Sunday, September 24, 2006


Written 9/24/06

Confusion Surrounds County Plans

A resident of a nearby subdivision along Barber Creek relayed to me a comment a neighbor had made to her recently. The comment illustrates how much confusion exists in the community about Oconee County’s plans to expand its Rocky Branch sewage plant and begin dumping treated wastewater into Barber Creek.

My friend said her neighbor argued that the County’s plans actually would be a good thing, because the water from the sewage plant would increase the volume of the stream in the summer when the creek has little water.

In fact, the County says it is unlikely to release water into the Creek during summer or other drought periods. At those times, the County says, it will have lots of customers for its "reuse quality water."

The County will be dumping water into Barber Creek when it cannot sell the water for irrigation. When the creek is full because of heavy rains, the county is going to be most in need of the permit is it seeking from the state Environmental Protection Division (EPD) to discharge treated sewage water into Barber Creek.

In sum, my friend’s neighbor misunderstands one of the prime features of the County’s proposed plans for Barber Creek.

Given the complexity of the issue, the inherent uncertainty about how a nonexistent plant actually will operate, the confusing answers given by some county officials, and the poor coverage given the issue by most of the media, such confusion is not so surprising.

Confusion surrounding the key issue of how sewage plant discharge is monitored illustrates these points. I sent Gary Dodd, director of the Oconee County Utility Department, and his assistant, Chris Thomas, an e-mail message on August 20 of this year asking what monitoring is done at the existing Calls Creek plant, and what monitoring would be done at an expanded Rocky Branch facility. The Rocky Branch facility will use the same design as is used at Calls Creek.

The next day, Mr. Thomas, who generally tries to be helpful, wrote me the following reply:

"Most of the sampling of Calls Creek is voluntary. The EPD does not require us to sample the Creek unless there is a potential problem. We sample the creek to establish base lines and to ensure that our effluent is not having any negative effects on the environment. Also, GA EPD samples creeks that receive effluent periodically. This sampling is unannounced and we seldom hear of the results. If the board (Oconee County Board of Commissioners) approves the upgrade (to the Rocky Branch plant), we will begin sampling Barber Creek in the same manner."

I told Mr. Thomas I’d like to review data the County had on Calls Creek, and he wrote me on August 22 saying he had "contacted the wastewater plant and asked them for any sampling info that they have retained. I will let you know when I get a response."

I’ve never heard any more from Mr. Thomas on the topic.

I have subsequently learned through an open records request that the EPD had 20 samples drawn from Calls Creek in 2004 as part of a state-wide study of water quality. The County’s Calls Creek plant was modified and updated in 1995 and given a permit by the EPD to discharge 0.4 million gallons per day (MGD) of water into Calls Creek. In 2004, the plant’s capacity was expanded to 0.67 MGD.

David Wenner, a water scientist in the Department of Geology at the University of Georgia and an active member of Friends of Barber Creek and of the Upper Oconee Watershed Network (UOWN), took a look at the data for 2004. Here’s David’s response:

"I looked over this data as well as that from UOWN and don't off hand see any real numbers that indicate a problem. The only ones of possible concern are some of the bacteria data. They are high on a couple of dates. Elevated values are often seen following a rain event due to storm water runoff into the creeks ( presume this is the case with these data). This is pretty normal for most streams in the area."

Kathy Methier from the EPD subsequently told me that the County is obligated to do self monitoring and to file a report to the state for each permit it has. So the County must have done this for Calls Creek as well as for the existing Land Application System (LAS) the County operates at Rocky Branch. She said this is called a Discharge Monitoring Report, or DMR.

She said, in addition, the state does independent, unannounced facility monitoring to check on the self monitoring data. This is called a Compliance Sampling Inspection, or CSI. There should be reports for Calls Creek and Rocky Branch as well.

I’ll file an open records request for access to these data shortly.

Such monitoring data are important, because plants do not always operated perfectly. James Holland, Altamaha Riverkeeper, made this observation in response to an e-mail message I sent out about the Rocky Branch plant:

"The state of Georgia is doing a lousy job at maintaining water quality discharges from industrial pipes as well as municipality discharges...Some...examples are the waste water treatment plant for Dublin and Brunswick along with most any small town that uses oxidation ponds to treat sewage."

