Virginia Pollutant Discharge Elimination System (VPDES) General Permit Regulation for Discharges Resulting from the Application of Pesticides to Surface Waters
[9 VAC 25 ‑ 800]
The City of Portsmouth Department of Public Utilities
I would like to comment on the proposed action to develop and issue a VPDES general permit for discharges from pesticides applied directly to surface waters as these actions may affect the usual operations and practices that the Public Utility undertakes in the management of our water supply reservoirs and treatment systems.
The utility is responsible for the storage, treatment, and conveyance of a safe and aesthetically pleasing water supply to our citizens and customers. We are already a highly regulated and closely monitored utility that continually strives to produce a safe water supply that is 100% within all current regulatory limits.
I cannot imagine that the development of the general VPDES permit will in any way contribute to improvements in the safety or quality of our drinking water or offer further environmental safeguards. New permitting requirements will needlessly create additional regulatory and operational burdens that must be borne by public utilities and add expenses which must ultimately be passed on to consumers as increased water rates.
Our utility currently uses pesticides specifically for the control of algae in our water supply reservoirs. The uses and selection of algaecide products is already regulated by requirements to comply with existing Federal Insecticide, Fungicide and Rodentcide Act (FIFRA) requirements and VA Department of Agriculture Pesticide Applicator Certificates. Further, the active Cu ++ ingredient of Copper Sulfate based algaecides is already a regulated contaminate in our drinking water. Algae control is important as blooms can create filter clogging problems and also release taste and odor forming compounds which are difficult to remove from the treatment process. Utilities fear having taste and odor outbreaks as the consumer losses confidence in the water supply and may even turn to unsafe alternate sources of drinking water.
The utility requires the flexibility to respond to algae problems within reservoirs when and where problem areas occur. Our utility uses a system of raw water monitoring, chemical monitoring, (MIB and Geosmin testing), Taste and odor profile testing, operational data and customer feedback to determine when and if an algaecide needs to be applied. Still, the unpredictable occurrences of algae blooms, particularly the blue-green algae most associated with taste and odor problems demand a freedom of action regarding treatment decisions that I fear will be hampered by further regulatory demands. I fear that additional regulations will only slow and burden our current program without any gains of safety to the environment or our water customers.
I would be very disappointed to lose the ability to use copper sulfate or peroxide type algaecides freely as my personal experience with our specific reservoir system, treatment plant and training has allowed up to this time. I would encourage the regulators to exempt public water suppliers from any further regulation in the proper use of these pesticides.
