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General Assembly
RICHMOND
November
23,
2015
Mr.
David
Paylor
Director
Virginia
Department
of
Environmental
Quality
P.O.
Box
1105
Richmond,
VA
23218
RE:
60-day
extension
for
comments
on
the
Possum
Point
draining
permit
Dear
Director
Paylor:
Thank
you
for
the
public
information
session
on
November
18,
2015
regarding
permitting
actions
for
Dominion's
Possum
Point
coal
ash
ponds,
including
the
pending
VPDES
permit
modification
for
draining
Pond
D.
You
and
your
staff
have
been
very
helpful
to
our
fellow
lawmakers
and
the
public
to
help
us
better
understand
this
very
important
issue.
Based
on
what
we
have
learned
so
far,
we
believe
the
complexity
of
this
issue,
and
the
volume
of
technical
information
related
to
the
permit
modification,
warrant
additional
time
for
public
review
and
comment.
The
draft
permit
and
Fact
Sheet
are
over
300
pages,
and
the
proposed
dewatering
action
has
never
been
undertaken
in
the
Commonwealth
of
Virginia.
Several
of
Delegate
Surovells
constituents
at
the
public
hearing
told
him
they
only
found
out
about
the
action
through
his
email
message
or
blog
post.
It
is
not
clear
to
us
that
the
public
is
fully
aware
that
actions
are
proceeding.
We
should
endeavor
to
do
this
right
from
the
outset
to
set
a
strong,
protective
precedent
for
our
state.
Moreover,
we
are
not
aware
of
any
urgent
circumstances
that
would
require
the
draining
of
Pond
D
as
soon
as
possible.
There
also
remains
a
concerning
lack
of
specific
information
on
the
volume
of
metals-laced
water
to
be
discharged
and
the
rate
of
discharge,
as
well
as
scant
information
on
the
baseline
environmental
conditions
in
Quantico
Creek.
DEQs
Special
Study
for
assessing
contamination
in
the
Creek
will
not
be
completed
prior
to
making
a
decision
on
whether
to
allow
the
dewatering
discharge.
Finally,
the
issue
of
the
surface
water
discharge
from
the
Pond
D
toe
drain,
which
is
documented
to
contain
coal
ash
metals,
has
not
been
fully
addressed,
and
no
limits
on
metals
have
been
proposed
for
this
waste
stream.
In
light
of
this,
we
think
the
public
is
best
served
by
having
additional
time
to
review
the
permitting
information,
attend
the
public
hearing
on
December
8,
and
have
the
time
available
following
the
hearing
to
obtain
additional
information
from
DEQ
to
inform
public
comments.
Therefore,
we
are
requesting
a
sixty-day
extension
of
the
public
comment
period,
which
is
currently
slated
to
end
on
December
14,
to
allow
additional
time
for
review
and
allow
independent
consultants
to
better
inform
us
about
potential
impacts
to
receiving
waters
and
potential
public
health
issues
we
may
want
to
consider.
Alternatively,
it
seems
to
us
that
additional
information
is
necessary
to
complete
the
permit
process
at
least
relating
to
the
toe
drain.
If
their
application
is
incomplete,
we
would
think
that
would
merit
additional
time.
Thank
you
for
considering
this
request.
Please
let
us
know
if
you
have
any
information.