1. Alan Pollock VA DEQ, Office of Water Programs Alan.pollock@deq.virginia.gov804-698-4002 Water Quality Planning Regulation Unused Allocations in Shenandoah- Potomac River Basin: RAP Meeting November 4, 2009 DEQ – Northern Regional Office

2. Recent Actions by SWCB Increased WLAs for Merck for both total nitrogen and total phosphorus Considering increase to WLA for total nitrogen for FCW&SA-Vint Hill; currently in rulemaking process Objective: Under Watershed General Permit effective January 1, 2007, need to maintain total WLA cap for significant dischargers within Shen/Potomac basin

3. Potential Candidates for Unused Nutrient Allocations Requested Information on: 1. Timeframe for using WLAs 2. Impact if all or part of WLA used as offset higher WLAs 3. Know of any other facilities that appear to have unused WLAs

4. J.P Salyards [formerly Pilgrims Pride – Alma] Existing WLA: TN = 18,273 lbs/yr TP = 914 lbs/yr Basis for WLA – poultry processing plant Candidate for Unused WLA – original facility is inactive; no specific application for new operation needing nutrient WLA

5. J.P Salyards Summary of Response Timeframe – –No specific timeframe – –Currently marketing WLAs to others Impact on Facility – –Devastating without compensation – –Impact on market value of Alma plant w/o assigned WLAs is very significant – –SWCB taking WLAs without compensation is contrary to State law Owner Comments?

6. Shenandoah County North Fork Regional Existing WLA: TN = 9,137 lbs/yr TP = 685 lbs/yr Basis for WLA – Regional facility Candidate for Unused WLA – basis for original WLA no longer appears applicable; former industrial facility with no collection system; being used to treat leachate and septage

7. Shen. Co. North Fork Regional Summary of Response Timeframe – –No specific timeframe; nor how much of the WLAs the system will need – –Facility to provide multiple waste stream source treatment – –Designing septage acceptance facility and force main for County – –New owner of Aileen site has not finalized plans Impact on Facility – –Nothing specific mentioned Owner Comments?

8. Town of Leesburg Existing WLA: TN = 121,822 lbs/yr TP = 9,137 lbs/yr Basis for WLA – Design capacity = 10 MGD [Note: former VA-SNR agreed to 10 MGD as basis for WLA] Candidate for Unused WLA – existing facility has a design capacity of 7.5 MGD; while WLA is not footnoted, do not expect expansion until after December 31, 2010

9. Town of Leesburg Summary of Response Timeframe – –Using WLA now as part of long term Plan to provide for compliance after December 2010 – –Expect to begin design for upgrade/expansion in 2015 Impact on Facility – –Short term: increase costs due to accelerating upgrade to ENR, and need to purchase credits – –Long term: additional debt service and increases O&M Owner Comments?

10. Upper Occoquan Service Authority Existing WLA: TN = 1,315,682 lbs/yr TP = 16,446 lbs/yr Basis for WLA – Need for nitrate discharge to protect Occoquan Reservoir drinking water source; WLA based on TN = 8 mg/l instead of 3 mg/l; about equal to existing TN discharge load Candidate for Unused WLA – recent data indicates nitrogen load below WLA; DEQ unaware of negative impacts to reservoir

11. UOSA Summary of Response Timeframe – –Studies show that reduced TN discharge in 2007/08 created nitrate deficiencies in reservoir, leading to release of significant amounts of ammonia and phosphorus from sediments – –Will reach TN cap between 2012-14; design process begun for new treatment facilities to meet/maintain WLAs Impact on Facility – –Negative water quality impacts – –Negative impacts on current design and long term planning – –Jeopardize meeting WLA in future years Owner Comments?

12. Town of Round Hill Existing WLA: TN = 9,137 lbs/yr TP = 685 lbs/yr Basis for WLA – Design capacity = 0.75 MGD Candidate for Unused WLA – existing facility has a design capacity of 0.5 MGD; while WLA is not footnoted, do not expect expansion until after December 31, 2010

13. Town of Round Hill Summary of Response Timeframe – –Plan to have upgraded/expanded plant on line by December 31, 2010 – –Under consent decree with developer to provide wastewater treatment capacity Impact on Facility – –Could not meet limits or fund the facilities Owner Comments?