responsiveness summary to public comments - US Environmental ...

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2. Commenters were disappointed about Kit Creek not having been designated as a Class
C, Limited Warm Water Fishery stream by MDNR.
3. Notwithstanding present and future efforts to bring the Victoria Gardens MHP WWTF
into compliance, there are still concerns about contaminants remaining in the streambed due to
years of residue build-up from the WWTF.
EPA Response:
1. EPA’s basis for excluding Kit Creek from the 303(d) list is documented in Enclosure 1
to EPA’s April 29, 2003 decision letter to Missouri. EPA is not adding Kit Creek back to
Missouri’s list because Franklin County PWSD #3 is under a schedule to comply with final
effluent limitations at the WWTF. Some dates on the original schedule of compliance have been
extended until October 31, 2004 by MDNR in response to a request from Franklin County
PWSD #3 for additional time to study the proper solution for meeting the discharge permit total
residual chlorine (TRC) limit of .01 mg/l. MDNR issued a public notice proposing a
modification to the existing permit. If chlorination is elected over ultra-violet treatment, MDNR
will require de-chlorination thereby eliminating the toxicity concern for aquatic life in Kit Creek.
If ultra-violet treatment is chosen, then the need to de-chlorinate is moot.
2. Regarding comments seeking designation of Kit Creek as a Class C, Limited Warm
Water Fishery, EPA intends to encourage the State to complete the process for appropriately
classifying this waterbody.
3. With respect to the residue buildup concerns in Kit Creek, the CWA contains no
provision that gives EPA or the state authority to clean up or compel the WWTF to clean up
previously deposited residue from the WWTF serving the Victoria Gardens MHP. After
improvements have been made to the operation of the WWTF, in accordance with the
compliance schedule, residue in the stream may still continue to exhibit elevated BOD for a
while, but this will improve in time as the organic material degrades and becomes an inert solid,
and/or flushes out during rainfall events.
Peruque Creek
Comment: In general, objections were raised to MDNR’s listing of Peruque Creek
based on an opinion that data was lacking or insufficient, and that existing data is potentially
unreliable. Sedimentation problems in Lake St. Louis at the mouth of Peruque Creek doesn’t
mean that the upstream waters do not meet water quality standards. Alternately, another letter of
comment requested that the 2002 listings of Peruque Creek (4 miles of #217 and 8.5 miles of
#218) be approved for continuing study, observation, testing, and corrective implementation.
EPA Response: EPA approved MDNR’s decision to list Peruque Creek.