsh one that requires you to go to court. In some cases, you may get arrested or lose your license because of how fast you were driving. With the documents below, DEQ is the arm of the state government that is enforcing the rules while KGCSA is the entity that is breaking them. Instead of a speeding ticket, DEQ will issue a Notice of Violation (NOV). Depending on the severity, DEQ could be lenient and issue a Warning Letter (WL). And for clarity, just because there is a rule being broken, it does not mean there is any criminal activity.
CAUTION - Some of the links below may show images of human waste.
Five NOVs are issued, one for each WWTP, on January 9, 2017. The Dahlgren District WWTP NOV states that 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." It also states that "DEQ has not received the required responses from compliance documents sent from November 18, 2015 to November 16, 2016." Purkins Corner WWTP, Oakland Park WWTP, Hopyard Farms WWTP, and Fairview Beach WWTP are also missing the same compliance documents from November 18, 2015 to November 16, 2016. Additionally, the Fairview Beach WWTP is cited for "a value of 31 n/100mL for the monthly mean concentration average limit for Fecal Coliform." based on the November 2016 discharge monitoring report (DMR). The monthly legal limit for Fecal Coliform is 14 n/100mL.
The General Manager disclosed none of these violations during his report at the January 17, 2017 Board of Directors meeting.
In three Compliance Reports dated January 24, 2017, DEQ informed Chris Thomas, General Manager, that Dahlgren WWTP, Purkins Corner WWTP, and Oakland Park WWTP were inspected. In the Dahlgren Compliance Report, the inspector requested "1) a narrative either outlining a plan to resolve or confirming the resolution of the solids and sheen on the clarifier water surface and solids in the effluent tanks, and 2) a timeline on when maintenance will be conducted on the lagoon liner." In the Purkins Corner report, the inspector asked for a narrative on how solids in the clarifier weirs, UV alarms, and other items would be fixed. The Oakland Park inspection noted UV treatment issues as well as effluent trough issues.
On February 15, 2017, each of the five WWTPs was again issued a form from DEQ, this time a Referral of Potential Violation. Once again, DEQ informs KGCSA that they have not received any of the required responses from November 18, 2015 through January 9, 2017. This same verbiage is used for Dahlgren WWTP, Purkins Corner WWTP, Oakland Park WWTP, Hopyard Farms WWTP, and Fairview Beach WWTP.
The next day, DEQ again issues NOVs for the same five WWTPs. Dahlgren and Purkins Corner WWTPs are again hit with the same failure to communicate language. The other three WWTPs also see the same language but have additional violations.
Oakland Park WWTP shows amounts above the legal limits for TKN (Total Kjeldahl Nitrogen or organic nitrogen and ammonia nitrogen), cBOD5 (carbonaceous Biochemical Oxygen Demand or the amount of oxygen used to breakdown organic material), and Total Nitrogen. The TKN in December 2016 read 15.8 mg/L for the week and 4.2 mg/L for the month when the limits were 4.5 mg/L and 3.0 mg/L respectively. The cBOD5 was reported at 17 mg/L for December 2016 when the limit is 15 mg/L. The Total Nitrogen was 16.3 mg/L in December 2016 when the limit was 15 mg/L. Hopyard Farms WWTP had 1.79 mg/L of Total Phosphorus in the December 2016 DMR while the limit was 1.0 mg/L. Fairview Beach WWTP also had an excess of Total Phosphorus in the December 2016 DMR with a reading of 1.5 mg/L. This was above the same 1.0 mg/L limit.
The February 21, 2017 Board of Directors meeting once again showed no signs of any of the DEQ violations.
On March 2, 2017, Jerome Brooks, the Office of Water Compliance (OWC) Manager at DEQ, sent Chris Thomas an email. In brief, the email stated that DEQ was willing to help the KGCSA come into compliance. Brooks said "Additionally, some of your facilities have been and continue to be listed in the United States Environmental Protection Agency (EPA) database as having significant violations of permit requirements, which means the level of attention is higher in terms of the oversight and potential involvement by the EPA." Brooks goes on to say that the EPA has the authority to enforce the rules before the State.