Another person, who has inside knowledge of the operation of the EPD, said:

"The joke is that almost any kind of sewage treatment plant is permitted, there is little monitoring, there are few penalties for misconduct and in the end,... when spills occur, nobody at the EPD will shut down a plant because effluent will back up if they do that."

A story on the front page of the Metro section of The Atlanta Journal-Constitution on September 15, 2006, underscored the point. South Fulton residents complain that a sewage treatment plant in their neighborhood stinks frequently and, in the view of some, is creating a health hazard.

Unfortunately, the newspapers serving Oconee County have not explored issues of plant operation and not done a good job generally of covering the story of the proposed Rocky Branch expansion.

The Banner-Herald mostly has ignored the story. The Oconee Leader ran one very good story in its September 7 issue. The Oconee Enterprise has consistently gotten the story wrong.

The Enterprise front-page story on September 21, 2006, was clearly the worst piece of reporting on the topic. It contained the following quote from Oconee County Utility Department Director Gary Dodd about the quality of the water to be discharged from the plant:

"You wouldn’t want to drink it (the water from the proposed Rocky Branch plant) because of the implications, but we are planning dual water lines in new subdivisions that want them, ‘grey’ water suitable for lawns, washing cars and dogs and such benign uses."

Mr. Dodd and the Enterprise reporter should know quite well that the Oconee County ordinance on use of "reuse quality" water recommends against precisely the kinds of uses he was discussing. That ordinance, passed in March of 2005, stipulates that reuse water should NOT be used for the following: "drinking, food preparation, hand washing, automobile washing, or irrigation of fruits and vegetables." The ordinance, available on the county’s web site, is based on state standards for use of the water.

The state standards on use of "reuse quality" water are available on the EPD website and in the Library (5/3/06 entry) on the Friends of Barber Creek web site, www.barbercreek.org. The state documents specifically recommends against any use that brings the water in contact with the skin. The document, on page 13, gives the following guideline for use of the water:

"The customer shall not allow reclaimed water to be used for consumption (human or animal), interconnecting with another water source, sprinkling of edible crops (gardens), body contact recreation, filling of swimming pools, or sharing a common reclaimed service between properties."

The Enterprise article of September 21 also is in error about the nature of the proposed changes for the sewage plant on Rocky Branch Road. The article says that the current Land Application System (LAS) "will be expanded to treat one millions-per-day of reuse quality water." Actually, the current LAS treatment facility is going to be eliminated, and a new plant will be built, if the County gets its permit.

The County currently has a permit to dispose of 0.4 MGD of water at the existing Rocky Branch facility by spraying it on hayfields on the site. The County will retain its current ability to spray water on the hayfields. When the fields are wet due to heavy rains, however, the water will go into Barber Creek, unless some other customer wants the water. That is unlikely to be the case, of course, since these other customers also will not need irrigation water at that time.

The County has no permit to dump treated sewage water into Barber Creek at present. That, rather than the LAS, is what the permit is all about.

The Enterprise also allowed Mr. Dodd to counter argue the recommendation of the consulting firm it hired, Jordan Jones & Goulding (JJ&G), to develop a Wastewater System Master Plan for Oconee County. JJ&G, an engineering and consulting firm based in Atlanta and with offices around the country, recommended phasing out the Rocky Branch and Calls Creek plants over time in favor of a plant on the larger Middle Oconee River.

According to Mr. Dodd, as quoted in the Enterprise, JJ&G made a mistake in not knowing that the state would not grant a permit for a plant on the Middle Oconee River. Yet the County has continued to use JJ&G, most recently for permitting to draw water from the Oconee River for the planned new reservoir on Barnett Shoals Road. The Enterprise did not point out this inconsistency, or ask Mr. Dodd to explain.

There is good reason to doubt Mr. Dodd’s assertion about the EPD’s unwillingness to grant a permit for the Middle Oconee. In a meeting I had with Mr. Dodd on March 22, he claimed that the EPD would not grant a permit for the Apalachee River. Jeffrey Larson, manager of the Permitting, Compliance and Enforcement Program at EPD, wrote to me on August 18, 2006, saying that EPD "has no policy or strategy for not issuing discharge permits to the Apalachee River."

