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Pollutant Discharge Elimination System (VPDES) Permit No. VA0077402 by Rocco
Farm Foods and Mountain View Rendering Company,
19992 Senedo Road, Edinburg, VA 22824
Public Hearing , November 5, 1998, Woodstock, VA
Robert Arner, Director, Shenandoah County Lord Fairfax Soil and Water District
For the last three years, as a Director on the Shenandoah County Lord Fairfax Soil and
Water District, I have observed unacceptable levels of nutrient degradation by
Rocco Farms, and Mountain View Rendering Company. This has directly polluted the local watershed, Stoney Creek. Information from numerous water quality data sources, i.e. the Department of Environmental Quality and the United States Environmental Protection Agency provides overwhelming evidence to support this conclusion.
Presently, Mountain View Rendering Company is seeking permit modifications to allow a
20 percent increase in operating hours and a 65 percent increase in the amount of raw material it processes (blood, feathers and offal).
I request a full environmental audit of the operation of these facilities, their testing procedures, permits and history of regulatory compliance so as to provide the basis for this proposed increase in operational hours and this proposed increase in raw material processed.
Also, it is my personal view that the Special Use Permit1 granted by this County is currently in violation since this agreement is predicated that the water quality of Stoney Creek be protected, and the contrary has occurred (Attachment A).
Under 680-14-02 - Policy for Nutrient Enriched Waters, adopted by the Virginia State Water
Quality Board in 1988 (Attachment B), clearly defined are both total nitrogen and total phosphorous concentration levels. In Section ß 3 the definition states that ìnutrient enriched watersî shall be required to meet monthly average total phosphorous effluent limitation of 2mg/l as quickly as possible in any event within three years following the modification of the NPDES permit. Section ß 4 further states that ìthe board may reopen the NPDES permit to impose monitoring requirements in the discharge.î I question why this hearing is to be held before the November
17th hearing designating Stoney Creek as a Nutrient Enriched Water, especially since Rocco Farms is cited as the only point source discharge impacted by this regulatory designation.
A May 1998 study on Rocco Farms conducted by Cliff Randell of Virginia Tech2 for EPA and DEQ (Attachment C) states,
ìThe effluent nitrogen concentration of 128 mg/L was the highest of any WWTP in the
Shenandoah Valley, and the total daily nitrogen discharge of 1174 lbs/d was one of the highest loads discharged. The effluent phosphorus concentration and load of 146 mg/L and 1339 lbs/d, respectively were even higher. The nitrogen and phosphorous annual loads discharged were
428,609 and 488,735 lbs, respectively.
A DEQ memo of September 8, 1997 to Tom Hopkins from Brad Chewning indicated that the entire watershed of Stoney Creek qualifies it for regulatory designation as nutrient enriched waters (Attachment D).
Finally, a July 29, 1998 letter to Bill Kregloe from Jeffrey Rein of the Maryland Department of the Environment (Attachment E) indicated that the Rocco facility discharges three times the nitrogen and twice the phosphorus of a similarly sized municipal plant.
Regarding Nutrient Reduction Strategies, Virginians will spend hundreds of millions of dollars on preventing nutrient pollution impacting our natural resources . In Shenandoah County, we will spend millions of dollars in water quality improvement funds to reduce non point nutrient pollution. Shenandoah Countyís 1994 reported value for non point nutrient loads; nitrogen was 403,000 pounds and phosphorus was 62,000 pounds, our proposed total nutrient loads regional strategy was to reduce nitrogen by 214,000 pounds, -64% and phosphorus by 37,000, -60%.3
Shenandoah County developed a plan to achieve 29% reduction of nitrogen and 40% of phosphorous by the year 20004. Rocco Farm reported in 1994, 206,000 pounds of nitrogen and 26,000 pounds of phosphorus and the exact same number for our regional strategy. In 1994, Shenandoah reported Total Nutrient Loads of 700,000 pounds of nitrogen and 106,000 pounds of phosphorus. As you see the numbers do not add up. Remember the May 1998 Virginia Tech study for DEQ and EPA of Rocco Farm indicated the nitrogen and phosphorus annual load discharge for Rocco were 428, 609 and 488, 735 pounds, respectively.
From a regulatory perspective, interviews with regulators indicate at least five years before nutrient control regulations for this processing facility will be enacted by state and federal officials and another several years for this industry to have to comply with these requirements. We may be talking seven-ten years for this sector to help us attempt a 40% nutrient load reduction to the Chesapeake that we have to meet in 2000.
How can we allow this major point source water contributor, Rocco Farms Foods and Mountain View Rendering Company continue to degrade Stoney Creek and continue their high levels nutrients discharge ? The citizens of Shenandoah County should not have to bear this tremendous economic burden. Some type of major pollution prevention or control technologies for these facilities are critical to protect the public health and preserve our environment.
(1) 11/14/88 Letter to Mt. View Rendering Co. from Vince Poling , Shenandoah Co. approving for a Special Use Permit , pg 2. The water quality of Stoney Creek shall not be degraded due to the operation of the rendering plant. Wastewater treatment shall meet or exceed all standards prescribed by the State
Water Quality Board. Wastewater discharge into the Stoney Creek shall be clear.
(2) Preliminary Assessment of the Rocco Farm Foods Wastewater Treatment Plant, Edinburg, Va, for Biological Nutrient Removal submitted to USEPA Chesapeake Bay Office and VADEQ, May, 1998 pg. 3
(3) Shenandoah and Potomac River Basin Tributary Reduction Strategy, December 1996, pg 47
4 Ibid. pg, 41, 46