Brooks also says "...the OWC would like to offer our assistance by means of a comprehensive performance diagnostic evaluation of your facilities. This degree of compliance assistance provided by the OWC, independent of the regional office support and involvement, is resource intensive and rarely offered but we believe in this case it will add a great deal of value in terms of working collaboratively to get these facilities back into compliance and to continue operating in compliance moving forward." Essentially, Brooks is offering the services and support, and presumably to some degree the financing, of DEQ to help KGCSA come back into compliance. The willingness of DEQ to come to the aid of the Service Authority struck me as something they rarely do but were more than willing to offer.
Nearly three weeks later, Brooks still had not heard from Thomas. When Brooks finally did hear from Thomas and a conference call was scheduled, Thomas asked to "...have his boss available for the call..." This is rather confusing as Thomas only answers to the five member Board of Directors. When it comes to the daily operations of the Service Authority, Thomas is the boss. Even the Service Authority Regulations state that the General Manager is the "Chief Administrative officer appointed by the King George County Service Authority Board of Directors."
The March 7, 2017 Board of Directors meeting had Chris Werle report about issues Faddis Concrete Products was having pumping waste water into the KGCSA sewer system. He also posted to Facebook about technicians relieving pressure in the industrial park sewer system to prevent damage to customers' grinders.
On March 14, 2017, DEQ sent Chris Thomas a letter regarding an additional violation at the Fairview Beach WWTP. In this case, the KGCSA was awarded a Water Quality Improvement Fund (WQIF) Grant in the amount of $330,493. However, because of excessive amounts of Total Phosphorus at Fairview Beach, the Service Authority was assessed a fine of $1,704 for the violation. This amount was paid a month later on April 18, 2017 as shown in the Agenda for the same date however nothing was mentioned during the General Manager's report that night or in previous meetings.
On March 15, 2017, all five WWTPs once again received NOVs. Yet again, all five were cited for a failure to communicate required information from 2015. Dahlgren and Hopyard had relatively minor violations. In addition to that, Purkins Corner WWTP in January 2017 had a reported value of 16.6 mg/L of TSS (Total Suspended Solids) where the limit is 15 mg/L. Oakland Park WWTP had 5.4 mg/L for TKN with a limit of 4.5 mg/L in January 2017. It also showed a value of 22 mg/L of Total Recoverable Copper when the limit is 20 mg/L. Fairview Beach WWTP had excess Fecal Coliform and Enterococci in January 2017. Fecal Coliform was reported at 64 n/100mLs with a limit of 14 n/100mLs and Enterococci was 104 n/100mLs with a limit of 35 n/100mLs.
The March 21, 2017 Board of Directors meeting made no reference to any violations at any of the WWTPs. However on March 24, 2017, Chris Werle reported on Facebook that several elected officials from the region toured the Dahlgren WWTP to see the upgrades that allow for "reduced effluent nitrogen and phosphorus."
On March 27, 2017, the repeating record of NOVs is again playing the same song of non-compliance. Dahlgren, Purkins Corner, Oakland Park, Hopyard Farms, and Fairview Beach WWTPs all received a Referral of Potential Violation. All reference a lack of communicating to DEQ the required documentation since November 2015.
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).
To give a little background on the documents below from the DEQ and the KGCSA, the analogy of a speeding ticket seems to work best. If you break the law by speeding, you might get a warning or a speeding ticket. If you get a ticket, it may be a simple one that you can pay online or it may be a harsh one that requires you to go to court. In some cases, you may get arrested or lose your license because of how fast you were driving. With the documents below, DEQ is the arm of the state government that is enforcing the rules while KGCSA is the entity that is breaking them. Instead of a speeding ticket, DEQ will issue a Notice of Violation (NOV). Depending on the severity, DEQ could be lenient and issue a Warning Letter (WL). And for clarity, just because there is a rule being broken, it does not mean there is any criminal activity.
