Comment to WVDEP on Water Quality Standards Revisions


Water Quality Standards are the legal basis for controlling the amount of pollution entering our waters. WVDEP has released their proposed changes to West Virginia’s Water Quality Standards for public comment. View the proposed revisions here.

You can submit comments on the proposed revisions through July 10, 2018. WV Rivers made it easy to submit comments online here. You can also submit comments in person during a public hearing on July 10 at 6:00pm at the WVDEP headquarters in Charleston.

Key Revisions and Suggested Comments

Human Health Criteria. EPA has updated the National Recommended Water Quality Criteria to protect human health for 94 chemical pollutants. These criteria set limits on the allowable amount of the chemicals to be present in a waterbody. EPA’s updates reflect the latest scientific information. WVDEP has chosen to only adopt the updated criteria for 56 pollutants.

Request: Adopt all 94 recommended criteria. Doing so would proactively equip WVDEP with protective pollution limits should any of the 94 chemicals be discharged in WV.

Overlapping Mixing Zones. Revisions allow for overlapping mixing zones containing pollutants most dangerous to human health. Mixing zones are toxic hot spots where pollutants are allowed to be discharged at levels that exceed safe standards, relying on eventual dilution of pollutant concentrations to safer levels. Overlapping mixing zones can lead to higher pollution concentrations and potential interactions between pollutants.

Request: Add language to the rule that requires evaluation of potential human health impacts caused by cumulative effects and interactions between different pollutants, as recommended by EPA, prior to approval of any overlapping mixing zone.

Request: Require signage that warns the public that the waterbody contains high levels of pollutants harmful to human health, and that contact with the water or consumption of fish harvested in the area could have severe health impacts. The signage should also include a graphic depicting the toxicity of the water for individuals that cannot read English.

Harmonic Mean to calculate discharge limits . Remember the toxic water bill, aka “Cancer Creek bill”, the WV Legislature passed in 2017? Now it’s being implemented with the proposed changes in this rule. The consequence is more toxins and cancer-causing chemicals allowed in our water. The new method, harmomic mean, puts at us risk for short-term exposure.

Request: Include discretion to apply a more protective method for calculating discharge limits for pollutants that are known to harm human health through short-term exposure.

How to Comment

Submit comments online here.

Submit comments by mail, reference “Triennial Review (47CSR2)” in your letter:

Laura Cooper
Water Quality Standards, DWWM
WV Department of Environmental Protection
601 57th St. S.E.
Charleston, WV 25304

Submit comments at the public hearing:

When: July10, 2018 at 6:00pm
Where: Coopers Rocks Room, WVDEP Headquarters
Charleston, WV 25304

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