Hello,
If you have additional questions about the issues with this permit, please
don't hesitate to contact me to discuss it. Thanks.
Steve Veysey
Conservation Co-chair
515-232-4635 (home)
515-294-5805 (work)
At 02:53 PM 2/5/2007, you wrote:
>Story County members may be interested in this message from the Iowa
>Environmental Council. The hearing is this Thursday at 7 p.m. at the
>Story City City Hall Council Chambers.
>
>
>
>PUBLIC HEARING
>
>Story City Wastewater Discharge Permit
>
>7:00 pm, Thursday Feb. 8, 2007
>
>
>
>The Iowa Environmental Council provided comments to DNR on the draft NPDES
>permit for the City of Cedar Rapids Wastewater treatment plant in a letter
>dated November 20, 2006. As part of our comments we requested that DNR
>hold a public hearing to discuss this permit. The hearing is scheduled
>for 7:00 pm on Thursday February 8th at the Story City, City Hall, 504
>Broad Street, in the Council Chambers.
>
>
>The South Skunk River in Story County is designated for primary contact
>recreation (class A1) and significant resource warm water (class
>B(WW-1)). The segment of the South Skunk River that receives the Story
>City discharge is also listed on Iowa's 2004 Impaired Waters List or the
>303(d) list as impaired by bacteria. The proposed permit includes a
>compliance schedule for preparation and testing of the plant's existing UV
>disinfection equipment and the fecal coliform bacteria limits in the
>permit must be met by the beginning of the 2007 recreation season on March
>15, 2007.
>
>The Council supports this compliance schedule and is glad to see that the
>fecal bacteria contamination from the Story City wastewater will no longer
>be allowed to contribute to the impairment of recreation uses in the South
>Skunk River. However, the Council has serious concerns about the proposed
>increased limits in the permit for biochemical oxygen demand and ammonia
>and the impact these increase may have on the aquatic life in the South
>Skunk River.
>
>
>
>Following is a summary of our major concerns with the permit:
>
>1. The proposed permit would allow substantial increases
>in permit limits without complying with antidegradation or
>anti-backsliding requirements of the Clean Water Act. Increases in the
>biochemical oxygen demand may lower the amount of oxygen in the water that
>fish and other aquatic life need to survive and increases in ammonia could
>be toxic to sensitive aquatic life downstream of the discharge. These
>increases are proposed without explanation as to why they are necessary or
>whether alternatives are available. The proposed effluent limits would
>allow the City of Story City to more then triple their daily maximum
>ammonia discharge for the months of March through December and nearly
>double allowable ammonia discharge in January and February. The 30-day
>average limit for Carbonaceous Biolochemical Oxygen Demand (CBOD) for July
>and August is proposed to be increased from 13 parts per million to 20
>parts per million. Ammonia is toxic to many species of aquatic life and
>is particularly toxic to freshwater mussels. In fact, the U.S
>Environmental Protection Agency is currently re-evaluating its ammonia
>criteria because new research shows that the existing criteria are not
>protective of mussels.1
>
>2. The DNR must ensure that the Story City permit
>protects mussels and other aquatic life in the South Skunk River
>downstream of the discharge. The South Skunk River and other rivers in
>Iowa once supported a healthy population of freshwater mussels, but recent
>surveys have shown that mussel populations in Iowa rivers are in serious
>decline. As noted on the DNR website "A dozen of the 50 or more known
>mussel species are gone; extirpated from Iowa waters. Another 15 are on
>the endangered or threatened species lists. The rest are not far
>behind."2 State and federal agencies and concerned citizens are taking
>urgent measures to document and protect any remaining species in Iowa
>rivers such as the South Skunk River before they disappear.3 Locally, the
>"Skunk River Navy," comprised of ISU students and faculty, regularly
>conduct water quality assessments and monitor populations of freshwater
>mussels in the Skunk River.4
>
>3. DNR must improve their permit process to adequately
>account for uncertainties and a margin of safety and to prevent further
>degradation of water quality. The DNR's policy appears to be that the
>most defensible permits are those that calculate the maximum quantity of
>pollutants and toxics that could theoretically be discharged, with no
>margin of safety. This approach ignores important factors or
>uncertainties that could lead to acute and chronic toxicity in the South
>Skunk River and does not take into consideration protection of sensitive
>species such as freshwater mussels. The DNR is currently working with the
>Council to improve the antidegradation rules and implementation
>procedure. These rules are currently scheduled to be finalized in January
>to March of 2008. The Council appreciates DNRs efforts to correct these
>procedures, however, we are not prepared to stand by and allow clearly
>deficient permits such as the Story City permit to go into effect before
>Iowa's program is fixed.
>
>
>References:
>1 U.S. EPA Ammonia Criteria Re-evaluation
><http://www.epa.gov/waterscience/criteria/ammonia>http://www.epa.gov/waterscience/criteria/ammonia
>
>2 Joe Wilkinson, Search for Endangered Mussels (Sept. 26, 2006
><http://www.iowadnr.com/news/06sep/mussels.html>http://www.iowadnr.com/news/06sep/mussels.html
>
>3 U.S. Fish and Wildlife Service
><http://www.fws.gov/midwest/mussel/index.html>http://www.fws.gov/midwest/mussel/index.html
>
>4 Skunk River Navy
><http://www.las.iastate.edu/newnews/skunkriver0925.shtml>http://www.las.iastate.edu/newnews/skunkriver0925.shtml
>
>From: <mailto:[log in to unmask]>Susan Heathcote
>Sent: Monday, February 05, 2007 2:33 PM
>Subject: Story City Public Hearing
>
>Attached is a fact sheet on the Story City permit hearing scheduled for
>this Thursday evening Feb. 8th at 7:00 pm. The hearing will be held in
>the Story City, City Hall, in the Council Chamber. Please spread the word
>to others who you think would be interested in attending.
>
>*Please note new email address below*
>After Dec. 1st, email will no longer be forwarded from my old
>earthweshare.org address
>
>Susan Heathcote
>Water Program Director
>Iowa Environmental Council
>711 East Locust St.
>Des Moines, IA 50309
>phone: 515/244-1194 ext. 12
>fax: 515/244-7856
><mailto:[log in to unmask]>[log in to unmask]
>http://www.iaenvironment.org
>
>
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