CAUTION - Some of the links below may show images of human waste.
January 2017
The Service Authority began the year with a Board of Directors meeting on January 3, 2017. Cedell Brooks was nominated by Ruby Brabo to serve as Chairman but he declined. Chris Werle was nominated by Richard Granger for Chairman and all voted in his favor. Brabo then nominated Richard Granger to serve as Vice-Chair and again, all voted in his favor.Five NOVs are issued, one for each WWTP, on January 9, 2017. The Dahlgren District WWTP NOV states that 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." It also states that "DEQ has not received the required responses from compliance documents sent from November 18, 2015 to November 16, 2016." Purkins Corner WWTP, Oakland Park WWTP, Hopyard Farms WWTP, and Fairview Beach WWTP are also missing the same compliance documents from November 18, 2015 to November 16, 2016. Additionally, the Fairview Beach WWTP is cited for "a value of 31 n/100mL for the monthly mean concentration average limit for Fecal Coliform." based on the November 2016 discharge monitoring report (DMR). The monthly legal limit for Fecal Coliform is 14 n/100mL.
The General Manager disclosed none of these violations during his report at the January 17, 2017 Board of Directors meeting.
In three Compliance Reports dated January 24, 2017, DEQ informed Chris Thomas, General Manager, that Dahlgren WWTP, Purkins Corner WWTP, and Oakland Park WWTP were inspected. In the Dahlgren Compliance Report, the inspector requested "1) a narrative either outlining a plan to resolve or confirming the resolution of the solids and sheen on the clarifier water surface and solids in the effluent tanks, and 2) a timeline on when maintenance will be conducted on the lagoon liner." In the Purkins Corner report, the inspector asked for a narrative on how solids in the clarifier weirs, UV alarms, and other items would be fixed. The Oakland Park inspection noted UV treatment issues as well as effluent trough issues.
February 2017
During the February 7, 2017 Board of Directors meeting, Chris Werle reported that he and Chris Thomas met with DEQ regarding the permit for the wells at Hopyard Farm. Neither mentioned any previous violations at the WWTPs. Thomas did suggest that Werle be compensated for his service on the Board and that such compensation is allowed per Virginia Code but would need to be adopted in a resolution from the Board of Supervisors. During the Board of Supervisors meeting, the resolution to pay citizen members $75 per meeting was adopted.On February 15, 2017, each of the five WWTPs was again issued a form from DEQ, this time a Referral of Potential Violation. Once again, DEQ informs KGCSA that they have not received any of the required responses from November 18, 2015 through January 9, 2017. This same verbiage is used for Dahlgren WWTP, Purkins Corner WWTP, Oakland Park WWTP, Hopyard Farms WWTP, and Fairview Beach WWTP.
The next day, DEQ again issues NOVs for the same five WWTPs. Dahlgren and Purkins Corner WWTPs are again hit with the same failure to communicate language. The other three WWTPs also see the same language but have additional violations.
Oakland Park WWTP shows amounts above the legal limits for TKN (Total Kjeldahl Nitrogen or organic nitrogen and ammonia nitrogen), cBOD5 (carbonaceous Biochemical Oxygen Demand or the amount of oxygen used to breakdown organic material), and Total Nitrogen. The TKN in December 2016 read 15.8 mg/L for the week and 4.2 mg/L for the month when the limits were 4.5 mg/L and 3.0 mg/L respectively. The cBOD5 was reported at 17 mg/L for December 2016 when the limit is 15 mg/L. The Total Nitrogen was 16.3 mg/L in December 2016 when the limit was 15 mg/L. Hopyard Farms WWTP had 1.79 mg/L of Total Phosphorus in the December 2016 DMR while the limit was 1.0 mg/L. Fairview Beach WWTP also had an excess of Total Phosphorus in the December 2016 DMR with a reading of 1.5 mg/L. This was above the same 1.0 mg/L limit.
