Comment to WVDEP on the Water Quality Impacts of the TeMa Facility

The proposed TeMa Facility, located in Jefferson County, would produce insulation and drainage systems for residential, commercial and industrial use. Stormwater runoff associated with the facility would drain into the Elk Run Watershed and the Chesapeake Bay Watershed.

Permit Available for Public Comment

The West Virginia Department of Environmental Protection (DEP) released for public comment Jefferson County Development Authority’s application for the NPDES permit WVG611874 for the TeMa Facility located in the Burr Industrial Park.

Suggested Comments

The proposed TeMa facility is located in karst topography and is in the wellhead protection area for Walnut Grove Utilities, North Jefferson Elementary School and within 1.5 miles of Harpers Ferry Water Works’ zone of critical concern. Because of these sensitive water resources, additional scrutiny of this facility and its potential impacts on water quality is warranted.

Drinking Water Impacts: This facility is located within the wellhead protection area for Walnut Grove Utilities, a half a mile from North Jefferson Elementary Wellhead Protection Area, and 1.5 miles from Harpers Ferry Water Works’ zone of Critical Concern. Because the facility is within and in close proximity to source water protection areas, monitoring is critical to protect drinking water resources. Analytical results should be shared with water utilities that could be potentially impacted from a pollution event.

Watershed Protection: The facility is located within the Chesapeake Bay Watershed. Restoration efforts are underway to improve the Chesapeake Bay and significant progress has been made. The region is currently developing Phase III of the Watershed Implementation Plan (WIP III). This facility will contribute to the impervious area associated with Industrial NPDES Permits. Load-based waste load allocations must be determined for this new source of pollution in the Chesapeake Bay Watershed.

Potential Pollutants: The permit lists floatable plastic pellets and zinc as potential stormwater pollutants associated with the facility. While there are monitoring requirements for zinc in the permit, there are no monitoring requirements for detecting plastic in the outfalls. There is no plan or Best Management Practices listed in the application to manage the plastic pellets and prevent them from entering the stormwater.

Karst Terrain: Pollutants leaving the facility are more likely to impact groundwater because of the karst terrain. Less than half a mile from the facility location, a sinkhole opened up in the Burr Industrial Park into which stormwater was draining without a permit. The sinkhole is currently being remediated and stormwater is being diverted. This is an example of how the groundwater has been and could be further impacted at the location. The Pollution Prevention Plan (PPP), which includes the Stormwater Pollution Prevention Plan and the Groundwater Protection Plan, submitted with the permit application makes no mention of the karst terrain and provides no specific details on how the groundwater will be protected from pollutants. More specific details must be included in the PPP. A Sinkhole Mitigation Plan should also be included with the permit application.

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