Luray RV Resort and Campground on Shenandoah River is expanding and, as required, has submitted a permit request to the Virginia Department of Environmental Quality (DEQ). The permit will allow the discharge of up to 50,000 gallons per day of treated wastewater into the Shenandoah River. The permit will also allow the company to participate in nutrient trading in which the company purchases credits from the Town of Leesburg and their wastewater treatment plant to keep the level of nitrogen and phosphorous from increasing in the Chesapeake Bay.
DEQ staff reviewed all of the comments made in opposition to the permit which were submitted during the April 2023 public comment period, summarized and categorized the concerns and provided responses.
The six categories of concern include the following:
1. The South Fork Shenandoah River is already impaired, and authorizing an additional discharge will further impair the river.
Synopsis of DEQ response: the discharge levels, as permitted by DEQ, meet state standards for recreational use. Water quality will continue to be monitored.
2. The nutrient trading agreement for the proposed discharge is not protective of local water quality in South Fork Shenandoah River.
Synopsis of DEQ response: There are no local limits for nutrients, that is, nitrogen and phosphorous. However, there are for the Chesapeake Bay, so nutrient trading can occur at a facility anywhere in the watershed, along the South Fork Shenandoah River, the main stem and the Potomac River.
What You Can Do
Attend the Public Meeting*
Tuesday, June 20
Luray High School Auditorium,
243 Bulldog Drive, Luray, VA
*Only those who submitted comments during the April public comment period will be given the opportunity to respond to the agency’s summary directly—no new information will be accepted.
3. The RV resort and campground design characteristics may not have been clearly conveyed, the design of the wastewater treatment facility may need to be revisited, and DEQ does not have a technical review process.
Synopsis of DEQ response: The wastewater treatment facility will need to be designed, installed, and operated to ensure compliance with final, approved discharge limits. It is the responsibility of a licensed professional engineer in the Commonwealth of Virginia to certify that the project design adheres to the design requirements of the Sewage Collection and Treatment Regulations. Wastewater quality is monitored to ensure protection of the stream quality, and the wastewater treatment facility is inspected by DEQ staff to ensure compliance with all permit requirements, including proper operation and maintenance.
4. The wastewater treatment facility will be in the 100-year floodplain and may be adversely affected by flooding.
Synopsis of DEQ response: The engineer, not DEQ, determines the location of the facility. Based on info provided by the engineer, the wastewater treatment plant is approximately 10 feet above the FEMA-defined 100-year flood line and approximately 7.5 feet above the high-water line created by the effects of Hurricane Fran on September 7, 1996.
5. The applicant should consider disposing the wastewater on their own property in a drain field or hauling the wastewater off-site.
Synopsis of DEQ response: The applicant is able to choose how to spend their resources as long as the selected wastewater disposal option meets all statutory and regulatory requirements.
6. How compliance will be assessed and ensured at this wastewater treatment facility is not known.
Synopsis of DEQ response: All wastewater treatment facilities are routinely inspected, and DEQ inspectors have the authority to inspect a facility whenever they choose, at reasonable times. In addition, DEQ is committed to following up on any inquiries or complaints regarding the facility’s operation. Any noncompliance will the addressed through DEQ’s established compliance and enforcement procedures.
For a complete picture, read the full DEQ response here.