The Enterprise, which has a history of challenging authority in the County, seems to think its job in this case is to promote the County’s plans for sewage treatment rather than ask questions about them. In this way, the paper’s coverage is very close to that of Ms. Kate McDaniel who runs the web site, A Positive Vision for Oconee County. At least Ms. McDaniel does not claim she is providing objective coverage of the issue.

The issue before the county is complex. The County has promised developers sewage treatment capacity it does not have. The County also has no agreed upon plan for how to develop that capacity. It has refused to hold open discussions on the two drafts of a Wastewater System Master Plan prepared for it by JJ&G.

In other words, the County is flying in the dark. It is hardly surprising that citizens in the County are confused about what is being proposed and its consequences.

On September 16, while walking my dog along Barber Creek behind my house, he and I spotted an otter swimming upstream. It has been several years since I’ve seen otter in the creek, and I was pleased to see one again. River otters eat a variety of fish and shellfish, as well as small land mammals and birds. It suggests to me the creek still has some life in it, despite all the development in the County and the poor protection it has been given from stormwater runoff by the County.

The County’s plans for sewage treatment are a potential threat to that otter. How serious the threat is in difficult to know. What I do know is that the otter cannot ask the County and the state to discuss all the options and be clear about them. So we have to do that.

Friday, September 22, 2006

Written 9/22/06

Barber Creek Permit Request Not Likely the Last

Anyone who thinks the current request by Oconee County for a permit to dump 1 million gallons per day of treated wastewater into Barber Creek from the Rocky Branch sewage plant will be the last should read carefully the lengthy article on sewage treatment in the Sept. 21 issue of The Oconee Enterprise.

Oconee County Utility Department Director Gary Dodd is quoted as saying that the Georgia Environmental Protection Division will not give the county a permit to discharge treated water into the Middle Oconee River. So the current sewage plants, including Rocky Branch, will have to be expanded in the future.

There is good reason to doubt Mr. Dodd’s assertion. In a meeting I had with Mr. Dodd on March 22, he claimed that the EPD would not grant a permit for the Apalachee River. Jeffrey Larson, Manager of the Permitting, Compliance and Enforcement Program at EPD, wrote to many of us on August 18, 2006, that EPD "has no policy or strategy for not issuing discharge permits to the Apalachee River."

The County hired Jordan Jones & Goulding to develop a Wastewater System Master Plan. JJ&G recommended phasing out the Rocky Branch and Calls Creek plants over time in favor of a plant on the larger Middle Oconee River.

Mr. Dodd is quoted in the Enterprise as saying this recommendation is not "acceptable" because JJ&G did not take into consideration that the EPD would not grant any permits for the Middle Oconee.

OK. The Enterprise often gets things wrong. The front page headline is pretty silly: "Oconee has traveled a long path from the outhouse." Even if Dodd is misquoted in places in the article, however, the thrust of what he is quoted as saying is consistent with the County’s reluctance to take seriously the advice of its consultants.

We need a hearing on these issues. We have an extension on the deadline for writing to the EPD. We need to generate more letters so we get the hearing and can learn exactly what the EPD is willing to consider in terms of permits.

The alternative is that Rocky Branch is going to be expanded from its current 0.4 MGD of discharge into a spray field to 4.0 MGD. In January 20, 2006, Mr. Dodd informed the Oconee County Board of Commissioners that the Rocky Branch facility "can be upgraded to produce as much as 4.0 MGD of reuse quality effluent without requiring additional land or encroaching on existing buffer areas."

The likelihood is that Barber Creek is going to be targeted for much more than the 1.0 MGD covered by the current permit.

Please write immediately, and send me a note saying you did so. Write a second time if you can. Or print out the letter below and get a neighbor to sign it. Send it in yourself or fax it if necessary.

Thanks

Lee

DATE

Linda MacGregor, Branch Chief
Water Protection Branch
Georgia Department of Natural Resources
Environmental Protection Division
4220 International Parkway, Suite 101
Atlanta, GA 30354

FAX 404 675 6247

Dear Ms. MacGregor:

The Oconee County Board of Commissioners is seeking NPDES Permit No. GA0038806 for the Rocky Branch Water Reclamation Facility on Rocky Branch Road. The permit is to provide for a discharge flow of 1.0 million gallons per day of treated wastewater to Barber Creek.

