We asked for a public hearing on Water Quality Certification and we are getting it -
Thursday, July 12, 6:00 - 9:00pm at the Western Greenbrier Middle School in Crawley (same place as the public hearing on the Draft EIS).
It is vital that we have a good attendance and let the WV DEP know how much we care about water quality. I cannot stress how important turnout is, so mark your calendars and bring friends and neighbors.
Below are talking points for what to say, but if you aren't good at public speaking and your voice shakes as much as your knees, just say (after introducing your self and where you live), "I came because I want the Department of Environmental Protection to protect the Meadow River." Or, if you live in or near Rainelle, "I came because I want the Department of Environmental Protection to protect my supply of drinking water."
If you fish, raft, kayak, swim, or otherwise enjoy the Meadow River, mention that.
Keep watch for more information about this between now and the hearing.
Talking points:
The Legislative Rules for the Department of Environmental Protection Office of Water Resources states, "It is declared to be the public policy of the State of West Virginia to maintain reasonable standards of purity and quality of the water of the State consistent with (1) public health and public enjoyment thereof; (2) the propagation and protection of animal, bird, fish, and other aquatic and plant life; and (3) the expansion of employment opportunities, maintenance and expansion of agriculture and the provision of a permanent foundation for healthy industrial development."
Under Antidegradation Policy, the Legislative Rules make it clear that existing uses shall be maintained and protected.
The quality of the water of the Meadow River would suffer if the flow is significantly reduced, so the DEP should not grant 401 Water Quality Certification without conclusive scientific data that the Meadow River will be okay.
So far, to date, there has been no official information assuring that there will be enough water for the WGC plant. At the public hearing on the Draft EIS, DOE representatives admitted that studies were ongoing. We have not heard any results from those studies.
The Draft EIS did not specify a final plan for where the water would come from, just that they need 1200 gallons/min, that 500 gallons/min would come from the Rainelle Sewage Treatment Plant, and the rest would come from the Meadow River and/or local wells or maybe some additional source.
The problem is that both the Meadow River and the aquifer are at their lowest levels at the same time of the year. Furthermore, the effluent from the Rainelle Sewage Treatment Plant that used to go back into the river will now be completely subtracted from the Meadow River.
The information about the Meadow River was based on old data about flow with no studies about impacts on recreation or fish or other biota in the river.
The pump tests on the aquifer were so inconclusive that the consultant hired to evaluate groundwater pumping recommended further longer tests and stated that these further tests might indicate that long term pumping is not sustainable.
Following are the comments I filed about the water supply on the Draft EIS. If you would like to see the comments from the Appalachian Center, let me know and I will forward them.
The incompleteness of the Draft EIS regarding sufficient water supply is admitted on page 2 - 39, where it is stated, "Additional and ongoing groundwater studies are planned to better characterize the local aquifer and the effects of long-term pumping. These studies were not completed in time to be incorporated into the Draft EIS, but they are expected to be available for incorporation into the Final EIS." Conversations with Mark McKoy, geologist with DOE, at the January 4, 2007 public hearing confirmed that studies are ongoing and a sufficient water supply has not been confirmed. Mr. McKoy attempted to characterize this as an insignificant factor by saying that they did not feel they needed to be 100% certain of the water supply, but I submit that the following information demonstrates that they are a long way from 100%. * Page 2 - 37, 2.4.6 Water Supply, states that water supply requirements range from 900 to 1200 gallons per minute depending on seasonal fluctuations (with peak demand in the summer months). (Emphasis added) * Then on page 2 - 38, Figure 2.4-5 illustrates that it is during the summer months of peak demand that the primary water source, the RSTP, is lowest. * Page 2 - 39 goes on to admit, "Because there is some uncertainty regarding whether sufficient water would be available from either the Meadow River or groundwater sources under extended low recharge conditions, WGC has considered two options for supplemental process water supply for the power plant." These options are to use both the Meadow River and the groundwater aquifer; the options differ in which is to be the secondary and which the tertiary source.
The problem is that both the Meadow River and the aquifer are at their lowest levels at the same time of the year. * In fact, on page 4.4-12, Figure 4.4-5 illustrates that for over two months in August, September and October the Meadow River flow is below both 60% of the annual average flow and 60% of the average seasonal flow, yielding the sole conclusion that no water at all could be drawn from the river during this time. * In addition, in Appendix D, Groundwater Pump Test, the last statement on page 6, Model Predictions, is that 12 feet could be considered the additional drawdown to reflect short-term drought conditions.
