버지니아 규제 타운홀
기관
환경 품질 부서
 
보드
주 수자원 관리 위원회
 
chapter
지표수에 살충제 살포로 인한 배출에 대한 버지니아 오염물질 배출 제거 시스템(VPDES) 일반 허가 규정 [9 VAC 25 - 800 ]입니다.
액션 살충제 배출에 대한 일반 VPDES 허가
스테이지 제안
댓글 기간 12/27/에서 종료2010
스페이서

4 댓글

이 포럼의 모든 댓글
댓글 목록으로 돌아가기
10/27/10  11:06 오전
댓글 작성자: 댓글 작성자: 톰 워머스, Cygnet 엔터프라이즈, Inc.

EPA/NPDES 상황을 최대한 활용하기....
 

VA DEQ가 EPA의 새로운 NPDES 규정을 인정하고 준수하면서도 중복되고 비용이 많이 들며 불필요한 것으로 쉽게 발견되는 새 규정의 일부를 해결할 수 있는 주 허가를 제안한 것은 다행입니다. 첫 번째 "운영" 기간은 2년으로 하는 것이 좋습니다. 이렇게 하면 해당 허가에 대한 약속 시간을 상당히 짧게 유지하면서 규제 당국이 새로운 일반 허가 초안 작성을 시작할 수 있는 충분한 시간을 확보할 수 있습니다(원하는 경우). 등록 명세서, 수수료 요건을 없애고 개인 기록 및 독점 정보 보고를 최소화함으로써, 제안된 허가는 관련자(대행사 및 신청자)에게 시간과 비용 모두에서 최소한의 비용으로 증명될 수 있습니다.

그러나 VA 버전의 NPDES 허가는 규제 수레바퀴가 움직이기 시작하면 발생하게 될 다른 문제를 해결할 수 없습니다. 한 가지 고려해야 할 점은... 향후 발생할 수 있는 소송에 대해 청정수법의 적용을 받는다는 점입니다.  수중 서식지와 자원을 깨끗하게 유지하고 보존하며 이러한 환경의 지속성을 보장하기 위해 노력하는 기업들은 이러한 유형의 법률에 따라 부과되는 법적 비용으로 인해 큰 영향을 받을 수 있습니다. 

 

댓글ID: 14510
 

12/13/10  8:55 오전
Commenter: Sarah C. Tarallo, City of Manassas

VPDES for Pesticides
 

The City of Manassas would like to make these following comments:

1)      It is the City’s request that municipalities that are already regulated under the Department of Conservation (DCR) MS4 storm water program be exempt from this regulation. This would be effectively layering the regulatory process, which is not beneficial and would only result in additional paperwork and permitting costs that are unnecessary for cities/counties in the Commonwealth.
2)      The City would request an exemption for jurisdictions within the Commonwealth that own, maintain, and operate their own water supply reservoirs for drinking water purposes. These water supplies have historically been responsible for treating aquatic weeds and algae for water quality control purposes for the control of organics entering the Water Treatment facility. These Water Treatment Plant’s (WTPs) are permitted and regulated by the Virginia Department of Health (VDH) and as such should not fall under a separate VPDES permit.
3)      Currently, the City is monitoring and reporting under the Department of Environmental Quality (DEQ) Individual VPDES permit for discharges that occur at an outfall into Broad Run. Since the Algaecide applied at the Lake is housed on the Water Plant property, this chemical is reported in our current VPDES permit as a method of algae removal from our Lake
4)      The City requests an exemption for municipalities currently under water quality monitoring programs to maintain water quality issues as they arise. The City’s main water supply, Lake Manassas, has been continuously monitored for various water quality indicators through the Occoquan Watershed Monitoring Laboratory (OWML) through Virginia Tech., since the 1970’s. Additional monitoring and testing is redundant.
댓글ID: 14743
 

12/20/10  4:57 오전
Commenter: SD, Water Ltd

Solutions
 

The earliest precursor of pollution generated by life forms would have been a natural function of their existence. The attendant consequences on viability and population levels fell within the sphere of natural selection. These would have included the demise of a population locally or ultimately, species extinction. Processes that were untenable would have resulted in a new balance brought about by changes and adaptations. At the extremes, for any form of life, consideration of pollution is superseded by that of survival.

