The Case for the Rush

by Friends of the Rush Steering Group for Friends of the Rush, March 15, 2006

Concerned riparian landowners living downstream from the Town of Washington came together last month to question Town plans to discharge treated sewage effluent directly into the Rush River. Joined by more than fifty citizens across the county, Friends of the Rush have doubts about whether the Town’s expensive plans, long in the making but only recently clear to many outside the Town, represent the best solution for County and Town residents, for County water resources, and for the health of Chesapeake Bay.

The Virginia Department of Environmental Quality (DEQ) has issued a Draft Permit that would allow the Town to discharge treated sewage wastewater from a proposed sewage treatment plant into the Rush River at the rate of up to 60,000 gallons per day, even though the Rush is sometimes reduced to zero flow during dry periods. According to the Draft Permit, the effluent would be allowed to contain reduced levels of dissolved oxygen, elevated levels of nitrogen and phosphorous nutrients, and levels of fecal coliform bacteria an order of magnitude above what is easily achieved with today’s technology. Nutrient pollution from the Rush River discharge could be offset through the purchase of credits from treatment plants operating outside of Rappahannock County or by nutrient remediation anywhere in the Rappahannock River watershed. The permit does not regulate levels of most toxic compounds, including organic and inorganic chemicals, heavy metals, pesticides, herbicides, carcinogens, and pharmaceuticals.

There will be a public hearing on the draft DEQ Permit on March 28 in the Rappahannock County High School auditorium. Attendees will have an opportunity to ask questions of DEQ officials at a 6:30 p.m. question and answer session at the start of the meeting and will be allowed to comment for the record during the official hearing, immediately following.

Unresolved concerns expressed to date by various participants in two Friends of the Rush public meetings, recent Town Council and County Board of Supervisors meetings, and at several meetings of the Friends of the Rush Steering Committee include the following:

Septic system problems on private property in the Town of Washington are inadequately understood and insufficiently defined. Through the Health Department in 1997, the Town conducted a question and answer survey of 87 property owners/residents that resulted in 27 properties reporting one or more observations that could be interpreted as symptomatic of septic system problems. The Town made no attempt, however, to conduct, with the help of the Health Department or engineering consultants, a detailed inspection/evaluation study of each property to confirm the existence and precise nature of problems. So there is no conclusive determination of how many homeowners have septic system defects and how many of those defects could be fixed with low-cost, on-site repairs, including pumping septic tanks, replacing broken pipes and cracked tanks, etc. The Town has been unable to provide rigorous data to support the conclusion that a centralized sewage treatment plant is required.

The Town’s revised Comprehensive Plan will provide for a 33 percent increase in the number of residences over the next 20 years (34 new homes). Is this level of growth necessary or desired? Every new home for the Town increases the need for a centralized sewage treatment facility and disposal of treated sewage effluent into the Rush River. And under the current plan, every new home increases the volume of effluent that must be absorbed by the Rush. How much growth is too much?

The average current daily water use for the entire Town is 35,000 gallons. The all-time peak daily use is 42,000 gallons. Does the Town need a sewage plant that will treat 60,000 gallons per day? The Town is inviting growth to fill out the capacity of a larger-than-necessary treatment plant.

The Town seriously examined just one of many possible alternatives to discharging treated sewage effluent into the Rush River. The alternative plan would have distributed treated effluent into a large underground drain field, but was eventually abandoned. Properties available to the Town for this purpose had the capacity, according to studies commissioned by the Town, to handle 55,000 to 65,000 gallons per day, with an equally large (100 percent) reserve capacity. With the discharge of treated sewage effluent into the Rush the only option currently on the table, downstream riparian landowners worry that decisions by the Town will transfer some of the burdens of pollution to them in the form of degraded stream quality, health risks, and reduced property values.

Some progressive small communities around the country have opted for disposing of sewage in innovative ways that do not require discharge to streams and rivers. Common areas or country fields can be irrigated, green houses watered, gardens planted, or wetland parks created. None require stream discharge and none create unpleasant odors or health risks.

According to the Town’s consultant, the initial capital costs of the proposed sewage treatment and disposal solution have reached $4 million, even before DEQ has finalized pollution standards for the Permit and before the plant has been designed. This does not include ongoing operation and maintenance, or the costs of possible expansion or upgrades of the plant if the Town grows beyond the current 20-year plan or if (more likely when) DEQ requires more stringent control of pollution in the future. It is going to be expensive for Town residents to hook up to the new sewage disposal system, and most, if not all, will be required to do so. Sewer hook-up charges for small communities can be in the neighborhood of $20,000 per household.

How will the Rush be impacted by the discharge of treated sewage effluent into the river? Will coliform bacteria from the effluent endanger recreational users of the Rush? Will lower levels of dissolved oxygen endanger aquatic life? Will added nutrients increase the already high levels of destructive algae growth in our streams, and add to the difficulties of the Chesapeake? What impact will a host of other toxic pollutants have on stream health and aquatic life? What will be the effects of altered flow regimes and elevated water temperatures on Rush ecosystems?

DEQ periodically tests water quality in the Rush. In some of those tests, the Rush was found to be impaired by the presence of fecal coliform bacteria in a section of the river from about two miles above Washington to just below the Town. There is no data demonstrating that failing septic systems in the Town are contaminating the river. The most likely source of this periodic contamination is from non-point sources (farm animals) above the Town. There is hope that those sources of pollution will be identified and contained through Best Management Practices of our land. Any failing septic systems in the Town also need to be addressed. But if a sewage treatment plant that discharges into the Rush is installed at Washington, the Rush could be forever impaired. Once the river discharge of treated wastewater begins, there is no going back.

Until the formation of Friends of the Rush, the County Board of Supervisors took virtually no role with regard to the Town’s sewage disposal plans. Although the proposed sewage treatment plant will be on Town land, the outflow will be piped on a VDOT right-of-way to the Rush River, outside of the Town and in the County. For obvious health, safety, recreation, and environmental reasons, many citizens across the County view any new waste discharge into a County stream as a County issue. At its February 6 meeting, in response to an outpouring of citizen concern, the Board of Supervisors decided to engage a consultant to examine the draft DEQ Permit for discharge of wastewater into the Rush. The consultant’s report is due before the March 28 DEQ permit hearing. So far, there is no indication that the County Board of Supervisors will become involved in a more significant way on behalf of citizens.

Everyone with a stake in Rush River water quality and everyone who loves our beautiful rivers should plan on attending (and speaking at) the DEQ wastewater discharge permit hearing on March 28. According to DEQ official Tom Faha, the purpose of the DEQ permitting process is to give localities permission to pollute streams. Isn’t there a better way in Rappahannock County?

©Times Community Newspapers 2006. With permission.