Just before the holidays, Potomac Riverkeeper Network submitted formal comments to Virginia’s Department of Environmental Quality regarding the City of Alexandria’s effort to address untreated sewage pollution emanating from its antiquated “Combined Sewer System” into the Potomac River and nearby tributaries. PRKN is calling on Virginia DEQ to hold a public hearing and invite formal public comment on Alexandria’s illegal and inadequate plan, which fails to address a discharge point near Old Town which dumps about 70 million gallons of raw sewage and polluted stormwater into the river each year.
PRKN’s review of water quality testing done by Alexandria in Oronoco Bay, the location of this dumping into the Potomac, reveals that 51% of the City’s samples showed fecal bacteria at unsafe levels in the river, rendering the Potomac frequently unsafe for human contact.
“The citizens of Alexandria know dumping millions of gallons of raw sewage into the Potomac — a source of drinking water for millions of people — is wrong. Alexandria’s political leadership has proposed pushing this problem off for the next generation to deal with. It’s unacceptable — the health of our nation’s river is something we take very seriously," says Potomac Riverkeeper Dean Naujoks. “Clean water is a fundamental right for our children. Our high school crew teams and communities down river should be able to enjoy the river without risk of swimming in raw sewage.”
The levels of E. coli in the river violated Virginia state water quality standards in place to ensure that people recreating in state waters would not become ill from exposure to high levels of bacteria. The City’s sampling was done from 2007-2012, then discontinued. Since Alexandria has not taken concrete steps to address this pollution, it is highly likely that the same level of pollution and resulting public health risk continues today. PRKN opposes the current plan, and is calling on Virginia DEQ to reject the city’s plan, and require a comprehensive solution to Alexandria’s sewage pollution problem that minimizes or eliminates all dumping of untreated sewage by 2027.
“Virginia environmental regulators have a duty to enforce state and federal law, to protect the public from harmful fecal bacteria and stop dumping of untreated sewage into the Potomac,” said Phillip Musegaas, Vice President of Programs and Litigation at PRKN. “We fully expect DEQ to do its job and compel Alexandria to clean up its sewage mess once and for all, but we are ready to fight if the state doesn’t stand up for clean water.”
PRKN’s formal comments are supported by an independent consultant’s report, which includes the following key conclusions:
- Recent rainfall data shows that the proposed storage tunnels for capturing sewage before it’s dumped to Hunting Creek, a Potomac tributary, are too small to reduce sewage discharges to the maximum allowed of 4 per year – the city’s own analysis indicates at least 10 CSO events per year due to storm events with greater than 1.0 inch of rainfall. This would violate EPA’s national guidance for reducing sewage pollution to comply with the Clean Water Act.
- The 3 million gallon storage tank proposed for a third discharge point suffers from a similar deficiency. Based on the same rainfall data, the tank would not be effective in limiting CSO discharges to 4 per year – the analysis shows that at least 10 CSO events would continue to occur, based on rain events of more than 1.1 inches. This would also violate federal law.
- Alexandria’s insistence on using 1984 as the typical rainfall year for determining the frequency of future sewage discharges is inadequate and misleading, because it fails to account for the larger size and duration of storms during more recent years (1994-2013), thereby deliberately underestimating the number of untreated sewage discharges that will continue to occur once the storage tunnels and tanks have been completed.
- Alexandria’s proposal to stage the construction of the storage tank and tunnel over 19 years is completely unreasonable, and will fail to achieve any meaningful reduction in sewage pollution in the near future. For example, the construction of the storage tunnel for Outfalls 003-004 extends over 9 years, to build a tunnel less than 3000 feet long. This works out to only 1.2 feet of tunnel construction per day.