In the September 21, 2006, issue of The Oconee Enterprise, Oconee County Utility Director Gary Dodd is quoted as saying the EPD will not grant Oconee County a permit for the Middle Oconee River, making it necessary to expand its existing Calls Creek and Rocky Branch facilities.

INSERT A LINE HERE ABOUT HOW BARBER CREEK AFFECTS YOU.

The Middle Oconee is much larger than Barber Creek. I ask that you hold a public hearing on the pending request so that I can voice my concerns and so that I can learn how the EPD makes its decisions about which streams can handle sewage treatment plant discharge.

Sincerely,

YOUR NAME AND ADDRESS

Wednesday, September 13, 2006

Written 9/13/06

Getting Information on County Plans Difficult

Getting information on the County’s efforts to get a permit to discharge treated wastewater from its Rocky Branch sewage treatment into Barber Creek has proven to be quite a challenge.

Back in March, the County ran two public notices in The Oconee Enterprise about a public hearing on the issue to be held March 14. Both of these notices said three documents related to the request were available for review by the public in the Utility Department office.

The second of these notices ran in the paper on the 23rd, and I went to the Utility Department office the next afternoon and asked to see the documents. The receptionist said she had never heard of these documents, was unaware of the public notices, and had no idea where the documents might be.

A few days later I got a call from Utility Department Director Gary Dodd telling me I could see the documents, but only in his and Chris Thomas’ presence. Mr. Thomas is Mr. Dodd’s assistant.

I went back to the Utility Department office on March 3 to review the documents, which, as they said, I was able to review only in their presence. I did make arrangements to copy those I needed. Some of them, it turned out, I had obtained earlier through an open records request.

On August 11, in anticipation of Georgia Environmental Protection Division (EPD) action on the Oconee County permit request, I filed an open records request in the County asking Mr. Dodd for "all files, records and other documents in your possession that refer, reflect or relate to" the county’s permit application.

I went to the courthouse on August 22 to review the documents and make copies of what was available.

Two key documents were not made available: The County’s application for the permit, which was submitted to the EPD on June 29, and the draft of the permit, which the County received from the EPD on August 14.

I e-mailed Mr. Thomas on August 28 after I had reviewed again all the materials I had received and asked him for the application. He wrote me back the next day saying he did not have a copy. He said it was sent in by the engineers (Precision Planning, Inc., of Lawrenceville), and no copy existed in the Utility Department Office. A day later he said he had an electronic copy and would make it available to me.

On September 5, I visited Mr. Thomas’ office to get the application and asked for a copy of the draft permit as well. He made a copy for me, charging me $.25 per page to make the copies, which is the County’s standard charge. (The County also charges for time employees spend in searching records at $16.02 per hour. I was billed for 6 hours and 45 minutes on August 22.)

Ironically, on September 7 the County ran another legal notice in The Enterprise announcing that the EPD is considering issuance of a permit to begin discharging treated wastewater from Rocky Branch into Barber Creek. The notice said that the permit application, draft permit and other information were available for review either in Atlanta at the EPD or at the Office of the Oconee County Board of Commissioners.

The Georgia EPD has not been very helpful either. On August 28 I wrote to Jeffrey Larson, head of the Permitting, Compliance and Enforcement Program, which is handling the Oconee County permit request, asking for a copy of the draft permit. I still have not received it.

On August 30, I called Mr. Larson’s office and left a message on his voice mail asking for a copy of the Oconee County Permit Application, for data on EPD monitoring of Calls Creek, where Oconee County has its second waste treatment plant, and for the draft permit for the Rocky Branch plant.

Stephanie Heath, Georgia Open Records Act Secretary II at the EPD, called me back later that day and left a message on my voice mail. She said she was calling on behalf of Mr. Larson. When I called her back the next morning, however, she said she would not help me obtain any of the documents I requested unless I came to the EPD offices in Atlanta. She told me she had no idea what a Permit Application even looked like.

I called Mr. Larson back shortly after talking to Ms. Heath and left another message asking him once again to call me. I informed him that Ms. Heath has been less than helpful.