The February 21, 2017 Board of Directors meeting once again showed no signs of any of the DEQ violations.
March 2017
On March 2, 2017, Jerome Brooks, the Office of Water Compliance (OWC) Manager at DEQ, sent Chris Thomas an email. In brief, the email stated that DEQ was willing to help the KGCSA come into compliance. Brooks said "Additionally, some of your facilities have been and continue to be listed in the United States Environmental Protection Agency (EPA) database as having significant violations of permit requirements, which means the level of attention is higher in terms of the oversight and potential involvement by the EPA." Brooks goes on to say that the EPA has the authority to enforce the rules before the State.
Brooks also says "...the OWC would like to offer our assistance by means of a comprehensive performance diagnostic evaluation of your facilities. This degree of compliance assistance provided by the OWC, independent of the regional office support and involvement, is resource intensive and rarely offered but we believe in this case it will add a great deal of value in terms of working collaboratively to get these facilities back into compliance and to continue operating in compliance moving forward." Essentially, Brooks is offering the services and support, and presumably to some degree the financing, of DEQ to help KGCSA come back into compliance. The willingness of DEQ to come to the aid of the Service Authority struck me as something they rarely do but were more than willing to offer.
Nearly three weeks later, Brooks still had not heard from Thomas. When Brooks finally did hear from Thomas and a conference call was scheduled, Thomas asked to "...have his boss available for the call..." This is rather confusing as Thomas only answers to the five member Board of Directors. When it comes to the daily operations of the Service Authority, Thomas is the boss. Even the Service Authority Regulations state that the General Manager is the "Chief Administrative officer appointed by the King George County Service Authority Board of Directors."
The March 7, 2017 Board of Directors meeting had Chris Werle report about issues Faddis Concrete Products was having pumping waste water into the KGCSA sewer system. He also posted to Facebook about technicians relieving pressure in the industrial park sewer system to prevent damage to customers' grinders.
On March 14, 2017, DEQ sent Chris Thomas a letter regarding an additional violation at the Fairview Beach WWTP. In this case, the KGCSA was awarded a Water Quality Improvement Fund (WQIF) Grant in the amount of $330,493. However, because of excessive amounts of Total Phosphorus at Fairview Beach, the Service Authority was assessed a fine of $1,704 for the violation. This amount was paid a month later on April 18, 2017 as shown in the Agenda for the same date however nothing was mentioned during the General Manager's report that night or in previous meetings.
On March 15, 2017, all five WWTPs once again received NOVs. Yet again, all five were cited for a failure to communicate required information from 2015. Dahlgren and Hopyard had relatively minor violations. In addition to that, Purkins Corner WWTP in January 2017 had a reported value of 16.6 mg/L of TSS (Total Suspended Solids) where the limit is 15 mg/L. Oakland Park WWTP had 5.4 mg/L for TKN with a limit of 4.5 mg/L in January 2017. It also showed a value of 22 mg/L of Total Recoverable Copper when the limit is 20 mg/L. Fairview Beach WWTP had excess Fecal Coliform and Enterococci in January 2017. Fecal Coliform was reported at 64 n/100mLs with a limit of 14 n/100mLs and Enterococci was 104 n/100mLs with a limit of 35 n/100mLs.
The March 21, 2017 Board of Directors meeting made no reference to any violations at any of the WWTPs. However on March 24, 2017, Chris Werle reported on Facebook that several elected officials from the region toured the Dahlgren WWTP to see the upgrades that allow for "reduced effluent nitrogen and phosphorus."
On March 27, 2017, the repeating record of NOVs is again playing the same song of non-compliance. Dahlgren, Purkins Corner, Oakland Park, Hopyard Farms, and Fairview Beach WWTPs all received a Referral of Potential Violation. All reference a lack of communicating to DEQ the required documentation since November 2015.
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