The Town of Washington, located on U.S. Rt. 211 in Rappahannock County, needed to construct a new Wastewater Treatment Plant (WWTP). The Town has a Virginia Pollutant Discharge Elimination System (VPDES) permit to discharge 0.06 million gallons per day (MGD) to the Rush River in the Rappahannock River Basin. Unfortunately, the permit has zero waste load allocation. DEQ has agreed that the Town's offset for Total Nitrogen can be addressed by taking septic tanks offline within the Town. DEQ has not, however, given the Town any credit for Total Phosphorous (TP).  The Town is therefore in need of a point source waste load allocation offset of 183 lb/year of TP.  

DEQ informed the Town of Washington in 2008 that Spotsylvania County’s WWTP facilities have excess point source waste load allocation for Total Phosphorous.  DEQ in turn sent a letter to Spotsylvania County encouraging the County to assist Washington by providing an allocation of 183 pounds per year of Phosphorus on a temporary basis (the “Offset Allocation”), confirmed that Spotsylvania would retain its full Phosphorus allocation following the term of an offset agreement, and expressed its appreciation for Spotsylvania’s leadership and partnership in the Chesapeake Bay cleanup program. The Town respectfully requests that Spotsylvania County enter into the second amendment to the agreement to sell a 5 year allocation of the 183 lb/year of TP to the Town of Washington.

Spotsylvania County will bear no costs associated with the agreement or permits, etc. that may be required, and Spotsylvania will not lose any allocation.  The Town of Washington is bearing the cost of creating the agreement.

The County maintains an excellent reputation with DEQ. Any consideration that the County can afford the Town of Washington will engender goodwill with our sister jurisdictions and with DEQ.

DEQ sent confirmation to the County that (1) the state desires for the County to assist with the Total Phosphorus offset and (2) the County will retain its full Total Phosphorus wasteload allocation following the term of the original offset agreement. 

Alexandra Spaulding, Senior Assistant County Attorney

Edward Petrovitch, Assistant County Administrator/Director of Utilities                            Ben Loveday, Deputy Director of Utilities

 Doug Crooks, Wastewater Division Director

DEQ imposed stringent wasteload allocations on our two major wastewater treatment plants based on their design capacity and state-of-the-art nutrient removal technology performance.  The County plants have no issues meeting their discharge requirements for TP. While the County’s plants have no “excess” allocations, County staff believes it would be feasible to assist the Town with a Total Phosphorus offset, on a temporary basis, because our plants are currently operating below the full design capacity for which they were constructed.   

The table below summarizes the County’s allocations for TP and the amount of TP available for offsetting. As indicated below, the Town of Washington’s request represents 1.5% of our total allocation and 7.9 % of our net TP allocation available for offsets. The impact to the County is minimal. 

SPOTSYLVANIA COUNTY - ANALYSIS OF TOWN OF WASHINGTON TP OFFSET REQUEST:

County TP Allocations

FMC TP Allocation                                   4,934.00 

Massaponax TP Allocation                       7,309.00 

Total                                                       12,243.00 

County TP Load Estimate for 2017

FMC Plant Flow                                              2.58

Massaponax Plant Flow                                 6.88

Total Plant Flow                                              9.46

TP Concentration (Both Plants)                     0.30

TP Discharged Load Estimate             8,639.00

TP Allocation Available for Offsetting  

Total Allocation Less Load Estimate                         3,604 

"WQIF Held" Set Aside (FMC 1.4 MGD)                  1,279 

Net TP Allocation Available                                   2,325 

Town of Washington Request 

TP Requested                                                           183 

Request as % of Total Allocation                              1.5 %

Request as % of Net TP Allocation Available           7.9 %