Comments on Source Water Protection Plan
Editor’s Note: This letter sent to WV Dept. of Health and Human Resources, Bureau for Public Health Source Water Assessment and Protection Program. We run it as a guest column for our readers.
Dear Ms. White and Mr. Rodenheaver,
I appreciate the opportunity to comment on the Source Water Protection Plan documentation for West Virginia. I strongly believe that source water protection is critical for public health and economic development in West Virginia, and I commend your staff for investing time and resources in this vital issue. My perspective on these issues is informed by my research as a biologist at the US Geological Survey’s Leetown Science Center (Kearneysville WV) where I address issues of water quality and climate change on river and stream ecosystems. I also serve on the Planning Commission in Shepherdstown where my responsibilities include considerations of storm water management and development. My comments here are exclusively my own and do not imply any endorsement or opinion by the US Geological Survey or the Shepherdstown Planning Commission.
I have reviewed the draft Source Water Protection Plan (SWPP, “Plan”) developed by the Thrasher Group in conjunction with the Shepherdstown Public Works Department. The Plan accurately describes the importance of source water protection and successfully identifies some key concerns and opportunities for improvement. I commend the authors of the Plan and the Shepherdstown Public Works Department for their attention to this important document. My main concerns can be summarized in three points.
1. The geographic scope of the Plan is too small.
The “zone of critical concern” (ZCC) and “zone of peripheral concern” (ZPC) are not large enough to encompass the true areas of concern for the Shepherdstown water system. I realize that travel-time guidance for ZCCs and ZPCs were defined by the State and are not subject to revision at the local level. Nonetheless, planning should address the physical reality of our situation: Shepherdstown’s water quality is influenced by conditions much further upstream than indicated by the Plan.
Events of 2015 clearly demonstrate this point. On 23 September 2015 a latex-solution release into the North Branch of the Potomac River traveled downstream to Shepherdstown and other municipal water intakes. We were fortunate in that (a) the public health risks of the chemical contaminants were low and (b) the plume was visible and therefore was reported (see comment #3 below). However, this event demonstrates clearly that we must be concerned with conditions further upstream than considered by the Plan. Moreover, the implication of defining a zone of “peripheral” concern is that locations past this zone are of less-than-peripheral concern (i.e., not a concern), but this clearly is not the reality of our situation.
2. The Plan lacks monitoring for the risks it documents.
As intended, the Plan identifies important risks to the Shepherdstown water system. Specifically, the Plan identified several “potential sources of significant contamination” associated with confined animal feeding operations, aboveground storage tanks, golf course management, and sludge and septic disposal operations. However, current and proposed monitoring described in the Plan appears to be largely disconnected to these recognized threats. The current approach of monitoring raw water for dissolved oxygen, pH, temperature, and conductivity is useful and necessary, but insufficient to identify contamination from the recognized risks. Even though Shepherdstown is a relatively small municipality, I believe we deserve an “early warning” monitoring system as required by larger municipalities in West Virginia. I recognize that this will require additional funding and staff support, but I believe that the benefits will likely outweigh the costs.
3. The existing spill monitoring network is insufficient because it relies on visual identification.
I was surprised that the Plan did not mention the spill monitoring network that currently exists for the Potomac River. The Potomac River Drinking Water Source Protection Partnership1 was formed in 2005 as a network of municipal water suppliers and government agencies (including the Town of Shepherdstown) focused on protecting sources of drinking water in the Potomac River basin. A complete Plan requires some acknowledgment of this important existing network, as well as a discussion of its vulnerabilities and opportunities for improvement. I was also surprised to see no mention of the Emergency Spill Model developed by the Interstate Commission on the Potomac River Basin (ICPRB)2 with flow travel-time data provided by the US Geological Survey. This tool was implemented with success during the North Branch latex spill last year, and needs to be addressed in the Plan. This requires more than simply listing the existing tools and networks in the Plan but also describing their strengths and weaknesses.
The Plan does not address one of our most important current vulnerabilities: our existing spill monitoring network assumes that contaminant plumes will be visible and therefore likely to be reported. This was the case in the North Branch spill of 2015 but was not the case in the Elk River spill in 2014, so a visual assessment of contamination provides little confidence for municipal water users. An obvious catastrophic event such as a train derailment or tanker crash on I-81 (although further upstream than the designated ZPC) would be reported quickly, and the DWSPP network would take action. However, many of the contaminant risks identified in the Plan are not likely to emerge from a publically visible location, nor are they likely to show obvious visible plumes. Therefore the existing spill monitoring network is incomplete, and the Plan should recognize this and provide recommendations for improvement.
In summary, the stated purpose of the Plan is to “assess, preserve, and protect the raw water source used to for their Public drinking Water Supply System” and I commend the efforts of the WV Department of Health and Human Resources and local municipalities for addressing these vital issues. The draft Plan provides important contributions for assessment of some of the upstream risks, but lags behind the targeted monitoring and incentives necessary for preservation and protection. I believe the final Plan would be greatly improved by addressing the three main points raised here.
Thank you for considering my comments on this matter. Please feel free to contact me for clarification or additional information.
Nathaniel (Than) P. Hitt, PhD