Eastern Panhandle Pipeline Stormwater Permit

Comment to WVDEP on Eastern Panhandle Pipeline Stormwater Permit  

The West Virginia Department of Environmental Protection (WVDEP) has released for public comment the state stormwater permit needed for the Eastern Panhandle Expansion Project (EP Pipeline). You can submit comments on the EP Pipeline Stormwater permit through January 19, 2018. If you have questions, please contact Autumn Crowe, acrowe@wvrivers.org.

ACCESSING AND REVIEWING THE PERMIT

Oil and Gas Construction Stormwater General Permit (WVR310880): For more info on this permit see our Guide to Stormwater Permits. View the permit application on WVDEP website.

SUGGESTED COMMENTS

Mountaineer Gas Company’s application for the EP Pipeline does not meet the requirements for the WVDEP Oil & Gas Construction Stormwater General Permit.

  • Final mitigation or avoidance measures of geologically sensitive karst areas are not included in the application.
  • Site-specific designs for stream crossing methods are not included in the application. Open cut crossings and underground boring is proposed, but the open cut method is not specified and there is no contingency plan for underground borings.
  • No descriptions of stream bank restoration and stabilization are included in the application. Restoration plans for stream crossings must be included.
  • The inspection frequency is not as stringent as other pipeline projects within the state. Inspections after 0.25 inch rain event should be required.
  • No water quality monitoring is proposed. Monitoring is not required, but can be requested. Water quality monitors should be installed at sensitive stream crossings similar to the efforts being conducted along proposed pipeline routes in VA.

SUBMIT COMMENTS TO WVDEP BY 8PM ON JANUARY 19th

  1. By email with the permit number (WVR310880) in the subject line: dep.comments@wv.gov or
  2. By mail referencing the permit number (WVR310880) in your letter:

Director, Division of Water and Management, DEP
ATTN: Sharon Mullins, Permitting Section
601 57th Street SE
Charleston, WV 25304-2345

Comment to WVDEP on Water Quality Impacts of the MXP

Comment to WVDEP on Water Quality Impacts of the MXP

The West Virginia Department of Environmental Protection (WVDEP) has released for public comment the state stormwater permit needed for the Mountaineer XPress Pipeline (MXP). You can submit comments on the MXP Stormwater permit through December 22, 2017. If you have questions, please contact Autumn Crowe, acrowe@wvrivers.org.

ACCESSING AND REVIEWING THE PERMIT

Oil and Gas Construction Stormwater General Permit (WVR310872): For more info on this permit see our Guide to Stormwater Permits. View the permit application on WVDEP website. View a map of the Mountaineer Xpress Pipeline route.

SUGGESTED COMMENTS

Stormwater Permit: MXP’s application does not meet the requirements for the WVDEP Oil & Gas Construction Stormwater General Permit.

  • The applicant has not demonstrated that impacts to water quality have been minimized.
  • Wet trench crossing methods are proposed for minor water bodies causing increased sedimentation in streams.
  • Impaired streams crossed by wet trench methods will exceed water quality standards and be unable to meet their total maximum daily load pollution prevention requirements.
  • The use of rip rap is proposed for stream restoration instead of WVDEP’s preferred method of restoration using natural stream channel design techniques.
  • Engineering calculations for the sizing of culverts are not included in the application.
  • Site-specific spacing distances for trench line barriers are not included in the application.
  • No water quality monitoring is proposed. Monitoring is not required, but can be requested. Monitors should be installed at sensitive stream crossings similar to the efforts being conducted along proposed pipeline routes in VA.

SUBMIT COMMENTS TO WVDEP BY 8PM ON DECEMBER 22nd

  1. You can submit comments through WV Rivers’ online commenting tool.
  2. By email with the permit number (WVR310872) in the subject line: dep.comments@wv.gov
  3. By mail referencing the permit number (WVR310872) in your letter:

Director, Division of Water and Management, DEP
ATTN: Sharon Mullins, Permitting Section
601 57th Street SE
Charleston, WV 25304-2345

Antero Landfill NPDES Permit Fact Sheet

Comment to WVDEP on Antero Landfill Permit

The West Virginia Department of Environmental Protection (WVDEP) Division of Water and Waste Management (DWWM) is accepting comments on Antero Landfill National Pollutant Discharge Elimination System (NPDES) Permit. The NPDES permit covers stormwater discharges from the Antero Landfill facility which will be used to dispose of the salt generated at the adjacent Clearwater water treatment facility. You can submit comments on the permit to WVDEP through May 11, 2017. If you have questions, please contact Autumn Crowe, acrowe@wvrivers.org.

SUBMIT COMMENTS TO WVDEP BY 5PM ON MAY 11th
  1. You can easily submit comments through WV Rivers’ advocacy tool here.
  2. By email with “Permit WV0117579: Antero Landfill NPDES” in the subject line: comments@wv.gov
  3. By mail referencing “Permit WV0117579: Antero Landfill NPDES” in your letter.
SUGGESTED COMMENTS

Enforceable Discharge Limits: The permit requires monitoring for over 40 different pollutants but it does not impose limitations on any pollutants. Without pollutant limits in the discharge water, there is no legal enforceable limit to require that pollutants remain under safe levels. Request that WVDEP impose limitations of pollutants in the discharge water.

Discharges in Source Water Protection Area: There are 13 outlets that will discharge into Cabin Run a tributary of the Hughes River, and an unnamed tributary of Dotson Run another tributary of the Hughes River. The Hughes River provides source water to the Hughes River Water Board.  There are no requirements limiting discharges within a source water protection area. Request that WVDEP impose strict pollutant limits to protect Hughes River, a drinking water source for thousands of people.

Permit Modifications: The permit allows for future modifications that would reduce the discharge locations the pollutants to be monitored if there are consecutive monitoring events that don’t show levels of certain pollutants or if pollutant levels appear similar at different locations. Request that WVDEP adhere to the pollutant parameters and locations in the original permit and not allow future modifications.

Radioactivity: The radiation detection system proposed for the landfill detects gamma radiation; however, Radium 226 and 228 have very little gamma radiation meaning it will take a lot of it to trigger an alarm in the radiation detection system. Therefor the radiation detection system will not be very effective. Request that WVDEP require monitoring of activity levels (pCi/g) for specific radioactive isotopes of Radium 226 and Radium 228.