COUNTY OF FAUQUIER
TO: Ray Graham
Chairman, Board of Supervisors
CC: Board of Supervisors
Kevin J. Burke, Acting County Attorney
FROM: Paul S. McCulla
DATE: March 22, 2005
RE: Executive Summary of Spray Irrigation of Athletic Fields Using
Reclaimed Water; A Review for Fauquier County
Report of Stone Environmental, Inc.
You have requested that I review the report of Stone Environmental, Inc. related to the possibility of spray irrigation of athletic fields using reclaimed wastewater on the property known as the Wampler tract which is located west of Catlett Road (Route 28) in Cedar Run District. The property has been identified as a potential site for the Southern Sports Field Complex. The developer of the property has suggested, in its proffered rezoning, that it would be willing to provide the County 100 acres of the 270 acre parcel for use as a park. In exchange for providing the property, the developer, however, would retain the right to use the 100 acre portion of the property for a collection, treatment, storage, and wastewater dispersal system which would be owned and operated by the Fauquier County Water & Sanitation Authority. While the report focuses on use of reclaimed water in many geographic areas of the nation and for
many purposes, I will limit my remarks to the portions of the report that discuss use of reclaimed water for irrigation of athletic fields as this appears to be the primary purpose intended under the suggested proffer agreement.
II. NATIONWIDE REVIEW OF PROJECTS:
The study reports that a number of states permit and have in service systems using reclaimed water for irrigation of ball fields and parks. Those states include Florida, North Carolina, Pennsylvania, Washington and California. It is important to note that the consultant was unable to find any instance in the Commonwealth of Virginia where reclaimed wastewater was being used to irrigate ball fields or parks. In addition, the consultant notes that the Commonwealth of Virginia does not have formal regulations relating to use of reclaimed wastewater to irrigate athletic fields and parks. The study notes that regulation would fall under the Department of Environmental Quality in consultation with the Virginia Department of Health. The consultant also recommends that the County and/or its water and sanitation authority should consider reviewing regulations in other states and adopting their own regulations prior to constructing a reclaimed wastewater irrigation system.
In the case of use of reclaimed wastewater for irrigation of ball fields, the consultant notes that there have been no confirmed cases of infectious disease in the United States where there has been compliance with appropriate regulatory controls. The consultant notes that regulations should be crafted to ensure that the potential for contracting disease is reduced to a minimum by addressing:
1) separation distances from potable water sources and pipes;
2) prevention of ability to tie in to reclaimed wastewater pipes for potable uses;
3) backflow prevention;
4) safeguard against converting potable water pipes to non-potable use;
5) isolating eating and drinking areas from irrigated wastewater reuse areas;
6) standards related to the application of reclaimed wastewater and the timeframe before public use may be made of areas to which used water has been applied.
In addition to the above standards, the consultant notes that site-specific issues related to soil conditions, topography, groundwater tables, etc., may result in and necessitate additional standards and requirements for the Wampler tract or any other property.
III. VIRGINIA REGULATIONS:
While Virginia does not have specific regulations related to the reuse of reclaimed water for irrigation of ball fields, it does have general regulations related to the use of reclaimed water for irrigational purposes. Those regulations are found promulgated by the Virginia Department of Environmental Quality and the State Water Control Board Collection and Treatment Regulations, specifically, 9 VAC 25-790-880. The DEQ has a permitting process for water treatment facilities which include spray irrigation, aerosol irrigation or drip irrigation that exceed a particular threshold. The consultant notes that the irrigation system proposed for use on the Wampler tract would exceed the DEQ permitting threshold and would be subject to the Virginia DEQ permitting process.
While the Commonwealth has general regulations in this area, the consultant notes that neither the Health Department, the County, nor the WSA have regulations relating to the application of reclaimed wastewater to properties. In addition, the consultant also states that no federal regulations directly govern water reuse practices in the United States.
At the present time, the Virginia Department of Environmental Quality’s on-line project database lists no permit records for any water reuse system in Virginia. While one project has been approved in York County, it was for industrial purposes and did not include spray irrigation. Consultant also notes that the Bristol Manor Golf Club has a wastewater treatment plant which uses spray irrigation to distribute treated effluent to a 5.2 acre site of the golf club which is used as a driving range.
IV. COMMUNITY INTERACTION:
The report discusses a number of projects within the states of Florida, North Carolina, California, Pennsylvania, South Carolina and Washington in which reused water has been used for spray irrigation on parks and recreation and ball fields.
The study notes that use of reclaimed water for irrigation elicits more public concern as the amount of public interaction with irrigation sites increases. As such, where reclaimed water is proposed for irrigation of parks, ball fields and other sites which involve high public use, such projects often elicit a high degree of public concern and consultant notes that large “reuse projects have been stopped in San Diego, San Antonio and in Florida due to public opposition.” The consultant recommends that public acceptance is often higher where the degree of human contact is minimal; protection of the public health is clear; protection of the environment is a benefit of reuse; promotion of water conservation is a benefit of reuse; the cost of treatment and distribution systems and technologies is reasonable; the community has high awareness of water supply problems; the role of reclaimed water in the overall water supply and hydrologic cycle is understood; the perception of the quality of reclaimed water is high; and confidence in the local management of public utilities and technologies is high. As such, the consultant recommends that community involvement in the project begin early on and that such involvement include public dialogue, information seminars, etc., in order to establish and maintain a high degree of public confidence and trust.
V. CONSULTANT RECOMMENDATIONS:
The consultant recommends the following actions be taken if the County intends to go forward with this project:
1) That the County, the Parks & Recreation Department, the WSA, the developer, the Department of Environmental Quality and the Virginia Department of Health meet early and often in order to hammer out the various agreements needed early in the process to make sure that all the internal stakeholders in the project are in agreement as to the approval processes to be used and the scope of the project.
2) Soil conditions, site layout, groundwater tables, etc., need to be properly identified for the site in order to determine whether or not the site is appropriate for its intended purpose.
3) A water balance and nutrient analysis should be performed and a hydrological analysis of depth and direction of actual groundwater should be performed to ensure proper placement of groundwater monitoring wells.
4) Ongoing soil and plant analysis will be needed to maintain ideal growing conditions.
5) Safety precautions and best management practices will need to be identified and adopted to minimize public contact including, for example, night-time application and use of low trajectory nozzles and buffers to reduce aerosol travel.
6) System operation and maintenance and monitoring plans need to be created as they are crucial to how well the system performs, which will be a major factor in whether the public perceives the system to be functioning well.
7) An engineering analysis of several alternatives on the site relating to treatment, storage and dispersal technologies should be completed along with preliminary cost estimates for each of those alternatives.
8) The WSA should perform a financial analysis to determine the expected user rates and the costs for the operation and maintenance of this facility.
9) The Department of Community Development and the WSA should consider whether to change their regulations to address spray field proposals for irrigation systems.
10) A comprehensive public education and outreach program should be identified, created, and implemented to build public support for this type of a system.
In short, the consultant notes that while no similar project has been implemented in Virginia at this time, such a project would appear both legally and, for the Wampler site, geologically feasible. Because the project will be the first in Virginia, it will be subject to a high level of scrutiny and, as such, proper planning and implementation including the identification of appropriate regulations, etc., would be absolutely necessary to ensure that the project is successful.
If you have any questions, please do not hesitate to contact me.