Comment

TM 12: Question: to replace the drainfield at FMS, what was the reasoning to double the existing structure. Could the structure be more than doubled? Also if nitrogen concentrations in the treated wastewater effluent are significantly less (?10X or so) than that of the septic system couldn’t it be argued for a much higher flow limit in the permit?

Response

More than doubling the infiltration at that location could potentially lead to mounding of water and this could lead to flow paths, and mixing zone impacts that are difficult to predict. More research on groundwater and strata is needed to just permit the doubling of infiltration. In the process of that research effort, additional disposal capacity could potentially be identified. Data collected during operation will also provide information on whether the ultimate disposal capacity can be increased at this location.