Ms. Heath called me back on September 5 and informed me she would send me a copy of the Oconee County Permit Application but would not provide any additional information unless I came to Atlanta. I received the copy of the application from her a few days later.

On September 7, I filed an open records request with Mr. Larson asking for data on Calls Creek. I have heard nothing from him. By law, he is required to respond within three days of receipt of the request.

I guess my view of these documents is different from the view held by most of the officials. I know I paid for them. I think they are mine. I’m willing to be patient in reviewing them, but I feel I should be aided in doing so.

Mr. Thomas generally has gone out of his way to provide information and to answer questions. But I shouldn’t have had to ask for the Application for the Permit, which was produced in the period covered by my open records request, or for the draft permit, which arrived in the County office before my request was fulfilled.

The County should be putting these key documents on its web site so citizens can access them more easily. If the subcontractors are not providing documents in electronic format, the County should find others who will do so. The same goes for the EPD.

If the County and state officials are not willing to be second-guessed by the citizens who pay their salaries, they should find different jobs. Being second guessed goes with public service.

Monday, September 04, 2006

Written 8/30/06

Records Request Reveals Stormwater Negotiations

An open records request I filed earlier this month produced some interesting insights into the behind-the-scenes negotiations regarding the stormwater ordinance Oconee County passed on August 1.

The documents show that the state Environmental Protection Division scolded Oconee County for wanting to weaken its stormwater ordinance to satisfy developers. The County ignored that advice, however, and weakened the ordinance anyway. The EPD used the same arguments we used against the weakened ordinance. Luckily, our pressure resulted in a much stronger ordinance in the end.

Amy Morrison, stormwater/environmental coordinator for the county, indicated in a letter she wrote to the Land Use and Transportation Committee members on April 7, 2006, that she revised the ordinance originally presented to the public in September of 2005, at "the request of the BOC." BOC stands for Board of Commissioners.

The stormwater ordinance presented in 2005 applied state standards for stormwater management to the whole county; the revisions Ms. Morrison made in early 2006 greatly weakened the ordinance and restricted those standards to the already built out part of the county, labeled as "urbanized" by the EPD.

In a telephone conversation I had with Ms. Morrison on July 10, she said that she had been instructed to weaken the ordinance by her boss, Mike Leonas, the public works director. She said she was told by Mr. Leonas that the change was at the request of Melvin Davis, chairman of the BOC.

At the public hearing in October of 2005, no one asked that the stormwater ordinance be weakened. Ms. Morrison said in our telephone conversation, however, that the development community did not want the original stormwater ordinance because it would force builders to spend more money.

Shortly after I spoke with Ms. Morrison on July 10, I telephoned Mr. Leonas, and he confirmed that he had asked Ms. Morrison to make the changes in the original ordinance. He said Mr. Davis told him in a conversation some time after the public hearing on October 24, 2005, to change the ordinance. Mr. Leonas said he remembered that there had been an email message following the verbal request from Mr. Davis.

The open records request shows that Alan Theriault, administrative officer of the county, who, like Ms. Morrison and Mr. Leonas, works for Mr. Davis, sent an email message to Ms. Morrison on November 15, 2005, instructing her to make the changes in the ordinance. It was copied to Mr. Davis and Mr. Leonas.

In that message, Mr. Theriault said: "(Y)ou will begin the process of combining the 3 separate ordinance into a single document that pertains to the urbanized areas of the County only (italics in original)." Ms. Morrison also was told to proceed with a change in the original Notice of Intent that the county had filed with the EPD regarding the stormwater ordinance.

Lisa Perrett, environmental specialist at EPD, wrote to Mr. Davis on November 28, 2005, stating her displeasure with the change requested by Ms. Morrison. "EPD is greatly concerned with the proposed approach," she wrote.

Ms. Perrett said Oconee County, if it did not apply the state standards countywide, "may be allowing potentially inferior stormwater control measures to be utilized." She pointed out that the definition of the urbanized area of the county was based on the 2000 Census and that "the County has recently been experiencing a tremendous amount of growth." She continued: "(T)he majority of the currently defined urban area is already developed."

In sum, Ms. Perrett made all the same arguments with Mr. Davis that citizens did. Unfortunately, we didn’t know the letter existed until now.

