Turpentine Plant Discharge in City of Springfield
The following are official comments submitted to the Georgia Department of Natural Resources by the Georgia Conservancy regarding DRT America's Application to the City of Springfield for Industrial Pretreatment to Discharge
The Georgia Conservancy would like to submit this comment letter voicing our concerns and requesting more detail related to DRT America’s application in the City of Springfield. Our issues center on how DRTA could impact this environmentally important watershed. Much of this concern is due to a lack of information contained in the permit application and process information available for review.
Founded in 1967, The Georgia Conservancy is one of Georgia’s oldest nonprofit conservation organizations. Working to protect our coast for 50 years, the Georgia Conservancy is a statewide organization whose goal is to develop practical conservation solutions for protecting Georgia’s environment. Our water policy envisions a Georgia where all citizens enjoy clean and abundant drinking water, where diverse aquatic habitats are preserved for wildlife and recreation, and where water management is guided by a comprehensive state water management plan that is founded on sound science and ecological integrity. This vision is guided by public participation, and enforced through statutes and regulations.
The Georgia Conservancy has been involved in Ebenezer Creek conservation efforts for more than 35 years. The EPD review of this NPDES pretreatment permit is a critical step in the continued protection of Ebenezer Creek.
Specific concerns with this submittal are:
• Additional information is needed on the feedstock sources, characterization of the chemical composition, probable contaminants and related information. Will changes in source material change the operation of the processing plant and waste water treatment?
• Where has this chemical processing technique been used before, and is the proposed wastewater treatment process proven to be effective in such conditions? Has DRTA undertaken a treatability study to verify that the Membrane Batch Reactor (MBR) system will meet the limits? If so, can they share the results of that study?
• How large is the equalization tank? What type of MBR system is proposed: hollow fiber, flat plate or tubular? What membrane material?
• What hydraulic retention time in the aeration tank? What solids retention time (sludge age) would there be in the system? What mixed liquor/suspended solids concentration is planned? Is nutrient addition planned? Is foam suppression planned? What type of aeration system would they use?
• What data on wastewater characteristics is available (e.g. BOD, COD, TSS, oil and grease, temperature, pH)? How will they adjust pH?
• What are the contingency plans for spill control, power disruption and natural disasters?
For any questions regarding our official comments, please contact Georgia Conservancy Coastal Director Charles McMillan at firstname.lastname@example.org