For humankind, the factor of technology is a distinguishing and critical consideration, both as an enabler and an additional source of byproducts. Short of survival, human concerns include the range from quality of life to health hazards. Since science holds experimental demonstration to be definitive, modern treatment of toxicity or environmental harm involves defining a level at which an effect is observable. Common examples of fields where practical measurement is crucial include automobile emissions control, industrial exposure (e.g. Occupational Safety and Health Administration (OSHA) PELs), toxicology (e.g. LD50), and medicine (e.g. medication and radiation doses).

"The solution to pollution is dilution", is a dictum which summarizes a traditional approach to pollution management whereby sufficiently diluted pollution is not harmful.[35][36] It is well-suited to some other modern, locally scoped applications such as laboratory safety procedure and hazardous material release emergency management. But it assumes that the dilutant is in virtually unlimited supply for the application or that resulting dilutions are acceptable in all cases.

Such simple treatment for environmental pollution on a wider scale might have had greater merit in earlier centuries when physical survival was often the highest imperative, human population and densities were lower, technologies were simpler and their byproducts more benign. But these are often no longer the case. Furthermore, advances have enabled measurement of concentrations not possible before. The use of statistical methods in evaluating outcomes has given currency to the principle of probable harm in cases where assessment is warranted but resorting to deterministic models is impractical or unfeasible. In addition, consideration of the environment beyond direct impact on human beings has gained prominence.

Yet in the absence of a superseding principle, this older approach predominates practices throughout the world. It is the basis by which to gauge concentrations of effluent for legal release, exceeding which penalties are assessed or restrictions applied. The regressive cases are those where a controlled level of release is too high or, if enforceable, is neglected. Migration from pollution dilution to elimination in many cases is confronted by challenging economical and technological barriers.http://en.wikipedia.org/wiki/Pollution http://www.private-medical-insurances.co.uk/ http://www.car-tinted.com

 

댓글ID: 14801
 

12/27/10  4:50 오후
Commenter: Matthew J. Lohr, Commissioner, VA Dept of Agriculture and Consumer Services

9VAC 25-800 - General VPDES Permit for Pesticide Discharges
 
The Virginia Department of Agriculture and Consumer Services (VDACS) administers the provisions of Virginia's pesticide statute, Chapter 39 of Title 3.2 of the Code of Virginia, as well as the regulations promulgated by the Virginia Pesticide Control Board. VDACS also has delegated authority to enforce the provisions of FIFRA (the Federal Insecticide, Fungicide and Rodenticide Act). As such, VDACS is the primary agency for the regulatory oversight of pesticides in the Commonwealth. 
 
VDACS and other members of the National Association of State Departments of Agriculture (NASDA) have voiced concerns about the 2009 ruling by the Sixth Circuit Court of Appeals in National Cotton Council v. U.S. Environmental Protection Agency that considered pesticide applications "in, over, or near" waters of the U.S. subject to permits under the Clean Water Act, rather than FIFRA.  VDACS believes that the Court's decision failed to consider existing pesticide-related regulations under FIFRA while simultaneously expanding the scope of the Clean Water Act.  We also believe that pesticide applications made in accordance with FIFRA adequately provide for human health and environmental protections and should therefore not be further regulated under the Clean Water Act. Nonetheless, we recognize that this particular regulatory action by the Virginia Department of Environmental Quality (DEQ) emanates from the Court's decision.
 
VDACS believes that the proposed regulation needs (i) to adequately reflect VDACS authority to administer the pesticide statute, (ii) to be compatible with the regulations promulgated by the Virginia Pesticide Control Board, and (iii) to impose on the regulated community only the administrative and financial burdens essential to complying with the Court's decision. 
 
VDACS offers the following specific comments:
 
·        As currently defined, the term "Operator" could lead to confusion because it provides that more than one person could be responsible for the same discharge resulting from a pesticide application.  VDACS recommends that responsibility for compliance with the requirements of the general permit be assigned to the person who actually makes the decision to apply a pesticide that results in a discharge.
   
·        The current thresholds in the general permit above which an operator must meet the requirements of the permit, including development of a pesticide discharge management plan, were not determined based upon actual data collected but rather were incorporated directly from the thresholds established in the draft federal permit. VDACS recommends that DEQ work with relevant Virginia stakeholders to determine appropriate thresholds in the Commonwealth.
 
Finally, VDACS recognizes the magnitude of the outreach efforts that will be necessary to ensure compliance by licensed pesticide businesses and certified pesticide applicators. VDACS stands ready to assist DEQ in these efforts.
댓글ID: 14823