The Perrett letter, in its entirety, is in the "library" on the web site of Friends of Barber Creek, www.barbercreek.org.

Lee
Written 9/4/06

Rocky Branch to Treat Industrial Waste

We still need letters sent to the state Environment Protection Division if we are going to get a public hearing on the County’s request to begin dumping treated wastewater from the Rocky Branch Waste Treatment Plant into Barber Creek.

Here’s another reason to want that hearing: The Rocky Branch Waste Treatment Plant will treat INDUSTRIAL waste as well as residential waste.

In July the pharmaceutical company Novartis announced that it was bypassing Georgia and building its influenza vaccine plant in North Carolina instead.

The Georgia location that Novartis was considering was at Georgia Highway 316 and U.S. Highway 78. The land is referred to as the Orkin Tract. It lies in Oconee and Clarke Counties.

The Rocky Branch Waste Treatment Plant in Oconee County would have treated the waste from Novartis had it located here. The treated water would have gone into Barber Creek. The County has said it will seek other pharmaceuticals for the site.

During the speculation before Novartis announced its decision, I started an email exchange with Chris Thomas in the Oconee County Utility Department about special procedures that would be in place to protect citizens who live along Barber Creek should a vaccine manufacturer locate at the Orkin Tract.

That exchange is posted on the Friends of Barber Creek web site, in the library. The exact URL is http://www.barbercreek.org./barbercreek/library.html. The item was posted on 7/15/06. You can see for yourself what would happen.

Clearly, some safeguards are in place. But they depend on a lot of monitoring, which we need to insist is in place should the EPD grant a permit to Oconee County. Here’s a summary of what Mr. Thomas said.

First, the federal Environmental Protection Agency requires pharmaceuticals to pretreat their waste before discharging into sewer systems.

Second, the County also sets limits on what can be put into its sewage system, Mr. Thomas said.

Third, the plants can "handle higher loadings than their influent flows would normally bring." In other words, the plant should be able to handle the inflow even if it didn’t meet the pretreatment standards.

Finally, Mr. Thomas wrote, "These safeguards along with stringent effluent monitoring and
limits at the wastewater plants insure consistently safe discharges into streams and rivers as required under the rules of NPDES permitting."

NPDES refers to the National Pollution Discharge Elimination System, the permit program that requires all those discharging pollutants into waters of the United States to obtain a permit.

Mr. Thomas subsequently explained that Oconee County’s pretreatment limits "mimic" the federal standards, and, in fact, at present the Georgia Environmental Protection Division "regulates all significant industrial users for the County due to our small number of users...Oconee is in the process of implementing it's own pretreatment program, but it will be some time before we complete all of the requirements necessary."

Mr. Thomas also said "I may have been confusing when I referred to the stringent monitoring of the plants effluent. Although all treatment plants are closely monitored to ensure protection of the environment and public health, I was referring to the reuse limits. Reuse limits are more stringent than most plants in the state operate under."

In other words, the plant will be following state standards for production of "reuse" quality water.

How closely this is going to be monitored is something that we all should be concerned about, particularly if the Orkin Tract is developed as planned. The state has made it clear it would love to have another company such as Novartis locate here.

This is the kind of question we can pose at a public hearing on the Oconee County permit request if the EPD grants us a hearing. But we have to write and ask. Here is a draft letter:

DATE

Linda MacGregor, Branch Chief
Water Protection Branch
Georgia Department of Natural Resources
Environmental Protection Division
4220 International Parkway, Suite 101Atlanta, GA 30354

Dear Ms. MacGregor:

The Oconee County Board of Commissioners is seeking NPDES Permit No. GA0038806 for the Rocky Branch Water Reclamation Facility on Rocky Branch Road. The permit is to provide for a discharge flow of 1.0 million gallons per day of treated wastewater to Barber Creek.

TELL HOW BARBER CREEK AFFECTS YOU AND YOUR PROPERTY.

I am aware that the state and local officials have tried to get a major pharmaceutical manufacturer to locate at the Orkin Tract in the county in the past and have said they will continue to do so. I also know that the Rocky Branch facility would be the treatment plant for effluent from the manufacturer.

