In the last Mayor’s Corner of 2020, I shared what I perceived to be a positive report, regarding a pathway to DEP Compliance at the Town’s waste-water treatment facility. The good news was the State Division of Environmental Protection had accepted the Town’s third revised Plan-Of-Corrective-Action. The Agency’s acceptance of the Town’s plan is agreement that our engineers have us on the pathway to compliance. As if that process is not costly enough, now I have been informed the DEP assessed administrative penalty has been increased – by more than $50,000. Because of permit violations, $179,580 seems necessary to DEP.
I have previously shared the following information and how we got here. But in light of this new increase in fine, I want all to understand what is at the root of the Town’s recent sewer rate increase and the on-going evaluation of the entire sewage collection and treatment system.
To summarize, the Marlinton sewer system, (with just over 19 miles of collection lines) has historically been subject to significant amounts of inflow and infiltration (groundwater). In the simplest of terms – too much clean water finds its way into our collection system.
The Town’s National Polluant Discharge Elimination System (NPDES) permit allows for 200,000 gpd discharge. Over the past 10 years, total sewer flows have averaged 244,000 gpd, while customer sewage production (based on customer water purchases) averaged 66,000 gpd during that same period. That makes for a simple calculation of 73% I/I.
The large quantity of I/I has made meeting the 85% reduction requirements impossible, with average reductions of 80% of influent BODs and 67% of influent total suspended solids (TSS) being achieved over the past 23 months; the compliance rates over the past 10 years have been similar. A summary of the treatment facility’s performance over the past 24 months was included in response. Compounding the situation, the large quantity of I/I has contributed to discharges from the Combined Sewer Overflow.
One fact is for sure. Every dollar spent paying on a fine is a dollar unavailable to spend correcting the actual problem.