Since short-term drought conditions occur during August, September and October, it is when no water can be drawn from the Meadow River, and the aquifer may already be down 12 feet from the summer drought, that the most water (at least 800 gallons per minute in addition to the RSTP) will be required to operate the plant.
The first paragraph on page 4.4-14 says it all, "Because of limited hydrologic data on the relationship between the aquifer and the Meadow River, there is an ongoing study on the local aquifer that would provide more insight on the aquifer's characteristics and to a better judge its availability and impacts during use. Also, a gage would be located on Meadow River near the intake structure (under either water supply option) as part of a daily check to monitor and record stream levels. Ongoing collection of river data would allow for a better understanding of the Meadow River's characteristics and along with the ongoing aquifer study, provide WGC more data for better water use decisions. Furthermore, the state would review the issues and provide recommendations to WGC. The forthcoming results from the aquifer tests, continuous monitoring of the river's behavior and correspondence with state agencies would help WGC decide on the best approach to supplying water for the project and minimize adverse impacts to water sources." The actions listed in this paragraph should be completed before a Draft EIS is published for comment.
Several other factors further enforce my conclusion that the Draft EIS is incomplete and inadequate: * All these figures are averages and/or estimates, so the reality at a given time could be even worse. * The data regarding Meadow River flow is from 25 years ago. * The choice is left open as to whether the Meadow River will be maintained at 60% of its annual average or 60% of its seasonal average flow. * In most instances where the 60% threshold for reducing the Meadow River flow is mentioned there is an added clause, "or another comparable withdrawal limitation measure determined in consultation with the state." This is an open-ended factor meaning the actual drawdown of the Meadow River may be an unidentified amount. * There is no resolution of the WGC alternatives identifying which source of water supply is to be secondary and which tertiary.
The absurdity of the water supply situation is illustrated on page 2 - 39, where it is stated that, "WGC is also investigating alternate groundwater sources outside the drawdown area for the WGC production wells for use as a potential third source of water." Here we have another potential area of environmental impacts that is not identified, not studied, and for which the public will have no opportunity to comment. Incidentally, since the Meadow River is one of three sources of water, the statement should have read "a potential fourth source of water."
Additional questions that should be answered by a Draft EIS follow.
Why were the following issues raised on page 1 - 7, Table 1 - 1 Issues Identified for Consideration in the EIS, not addressed? * Impacts from elevated stream temperatures from disposal of waste heat. * Impacts from acid rain and mercury deposition in streams. * Impacts from disturbance of the Anjean gob pile (at that time, the only gob pile identified as part of the project).
Appendix F, Stream Studies, contains Aquatic Biota Habitat Surveys of Two Streams in Rainelle, WV. Why was no such study conducted on the Meadow River?
How is the 60% threshold of the Meadow River flow justified? The Draft EIS refers to the Tennant Method, but this is a technique, not a study. The pertinent statement in the Draft EIS is, "A general rule of thumb is that serious degradation of habitat occurs beyond 30 percent of the annual average." Figure 4.4-4 on page 4.4-11 demonstrates that the monthly variability of flow in the Meadow River makes a "general rule of thumb" invalid in determining how much can be withdrawn from the river without affecting river health; and as noted above regarding Appendix F, no study was conducted of aquatic biota in the Meadow River.
Since the unsubstantiated 60% drawdown of the Meadow River is further qualified by the open-ended statement, "or another comparable withdrawal limitation measure determined in consultation with the state," how is the public to make substantive comments on the environmental impacts of an unknown amount?
There was scant mention of the monitoring needed to ascertain that the flow of the Meadow River is sufficient (supposing a sufficient flow is determined). Who will perform this monitoring? Who will have access to the monitoring data? What will be the procedure for alerting WGC plant operators when the Meadow River is below the required level of flow?
In conclusion, this Draft EIS should be withdrawn and redone, or a supplemental EIS should be issued when the above studies have been completed and the alternatives selected. Barring this, the no action alternative should be selected on the basis that no additional negative environmental impacts will occur.
Regarding the existing drainage from the Anjean and other gob piles, there are other alternatives for dealing with those impacts that, by its own admission, are beyond the scope of this document. Besides, the gob piles are currently being treated; and the environmental impacts of disturbing the gob piles and then having the project halted because it becomes financially unfeasible, lacks a sufficient water supply, or other result of the incomplete planning that characterizes the project so far, would be much worse than the no action alternative.
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