I ask that you hold a public hearing on this request so that I can learn about state standards on pretreatment of industrial waste and monitoring procedures that will guarantee the safety of the water flowing into Barber Creek, should you grant a permit to Oconee County.

Sincerely,

YOUR NAME AND ADDRESS

Please let me know when you write. I am keeping a tally.

Thanks

Lee
Written 8/21/06

Rocky Branch Request Up For Review

The Oconee County request to be allowed to dump 1.0 Million Gallons Per Day of treated wastewater from an expanded Rocky Branch Waste Treatment Plant into Barber Creek is now up for review before the state Environment Protection Division.

Please write to the EPD and ask for a hearing. Reference Permit No. GA0038806. Here is the address:

Linda MacGregor, Branch Chief
Water Protection Branch
Georgia Department of Natural Resources
Environmental Protection Division
4220 International Parkway, Suite 101Atlanta, GA 30354

Tell the EPD how important the stream is to you. Contrast what you do with the creek with the following advise on use of reuse quality water, which is what will be dumped into the creek if the permit is granted.

Reuse water should not be allowed into dwelling units, should not be used for swimming, should not be used on edible crops, and should not be used to wash a car. Persons should limit body contact with the water.

You also can mention the following:

Experts from the firm of Jordan, Jones & Goulding, in a draft report presented to Oconee County in March of 2004, stated on Page 3-5:

"For Oconee County the surface streams with large enough flows to receive treated discharges are considered to be the Apalachee, Middle Oconee, and Oconee Rivers. The other streams, such as Barber Creek and Calls Creek, are considered to be too small to receive a substantial quantity of treated flow."

Remember, there is an alternative. The JJ&G experts told the county to phase out this plant and to build a new one on the Oconee River. That has never been openly discussed.

Lee

DATE
Linda MacGregor, Branch Chief
Water Protection Branch
Georgia Department of Natural Resources
Environmental Protection Division
4220 International Parkway, Suite 101Atlanta, GA 30354

Dear Ms. MacGregor:

The Oconee County Board of Commissioners is seeking NPDES Permit No. GA0038806 for the Rocky Branch Water Reclamation Facility on Rocky Branch Road. The permit is to provide for a discharge flow of 1.0 million gallons per day of treated wastewater to Barber Creek.

TELL HOW BARBER CREEK AFFECTS YOU AND YOUR PROPERTY.

I ask that you hold a public hearing on this request so that I can voice my concerns and so that I can learn what steps the EPD and Oconee County are going to take to protect my interests should such a permit be issued.

Sincerely,

YOUR NAME AND ADDRESS

Friday, September 01, 2006

Written 8/29/06

Barrow Granted Permit for Barber Creek Discharge

The Georgia Department of Natural Resources has issued a permit to Barrow County to allow it to begin dumping treated sewage water into Barber Creek.

The permit is initially for 0.5 million gallons per day of wastewater; it will go to 1.5 MGD when the plant is fully built.

The issuance of a permit is not a surprise. It is quite clear now that the Environmental Protection Division has signaled to both Barrow and Oconee counties its receptivity to permit requests to dump sewage water into Barber Creek. Oconee County has a permit request pending.

It is crucial that we force a public hearing on the Oconee County request so we can keep pressure on the state and on Oconee County officials to consider all the options before adding more treated sewage water to Barber Creek.

Here’s a draft letter:

DATE
Linda MacGregor, Branch Chief
Water Protection Branch
Georgia Department of Natural Resources
Environmental Protection Division
4220 International Parkway, Suite 101Atlanta, GA 30354

Dear Ms. MacGregor:

The Oconee County Board of Commissioners is seeking NPDES Permit No. GA0038806 for the Rocky Branch Water Reclamation Facility on Rocky Branch Road. The permit is to provide for a discharge flow of 1.0 million gallons per day of treated wastewater to Barber Creek.
On August 18, 2006, your office issued a permit to Barrow County allowing it to discharge 1.5 MGD of wastewater into Barber Creek. These two plants are only a short distance from each other.

TELL HOW BARBER CREEK AFFECTS YOU AND YOUR PROPERTY.

I ask that you hold a public hearing on the Oconee County request so that I can voice my concerns and learn more about the application in light of your decision to issue a permit to Barrow County.

Sincerely,