Wild Virginia is encouraging the public to let the Virginia Department of Environmental Quality (DEQ) know that we want it to prevent per- and polyfluoroalkyl substances (PFAS) from being released to the James River in Scottsville.

Tune in to this podcast on what the status is on PFAS bills from this legislative session, and how you can get more involved in the process.

As described in the section below, you can submit comments right now to DEQ. We provide all of the information you need and suggestions for what to include in your comments.

DEQ is proposing to issue a new permit to allow a treatment plant to discharge treated wastewater to small tributaries and the James River. DEQ knows this discharge contains certain forms of PFAS, dangerous chemicals that will accumulate in the environment and the bodies of wildlife and people, but the Department has refused to place conditions in the draft permit to monitor or control these releases.

Please let DEQ know that its failure to address this PFAS threat is unacceptable and that you expect it to change the proposed permit to include appropriate monitoring and PFAS removal requirements.

This effort to insist that the state take necessary actions to protect the public and the environment from PFAS is part of our ongoing campaign: Preventing PFAS Pollution. Follow the link to read more about this campaign and follow our updates to make sure you know how to use your voice to advocate solutions.

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Commenting on Scottsville Discharge Permit and PFAS

Deadline for commenting is Thursday, March 14, 2024

How to Submit Comments

By email: austin.galbraith@deq.virginia.gov

By mail:  Austin Galbraith, Department of Environmental Quality (DEQ), Valley Regional Office, P.O. Box 3000, Harrisonburg, VA 22801

Refer to: VPDES permit No. VA0025470, Scottsville Water Resources Recovery Facility (WRRF)

Include: Your name, mailing address, and email address

The discharge: Wastewater flows into James River through two small tributaries. The discharge flows around through the stream that borders Dorrier Park, into Mink Creek, and then into the river less than 300 yards upstream from the boat ramp at Scottsville. The treament lant is designed to discharge up to 200,000 gallons/day. Sampling by the Rivanna Water and Sewer Authority (RWSA) shows that the discharge contains significant concentrations of PFAS (per- and polyflouroalkyl substances). Samples collected between May 2020 and September 2023 show PFAS as high as 178 nanograms/liter (ng/l) in discharged water and averaged 82 ng/l.

The permit: DEQ’s draft permit and the background documents fail to address the risks of PFAS from the discharge and does not even mention that PFAS have been found in releases to the small streams and the river.  

Suggested Comments

• Describe your interests in and/or use of state waters, including the James River downstream from the discharge and/or in the small tributaries receiving pollutants from the plant.
• The RWSA’s data shows that PFAS are present in the discharge and threaten human health, wildlife, and the affected environments. DEQ has failed to disclose this in its documents.
• DEQ must perform its duty under the Clean Water Act and State Water Control Law to DEQ identify and control all pollutants that are or may be present in a permitted discharge and which may cause violation of water quality standards in the affected waterbodies. DEQ has failed to do so in the draft permit.
• DEQ must include requirements for continuing monitoring of PFAS at the plant as part of the permit.
• Describe any special experience or expertise you have that can help inform or strengthen your comments (e.g. medical, scientific, engineering backgrounds; fishing or boating guide/outfitter on the river; legal background; etc.).
• Ask DEQ to hold a public hearing – Explain that you want this opportunity to allow for wider public education and involvement in the process and to give more people the chance to speak and influence the decision. As required in the public notice include: A brief, informal statement regarding the nature and extent of you interest and those of any others you represent and describe “how and to what extent such interest would be directly and adversely affected by the permit.” Note that DEQ must change the permit to require monitoring and proper limitation on PFAS discharges to enforce water quality standards.

View more on what PFAS is by visiting our campaign page.

WHY ARE PFAS CONCERNING?

Scientific studies show that PFAS, even at low levels, pose significant risks to human health. Risks include cancers (prostate, kidney, and testicular cancers); harm to fetal and infant development; increased cholesterol levels; increased obesity risk; reproductive effects (decreased fertility, increased high blood pressure during pregnancy); and reduced immune system function. Wildlife experience similar health effects.

HOW DOES EXPOSURE OCCUR?

Polluted water is a major pathway of exposure. Such pollution is due to PFAS discharges into surface waters and groundwater from industrial users, firefighting foams, wastewater treatment plants, and biosolids (sewage sludge). Notably, conventional water treatment processes do not remove PFAS from drinking water. Consuming food contaminated with PFAS, including fish or shellfish from polluted waters as well as game meat, is another major pathway of exposure.

More detailed information can be found through the following websites:

U.S. EPA, PFAS Explained

Centers for Disease Control and Prevention, Per- and Polyfluorinated Substances (PFAS) Factsheet