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Miamiville Civic Association
PO Box 176, Miamiville, OH 45147 |
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Mr. Ron Ware 15 January 2004
Ohio EPA
Division of Surface Water
401 East Fifth Street
Dayton, OH 45402
Dear Mr. Ware:
We are writing this letter as a follow up to the previous letter we sent you after our December 18 meeting with Clermont County officials: Commissioners Bob Proud and Mary Walker, Administrator David Spinney, Utilities Director Tom Yeager, and others. We have previously stated some objections to the proposed WWTP plant being located in Miamiville.
You recently informed me that you will be making a decision on Clermont County's application for permit to discharge to the Little Miami River within the next two months. We have additional concerns of both an engineering/technical and environmental nature, which we believe need to be examined before any further consideration is given to the proposed Miamiville location.
First of all Clermont County has applied for a permit to discharge in Miamiville, to the un-named tributary, while stating to us that they will explore the Horner's Run area as a plant location. This would necessitate transporting the effluent a considerable distance, and the use of lift stations, to pump it to the point of discharge. We would like to know if there is any real possibility that OEPA would consider allowing the plant to be located anywhere other than naturally flowing to the point of discharge.
Next, the county has asserted that their number one reason for the construction of the proposed treatment facility is to protect the MGS water supply, which is located in Miamiville. If public health, and not additional development is the primary objective, then does it not make more sense to locate the point of discharge at the Horner's Run tributary, which is down river from the MGS wellhead? The county is requesting that EPA allow them to increase the amount of contaminated water that will be introduced to the aquifer by 1000 times!
We request that OEPA consider the absorption rate of the ground under and around the un-named tributary in Miamiville. The Miamiville location would directly access the MGS aquifer through the creek bed with sand and gravel below, which has minimal resistance to the aquifer. It would thus be an ineffective barrier to the additional 2MGD effluent that would be introduced from the proposed plant. In fact, many times during the year all the water flow is absorbed before it reaches the Little Miami. Clermont County has rationalized the installation of sewers in this area would correct the problem of septic system's waste water being absorbed through the sand and gravel. Yet they are proposing to send all the waste water from nearby homes and business to the same area the absorption problem exists. What is the rational? Horner's Run tributary on the other hand, would not directly access the MGS well field, is a limestone creek bed, and would therefore provide a natural barrier to the additional flow.
One glaring problem with Clermont County's application is that they made no change to their original proposal to use Earthtech to write an operation and maintenance manual, and operate the plant. This is the same company who so inadequately operated the Lower East Fork plant, that Clermont County terminated their contract, retained the bond posted by Earthtech, and has been cleaning up the sewage and legal mess ever since. The Business owners several miles away in Milford continue to complain that the smell has driven away customers. If the county is no further prepared to offer a better solution for maintenance of a new plant, how can we trust them to operate the new plant with the additional burden on and degradation of the water quality?
Back to the question of protection of drinking water and overall water quality in the Little Miami, why does Clermont County and OEPA continue to allow the Lake Remington trailer park to pump raw sewage into the river, while their application does not propose correcting this problem until the last phase of improvements to the Loveland/Horner's Run area, as seen in exhibit 10 of the application? In fact it is listed as #13 on the list of 15 items, and not scheduled to be completed until 2010, at the very earliest?
The last item of discussion is the Conservation easement that has been recently brought up by the county as a reason to prohibit Horner's Run from consideration as a location. If it has been so designated, we request that OEPA consider that at least the discharge could flow through the area, if a plant were located above Horner's Run, but outside of the boundaries of the future conservation area. One of the county's existing package plants already discharges effluent to the Horner's Run tributary, through the land in question.
Please consider the above concerns as part of the decision making process, in addition to our overriding plea to give the hundreds of residents of Miamiville, and the thousands of families living in the surrounding area who pass by Miamiville daily, and our quality of life, more weight than will be given to a different location, in which there are virtually no residents.
We also request that you meet with us to perform an on site inspection of all areas under consideration for possible plant location, prior to your decision on the application that is before you. Thank you for your help, and for working with us on this very important matter.
Sincerely,
Marie A. Brown
President
Miamiville Civic Association